Viking Global Investors LP: investment adviser

VGI manages the following private investment funds (together with any other fund or vehicle VGI may advise in the future, collectively, the “Funds”): the Viking Global Equities Funds (the “VGE Funds”), long/short hedge funds launched on October 1, 1999; the Viking Long Funds (the “VLF Funds”), long-only funds launched on January 1, 2009; the Viking Global Opportunities Funds (the “Hybrid Funds”), public/private hybrid funds launched on January 1, 2015; the Viking Global Drawdown Funds (the “Drawdown Funds”), private equity funds launched on October 1, 2021; the Viking Structured Capital Funds (the “Structured Capital Funds”), credit and structured capital funds launched on March 1, 2023; and the Viking Global Vintage IV Funds (the “Vintage IV Funds” and together with the Drawdown Funds, the “Vintage Funds”), private equity funds launched on October 1, 2025. O. Andreas Halvorsen is the principal owner and a co-founder of VGI. Mr. Halvorsen owns interests in VGI directly, as a limited partner, and indirectly, as a member of Viking Global Partners LLC, a Delaware limited liability company that is the general partner of VGI. B. Description of Advisory Services. 1. Advisory Services. VGI serves as the management company of the Funds. The VGE Funds include (1) Viking Global Equities LP, a Delaware limited partnership, (2) Viking Global Equities II LP (the “VGE Employee Fund”), a Delaware limited partnership offered only to VGI’s principals, certain qualified employees, and other VGI-related persons, such as family investment vehicles, charitable organizations, and estate planning vehicles associated with VGI’s principals and qualified employees (collectively, “Viking Affiliates”), and (3) Viking Global Equities III Ltd., a Cayman Islands exempted company. The VGE Employee Fund is classified as an “employees’ securities company” pursuant to Section 2(a)(19) of the Investment Company Act of 1940, as amended. In addition, VGI serves as management company to Viking Partners Fund LP, a Delaware limited partnership offered only to Viking Affiliates. Viking Global Equities III Ltd. invests substantially all of its assets in VGE III Portfolio Ltd., which in turn invests substantially all of its assets in Viking Global Equities Master Ltd. Viking Partners Fund LP, which is offered only to Viking Affiliates, invests substantially all of its assets in Viking Global Equities LP, Viking Global Equities II LP, and VGE III Portfolio Ltd. Viking Global Equities LP invests substantially all of its assets in Viking Global Equities Master Ltd. Viking Global Performance LLC (“Viking Performance”), a Delaware limited liability company affiliated with VGI, serves as either general partner or investment manager of each VGE Fund. The VLF Funds include (1) Viking Long Fund LP, a Delaware limited partnership, (2) Viking Long Fund III Ltd., a Cayman Islands exempted company, and (3) Viking Partners Long Fund LP, a Delaware limited partnership. Viking Long Fund III Ltd. invests substantially all of its assets in Viking Long Fund Intermediate LP, which in turn invests substantially all of its assets in Viking Long Fund Master Ltd. Viking Long Fund LP also invests substantially all of its assets in Viking Long Fund Master Ltd. Viking Partners Long Fund LP, which is offered

only to Viking Affiliates, invests substantially all of its assets in the VLF Funds. Viking Long Fund GP LLC (“VLF GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner or investment manager of each of the VLF Funds. The Hybrid Funds include (1) Viking Global Opportunities LP, a Delaware limited partnership and (2) Viking Global Opportunities III LP, a Cayman Islands exempted limited partnership. Viking Global Opportunities III LP typically invests substantially all of its assets in Viking Global Opportunities Intermediate LP, which in turn typically invests a substantial portion of its assets in Viking Global Opportunities Master LP, a Cayman Islands exempted limited partnership (the “Hybrid Master Fund”). Viking Global Opportunities LP also typically invests a substantial portion of its assets in the Hybrid Master Fund. The Hybrid Funds may, and from time to time do, make investments other than through the Hybrid Master Fund, including through special purpose vehicles. The Hybrid Master Fund typically invests substantially all of its assets in Viking Global Opportunities Liquid Portfolio Sub-Master LP and Viking Global Opportunities Illiquid Investments Sub-Master LP. Viking Global Opportunities GP LLC (“Hybrid GP”), or its wholly owned subsidiary, Viking Global Opportunities Portfolio GP LLC (“Hybrid Portfolio GP”), each a Delaware limited liability company affiliated with VGI, serves as the general partner of each of the Hybrid Funds. The Vintage Funds include (1) Viking Global Opportunities Drawdown (Onshore) LP, a Delaware limited partnership, (2) Viking Global Opportunities Drawdown (Offshore) LP, a Cayman Islands exempted limited partnership, (3) Viking Global Opportunities Vintage IV (Onshore) LP, a Delaware limited partnership, and (4) Viking Global Opportunities Vintage IV (Offshore) LP, a Cayman Islands exempted limited partnership. Viking Global Opportunities Drawdown GP LLC (“Drawdown GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner of the Drawdown Funds. Viking Global Opportunities Vintage IV GP LLC (“Vintage IV GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner of the Vintage IV Funds. The Vintage Funds and the Hybrid Funds are referred to herein, collectively, as the “Opportunities Funds.” Viking Partners Opportunities Fund LP, which is offered only to Viking Affiliates, invests a substantial portion of its assets in the Opportunities Funds. The Structured Capital Funds include (1) Viking Structured Capital (Onshore) LP, a Delaware limited partnership, (2) Viking Structured Capital (Offshore) LP, a Cayman Islands exempted limited partnership, and (3) Viking Structured Capital (Offshore 2) LP, a Cayman Islands exempted limited partnership. Viking Partners Structured Capital Fund LP, which is offered only to Viking Affiliates, invests substantially all of its assets in Viking Structured Capital (Onshore) LP. Viking Structured Capital GP LLC (“Structured Capital GP”) or Viking Structured Capital Portfolio GP LLC (“Structured Capital Portfolio GP”), each a Delaware limited liability company affiliated with VGI, serves as the general partner of each of the Structured Capital Funds and the Structured Capital Sidecars (as defined below). References to the Structured Capital Funds generally also apply to the Structured Capital Sidecars except as otherwise described in this Brochure or as the context otherwise requires. VGI has established the Structured Capital Sidecars and may in the future establish additional investment vehicles, SMAs, or other accounts or arrangements through which one or more persons invest alongside one or more Funds (each, a “Co-Investment Vehicle”). CoInvestment Vehicles may be formed on a transaction-by-transaction basis or to pursue multiple investments, whether on an opportunistic or systematic basis. For purposes of this Brochure, where appropriate and as the context permits, references to “Funds” also include any CoInvestment Vehicles.

VGI has engaged its affiliates located in the United Kingdom (“UK”) and Hong Kong to provide investment research, analysis, recommendations and advice, and trade execution services. 1 VGI and its affiliates assume full responsibility for any fees payable to such affiliates in connection with their provision of services. Viking Global Investors Europe LLP, the UK affiliate (“Viking Europe”), and Viking Global Hong Kong Limited, the Hong Kong affiliate (“Viking Hong Kong”), are each authorized to exercise discretionary investment authority over a portion of the assets of certain Funds. References herein to “VGI” shall be deemed to include Viking Europe and/or Viking Hong Kong where applicable. References herein to “Viking” shall be deemed to include VGI and its affiliates, including Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP. This Brochure generally includes information about VGI and its relationships with its clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein only applies to specific clients or affiliates. For purposes of this Brochure, references to “including” (and similar terms) mean “including, without limitation.” 2. Investment Strategies and Types of Investments. VGI leverages its core competencies, which include analyzing industry dynamics and business models, evaluating the strength of management teams, and assigning company valuations, to select investments in equity securities and in credit and other financial instruments. VGI typically causes the Funds to invest in companies located around the world that operate in a wide range of industries. The VGE Funds seek to achieve maximum capital appreciation commensurate with reasonable risk. VGI seeks to increase the performance of the VGE Funds while mitigating general market risk by employing a hedged approach, taking short positions as well as long positions. VGI uses leverage to magnify the effects of its investment selections. VGI expects the leverage of the VGE Funds’ equity portfolio, as measured by its “gross exposure” 2, generally to remain below 250%. VGI expects that the VGE Funds’ equity portfolio will generally maintain “net exposure” 3 below 60%, and, consequently, believes that the performance of the VGE Funds over sustained periods of time will be more a function of investment selection than of movements in broad market averages. Long and short credit positions may cause the aggregate gross exposure or net exposure of the VGE Funds’ portfolio to exceed these levels. The VLF Funds’ investment program generally replicates the long equity positions held in the VGE Funds’ portfolios.

In addition, a wholly owned subsidiary of each of Viking Performance and VLF GP acts as an administrative general partner of certain Cayman exempted partnership entities with the authority to submit filings in the Cayman Islands.

A Fund’s “gross exposure” is the value of its long positions plus the value of its short positions, if any, divided by the Fund’s net assets (excluding such Fund’s cash and treasuries). For example, if a Fund has net assets of $100 and has long positions valued at $120 and short positions valued at $80, such Fund would have a gross exposure of 200% ([$120+$80] / $100).

A Fund’s “net exposure” is the value of its long positions less the value of its short positions, if any, divided by the Fund’s net assets (excluding such Fund’s cash and treasuries). Using the example provided above for the definition of gross exposure, such Fund would have a net exposure of 40% ([$120-$80] / $100).

The Hybrid Funds’ objective is to maximize risk-adjusted returns primarily by making attractive illiquid and liquid investments in companies that operate in a wide range of industries globally. The Hybrid Funds’ illiquid portfolio may include a wide variety of illiquid investments but historically has been concentrated in private equity investments. The Drawdown Funds’ objective is to maximize risk-adjusted returns by making attractive illiquid investments in companies that operate in a wide range of industries globally. During their investment period, the Drawdown Funds generally pursued the same illiquid investment opportunities as the Hybrid Funds. The Vintage IV Funds generally pursue the same illiquid investment opportunities as the Hybrid Funds. The Structured Capital Funds’ objective is to generate attractive risk-adjusted returns by investing in instruments that VGI believes offer significant upside potential with meaningful downside protection. The Structured Capital Funds focus on primary structured financings in hybrid, credit, and credit-like investments, though they may also make secondary investments in hybrid and credit instruments, including in periods of market dislocation, and may pursue other adjacent opportunities. When an investment is appropriate for multiple Funds, allocations are made as described in Item 6 and Item 11. A more detailed description of the investment strategies pursued and types of investments made by VGI is provided in Item 8. The descriptions set forth in this Brochure of specific advisory services that VGI offers to clients, and investment strategies pursued and investments made by VGI on behalf of its clients, should not be understood to limit in any way VGI’s investment activities. VGI may offer any advisory services, engage in any investment strategy, and make any investment, including any not described in this Brochure, that VGI considers appropriate, subject to each client’s investment objectives and guidelines. C. Availability of Customized Services for Individual Clients. VGI has defined certain investment objectives for the Funds, as set forth in their respective offering memoranda and operative documents, and tailors its advisory services to meet those objectives. VGI is not restricted in the types of financial instruments in which it may invest on behalf of the Funds. However, VGI monitors and manages certain internal portfolio guidelines (for example, leverage and exposure requirements for internal risk-management purposes). These internal guidelines, which may change from time to time without notice to the Funds, confer no rights on the Funds or investors and impose no additional legal obligations upon VGI. D. Assets Under Management. As of December 31, 2025, VGI managed approximately $57,210,401,529 of client net assets on a discretionary basis and did not manage any client assets on a non-discretionary basis.

Viking also receives an asset-based allocation of profits from illiquid investments acquired or designated as such prior to January 1, 2024 in the Hybrid Funds (the “Priority Profits Allocation”). Effective as of January 1, 2024, Viking discontinued the Priority Profits Allocation for illiquid investments acquired or designated as such on or after January 1, 2024; Viking instead receives Management Fees in respect of such illiquid investments, as described below. Except as otherwise described in this Item 5, each of the Funds is subject to a Management Fee and Incentive Allocation. Only the Hybrid Funds are subject to the Priority Profits Allocation. Investors in the Funds who are Viking Affiliates do not bear a Management Fee, a Priority Profits Allocation, or an Incentive Allocation during the term of their employment or affiliation with Viking and, in some cases, for a period thereafter. Certain CoInvestment Vehicles do not pay Management Fees or Incentive Allocation. The Management Fee, Priority Profits Allocation, and Incentive Allocation, as applicable, are not negotiable. However, Viking may, in its discretion, (a) waive or reduce all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation with respect to any investor in any Fund, (b) cause all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation, as applicable, to be paid from, or on behalf of, the applicable Fund or any other entity through which such Fund invests directly or indirectly, including from a pass-through entity below an investment vehicle treated as a corporation for United States (“U.S.”) federal income tax purposes, and (c) cause all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation, as applicable, to be paid to any affiliate of Viking. Generally, Viking earns: VGE Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account or each series of shares (as applicable) of each VGE Fund.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to a percentage (20% for investors with a one-year lock-up; 17.5% for investors with a three-year lock-up) of the net capital appreciation allocated to each investor in a VGE Fund during such period. The Incentive Allocation is taken only on net capital appreciation in excess of the prior losses of such investor (a “high water mark”); however, Viking (or, for the non-U.S. domiciled VGE Fund, its Board of Directors), may reset the high water mark for certain classes of investors, which triggers an early right of redemption for any affected investors. In addition, the Incentive Allocation with respect to investors who initially agreed to be subject to a three-year lock-up period (and thus had been subject to an Incentive Allocation rate of 17.5%) will

be recalculated on the entire interest at a 20% rate retroactive to the beginning of the lock-up period and then crystallized and reallocated to Viking. VLF Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account or each series of shares (as applicable) of each VLF Fund.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to a percentage (20% for investors with a one-year lock-up; 17.5% for investors with a three-year lock-up) of the excess of the net return for each investment made by an investor in a VLF Fund over the performance of the MSCI World Index (as defined below). 4 The Incentive Allocation is taken only on net return in excess of any prior underperformance of each investment made by such investor relative to the MSCI World Index; however, Viking (or, for the non-U.S. domiciled VLF Fund, its Board of Directors), may reset the underperformance recovery amount for certain classes of investors, which triggers an early right of redemption for any affected investors. In addition, the Incentive Allocation with respect to investors who initially agreed to be subject to a three-year lock-up period (and thus had been subject to an Incentive Allocation rate of 17.5%) will be recalculated on the entire interest at a 20% rate retroactive to the beginning of the lock-up period and then crystallized and reallocated to Viking. The above references to the “MSCI World Index” refer to the Morgan Stanley Capital International World Index (dividends reinvested net of withholding taxes) measured in local currency terms (Bloomberg symbol: NDDLWI). 5

Hybrid Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account of each Hybrid Fund attributable to liquid investments.

upon the realization of an illiquid investment acquired or designated as such prior to January 1, 2024 (a “Pre-Election Investment”), a Priority Profits Allocation of gains from the realized Pre-Election Investment up to, but not exceeding the accrued priority profits balance for such Pre-Election Investment. The priority profits balance for each Pre-Election Investment increases at the beginning of each month by 0.125% (1/12th of 1.5%) of the value of the Pre-Election Investment’s capital account (based on the lower of the cost and fair value of the Pre-Election Investment), plus imputed interest on any previously accrued and unpaid priority profits balance. The priority profits balance ceases accruing upon the sooner of (a) the complete realization of the Pre-Election Investment or (b) the seventh anniversary of the creation of the illiquid capital account

If Viking does not receive an Incentive Allocation from the VLF Funds because insufficient net capital appreciation was allocated to an investor during an applicable period, then Viking will receive such Incentive Allocation at the end of the next fiscal year (and any subsequent fiscal years, as necessary) to the extent there is net capital appreciation in such year(s) (or as of the next date the applicable investor makes a redemption, to the extent there is any net capital appreciation at such time).

As of March 16, 2026, the MSCI World Index aggregated indices from the following 23 developed market countries: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, the United Kingdom, and the United States. (Source: https://www.msci.com/world)

relating to that Pre-Election Investment. Effective as of January 1, 2024, Viking discontinued the Priority Profits Allocation for illiquid investments acquired or designated as such on or after January 1, 2024 (“Post-Election Investments”) and instead charge a monthly Management Fee equal to 0.125% (1/12th of 1.5%) on the lower of cost or fair value of a Post-Election Investment. Upon a partial realization of an illiquid investment by way of a sale or other disposition, its cost generally will be reduced proportionately relative to the portion of the illiquid investment so realized, whereas distributions made (or deemed to be made) in the ordinary course from portfolio companies (e.g., interest payments, dividends, tax distributions) generally will not reduce the cost of an investment for purposes of calculating the Priority Profits Allocation or Management Fee, as applicable.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to 20% of the net returns of the investor’s liquid pool, taking into account any net depreciation or net appreciation (in each case, based on the lower of cost or fair value) of any unrealized illiquid investments. The Incentive Allocation is taken only on net capital appreciation in excess of the prior losses of such investor. In addition, an Incentive Allocation is made following the realization of each illiquid investment of 20% of the net profits from such illiquid investment (without duplication for any net depreciation or net appreciation previously taken into account in calculating the Incentive Allocation on the investor’s liquid pool). 6 The Incentive Allocation from gains on illiquid investments is subject to “true-up,” which may cause Incentive Allocation amounts preliminarily allocated to Viking to be returned to the investor to the extent there are subsequent losses through the end of the applicable calendar year.

Drawdown Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the capital contributions (as of the end of each month) for investments (including, for this purpose, the principal amount of any borrowings by the Drawdown Funds for investments, but without duplication of capital contributions used to repay such borrowing), plus any expenses related to such investments (as determined by Drawdown GP in good faith), less any such contributions (or borrowings) attributable to investments subject to a complete write-off, as adjusted for partial realizations on a pro rata basis.

upon the distribution of proceeds, 20% of the net proceeds from the Drawdown Funds as an Incentive Allocation once investors have received from such distribution proceeds and all prior distributions a return of their capital contributions to the Drawdown Funds.

Vintage IV Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of (a) with respect to Series 1 Interests, the capital contributions (as of the end of each month) for investments (including, for this purpose, the principal amount of any borrowings by the Vintage IV Funds for investments, but without duplication of capital contributions used to repay such borrowing), plus any expenses related to such investments (as determined by Vintage IV GP in good faith), less any such

In certain circumstances, the balance of an investor’s liquid capital may not be sufficient to satisfy the Incentive Allocation to which Viking is entitled. Any portion of an Incentive Allocation that is not reallocated to Viking may be reallocated as of the next month-end (and any subsequent month-end) to the extent of the investor’s liquid capital account balance or any proceeds from realized illiquid investments.

contributions (or borrowings) attributable to investments subject to a complete writeoff, as adjusted for partial realizations on a pro rata basis (“invested capital”) and (b) with respect to Series 2 Interests, (i) until and including the earlier of (1) expiration or early termination of the investment period and (2) the day preceding the commencement of the investment period of a subsequent fund, an investor’s capital commitment and (ii) following the investment period, invested capital.

upon the distribution of proceeds, 20% of the net proceeds from the Vintage IV Funds as an Incentive Allocation once (a) with respect to Series 1 and Series 2 interests, investors have received from such distribution proceeds (and all prior distributions) a return of their aggregate capital contributions to the Vintage IV Funds and (b) with respect to Series 2 interests, investors have also received an 8% preferred return, compounded annually, on such capital contributions and the Vintage IV GP has received a 100% GP catch-up.

Structured Capital Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the capital contributions (as of the end of each month) for investments, including any expenses related to such investments (as determined by Structured Capital GP in good faith), plus the aggregate outstanding borrowings incurred by the Structured Capital Funds or any special purpose vehicle for investments, less any such capital contributions (or borrowings) attributable to investments subject to a complete write-off, as adjusted for partial realizations on a pro rata basis; provided that any aggregate outstanding borrowings shall not, when added to the capital contributions in respect of such investments, cause the sum to exceed the cost of such investments.

upon the distribution of proceeds, 20% of the net proceeds from the Structured Capital Funds as an Incentive Allocation once (a) investors have received from such distribution proceeds (and all prior distributions) a return of their aggregate capital contributions to the Structured Capital Funds and a 7% preferred return, compounded annually, on such capital contributions and (b) Structured Capital GP has received a 100% GP catch-up.

B. Payment of Fees. Management Fees, the Priority Profits Allocation, and the Incentive Allocation are generally deducted or allocated from Fund assets. For all Funds, the Management Fee is generally calculated on a monthly basis and payable on either a monthly or quarterly basis. For the Hybrid Funds, the Priority Profits Allocation from Pre-Election Investments is generally allocated following realization of the relevant illiquid investments. For the VGE Funds, the VLF Funds, and the Hybrid Funds, the Incentive Allocation is generally allocated annually or upon an investor’s redemption. For the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds, the Incentive Allocation is generally apportioned following realization of each investment. C. Additional Fees and Expenses. Investors in the VGE Funds and the VLF Funds may, by giving the required amount of notice, redeem from a Fund on any calendar month-end during their lock-up period. Investors who redeem prior to the expiration of their redemption lock-up period are generally subject to an exit fee on net redemption proceeds. Exit fees are retained by the applicable Funds for the benefit of non-redeeming investors. Viking Affiliates are not subject to a lock-up period and therefore are not subject to exit fees.

From time to time, Viking may, directly or indirectly, receive commitment fees, breakup fees, monitoring fees, directors’ fees, fees or commissions in connection with securities offerings or loan syndications, and transaction, financing, advisory, consulting, divestment, and other similar fees received as compensation for advisory and similar services or relating to the making, disposition, or management of investments from companies in which the Funds invest (collectively, “Portfolio Fees”). In such instances, Viking intends to reduce the amount of Management Fees that would otherwise be borne by the investors subject to Management Fees in the applicable Fund by the amount of such Fund’s allocable portion of any Portfolio Fees received, with such reduction generally allocated among the investors subject to Management Fees in proportion to their interests in the investment giving rise to the Portfolio Fees, in each case as determined by Viking. These arrangements create conflicts of interest. Viking may derive economic or timing benefits from these arrangements and therefore has an incentive to cause the Funds to make investments that generate Portfolio Fees, even if such investments are less attractive than other available investment opportunities. In addition, investors who are not subject to Management Fees, or who redeem from the applicable Funds before sufficient Management Fees can accrue, may not receive the benefit of all or any portion of any such Management Fee reduction. Furthermore, the payment of Portfolio Fees may adversely affect the performance of the Funds’ investments. The foregoing describes Viking’s general approach with respect to Portfolio Fees, but certain Funds, such as the Structured Capital Funds and certain Co-Investment Vehicles, have more specific mechanics and differences, as described in the offering memoranda and/or operative documents of those Funds. Each Fund will bear certain of its own expenses as described in its offering memorandum and/or operative documents. These expenses include fees paid to third-party service providers, such as prime brokers, executing brokers, custodians, administrators, research providers, lawyers, accountants, consultants, and persons providing valuation services. Viking may also engage third-party service providers to provide services to a Fund that were previously provided by Viking and/or its personnel, in which case such Fund will bear the costs and expenses associated with such third-party service providers. From time to time, the Funds may invest a portion of their assets in other third-party managed vehicles and structures, generally to obtain exposure to a particular investment that is otherwise difficult to access. As a result, the Funds would be subject to additional fees (such as management fees and performance fees, if any) and expenses. Viking does not receive any portion of such fees and expenses. Additionally, the Funds have undertaken to indemnify their directors, general partners, investment managers, and certain third-party service providers (and certain related persons of each of the foregoing) for losses and expenses sustained by such persons, provided that such losses did not arise from such persons’ violation of applicable standards of conduct (for example, did not arise from such persons’ gross negligence or fraud). For the avoidance of doubt, such persons are not exculpated or indemnified for any liability (including liability under the federal securities laws which, under certain circumstances, impose liability even on persons that act in good faith) to the extent that such exculpation or indemnification would violate applicable law. Additional detail on each Fund’s indemnification obligations is included in its offering memorandum and/or operative documents. Item 12 further describes the factors that Viking considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation.

D. Prepayment of Fees. Generally, the VGE Funds, the VLF Funds, and the Hybrid Funds pay Management Fees to Viking on the first day of each month for such month. Generally, the Vintage Funds and the Structured Capital Funds pay the Management Fee at the beginning of each quarter, in arrears. The VGE Funds, the VLF Funds, and the Hybrid Funds only permit voluntary redemptions on applicable month-ends. The Vintage Funds and the Structured Capital Funds generally do not permit redemptions. If a Fund were ever to compel an investor to redeem on a date that is not a month-end, a pro rata portion of the Management Fee that was paid in advance by the Fund and borne by such investor would be refunded. E. Additional Compensation and Conflicts of Interest. Except as otherwise described in this Item 5 with respect to Portfolio Fees, Viking and its supervised persons do not accept compensation (for example, brokerage commissions) for the sale of securities or other investment products.

Considering the differences in the portfolios, Management Fees, and Incentive Allocation mechanisms of the Funds, Viking is incentivized to allocate investment opportunities among the Funds in a manner that maximizes the amount and/or expedites the receipt of compensation for Viking. Furthermore, if Viking Affiliates comprise a greater percentage (or all) of certain Funds, then Viking has an incentive to preferentially allocate investment opportunities to such Funds. Viking and Viking Affiliates could also enter into arrangements to provide financing to certain Funds, similarly giving Viking an incentive to preferentially allocate opportunities to, or manage investments so as to favor its interests in, such Funds. Potential conflicts of interest with respect to the allocation of investment opportunities are addressed by Viking’s allocation policy (as described below in this Item 6 and in Item 11). While each Fund’s investment program provides Viking with broad discretion in determining the types of investments in which such Fund may invest, Viking anticipates that each Fund’s portfolio (other than potentially the portfolios of the Structured Capital Funds) will be predominantly concentrated in investments that comprise such Fund’s “Core” investment mandate. Each Fund may also make investments, including substantial investments, that are “Non-Core” to such Fund (i.e., outside of such Fund’s Core investment mandate). While the portfolios of the Structured Capital Funds are expected to be concentrated in “Core” investments, the Structured Capital Funds may invest a majority or all of their capital in NonCore investments. This means that other Funds may have priority over the majority of the investments that the Structured Capital Funds wish to make, and there are no assurances that other Funds will not exercise their priority with respect to Non-Core investments the Structured Capital Funds would otherwise wish to pursue. Additionally, any Fund may decline to pursue investments within its Core investment mandate, in which case such investments may be made available to other Funds. Viking may launch funds or vehicles in the future that receive equal or higher allocation priority of Non-Core investments of a Fund, or may, for any reason or no reason, cause a Fund to discontinue making investments that are within such Fund’s Non-Core investment mandate for a finite or indefinite period of time. Certain Funds currently have, and any existing or new Fund may be given, priority investment allocations with respect to any category of investment within a Fund’s Non-Core investment mandate (and vice versa), even if similar investments were previously made by such Fund. Furthermore, Viking may allocate investment opportunities that are within a Fund’s Non-Core investment mandate to co-investors with priority over the Funds (and vice versa). Viking may also use the Funds to incubate a Non-Core investment strategy and thereby test the viability of such strategy. For example, in 2021, prior to the launch of the Structured Capital Funds, Viking began to expand Viking’s credit investing capabilities, with credit investments

generally allocated to the VGE Funds as Non-Core investments. Then, in 2023, Viking launched the Structured Capital Funds, which generally have priority over the VGE Funds with respect to certain credit investments. In the future, Viking may again use existing Funds to develop new investment strategies or expand existing investment strategies and later seek to form new Funds based on the success of the investment strategies deployed in the existing Funds. In the event any such strategies are unsuccessful in the existing Funds, the relevant Funds may bear negative returns. In the event any such strategies are identified as successful in the existing Funds, such strategies may become Core to new Funds, in which case the new Funds would generally have priority over the relevant Funds with respect to investments in such strategies. Viking may also establish additional Funds that have, or grant to an existing Fund, equal allocation priority as the Funds, including for investments that are within the Core investment mandate of any of the Funds. Such Funds may invest in all or a subset of the investments within an existing Fund’s Core investment mandate. For example, Viking may establish sector-, industry-, or geography-focused funds to make investments in such specific sectors, industries, or geographies. Viking’s allocation policy currently provides that fundamental research-driven investments in illiquid equity securities issued by operating companies (and related follow-on investments and hedges) are generally allocated with priority to the Opportunities Funds relative to other existing Funds. Similarly, the Structured Capital Funds generally receive priority allocation of credit investments, including liquid and illiquid credit instruments, as well as “hybrid” investments that are predominantly credit-like in nature and hedging positions related to any of the Structured Capital Funds’ investments. Such priority allocation methodologies are subject to (a) Viking’s discretion to make appropriate exceptions, for instance, when another Fund has a legal right of first refusal to a follow-on investment pursuant to the terms of its original investment and (b) Viking’s ability to grant other Funds equal priority with respect to investments within a Fund’s Core investment mandate. When it is determined that an investment opportunity is appropriate for one or more Funds that have the same allocation priority (including in the case in which no priority is given), then Viking will generally allocate the investment opportunity among such Funds in a fair and equitable manner over time, taking into account factors that it determines, in its sole discretion, to be appropriate. Such factors may include the relative amounts of capital available for new investments at the relevant Funds, the expected holding period and liquidity of the investment, the relative periods of time during which capital can be called or deployed for new investments by the relevant Funds, the expected duration of the relevant Funds, portfolio diversification, risk management, relative exposure to market sectors or investment themes of the relevant Funds, anticipated risk and return profiles of the investment, the current or anticipated availability of other suitable investment opportunities for the relevant Funds, any legal, tax, regulatory and other considerations, the decisions of the portfolio manager(s) assigned responsibility for making, managing, and disposing of the investment opportunity for the relevant Funds, and the investment programs and portfolios of the relevant Funds, as appropriate. These allocation decisions allow Viking to use a significant amount of discretion in determining appropriate allocations of investment opportunities among the Funds. Determinations made by Viking regarding a Fund’s capacity with respect to certain investments will require Viking to make allocation decisions using analysis that is, in part, inherently subjective. Although certain Funds may pursue investment objectives that are substantially similar to other Funds, the portfolios of such Funds may differ as a result of purchases and redemptions being made at different times and in different amounts, differences in investment programs and guidelines, and/or tax, regulatory, and liquidity considerations. Viking will have no obligation

to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any Fund solely because Viking purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any other Fund if it believes such security, transaction, or investment opportunity would not be suitable, practical, or desirable for the Fund. Please see Item 6 above and Item 11 below for additional disclosure regarding Viking’s allocation policy. Viking also has the ability to establish “Independent Advisory Committees” or “Limited Partner Advisory Committees” to consider and, on behalf of the Funds and their investors, approve or disapprove of certain matters involving potential or actual conflicts of interest. When Viking determines that an investment opportunity is within a Fund’s Core investment mandate and is otherwise appropriate for such Fund and one or more other Funds, Viking generally expects to allocate such investment opportunity among such Funds in a fair and equitable manner over time, taking into account factors that it determines, in its sole discretion, to be appropriate. Viking makes sizing and allocation decisions among Funds for investments in its sole discretion. Determinations as to whether any particular investment, including any follow-on investment, is Core or Non-Core to any Fund, as well as exceptions to such framework, are also made in Viking’s sole discretion in accordance with its allocation policies, which may give rise to certain conflicts of interest and, as applicable, are subject to approval by Viking’s Conflicts Committee. From time to time, Viking expects one Fund to make investments in the same company or issuer as one or more other Funds. While often Funds would make and exit any such investment on the same general terms, differences between such Funds, including their respective terms, investment periods, structures, regulatory and compliance obligations, jurisdictions, investor base, and investment strategies, could result in one Fund making or exiting its investment at a different time, at a different effective price, or with differing costs or terms than the other Funds. For example, a Fund may invest in the publicly traded securities of a company or issuer in which another Fund has previously invested, including by purchasing these securities in an initial public offering (“IPO”), in a secondary offering, or in the open market. Such investments may, and sometimes do, give rise to conflicts of interest and may influence Viking’s investment decisions, as different investment decisions could impact the different Funds unequally. For instance, in light of the different economic terms among the Funds, Viking may be incentivized to allocate investment opportunities to one Fund and not to other Funds to maximize the amount it or its affiliates receive in Management Fees or Incentive Allocation, or as a return on invested capital. A Fund may also make follow-on investments in another Fund’s portfolio companies by exercising pre-emptive rights, options, warrants, and other contractual rights obtained and negotiated for by such other Fund (or a different Fund) in connection with a previous investment in the applicable company or issuer, and vice versa. Such follow-on investments may create conflicts of interest, including where Funds have the opportunity to benefit from rights and options that were negotiated by another Fund, in some cases in exchange for consideration. Additionally, one Fund could have influence on a company or issuer, as applicable, through its ownership stake or the terms of its investments and influence the company or issuer, as applicable, or to make decisions that disadvantage another Fund. Viking might also be incentivized to cause one Fund to make an investment in a company or issuer that it would not have otherwise made unless another Fund was also invested in that company or issuer, for example, in a situation where such company or issuer requires liquidity or a cash infusion.

Determinations made by Viking regarding the factors described above will require Viking to make decisions using analysis that is, at least in part, inherently subjective. Additional Fund-specific disclosure regarding allocations and related conflicts are described in the Funds’ offering memoranda. B. Co-Investment Opportunities. There may be circumstances in which a portion of a particular investment opportunity that is within a Fund’s investment mandate is offered as a discretionary co-investment opportunity to one or more co-investors, including through Co-Investment Vehicles, other affiliates of Viking, their respective members, officers, and employees, and to third parties that may or may not be investors in the Funds (collectively, “co-investors”), for instance (a) when such opportunity is within a Fund’s Non-Core investment mandate, or (b) when such opportunity is within a Fund’s Core investment mandate and (i) exceeds the amount that Viking wishes to allocate to such Fund or (ii) certain business or strategic considerations cause Viking to consider discretionary co-investment alongside such Fund. Viking believes that having the ability to allocate co-investment opportunities on a discretionary basis in its sole discretion is likely to be beneficial to the Funds as a whole, though no investor should have any expectation that co-investment opportunities will be offered to it (including investors in dedicated CoInvestment Vehicles such as the Structured Capital Sidecars), and Viking has no duty to offer all or any portion of any investment opportunity to any investor or other person. Notwithstanding the foregoing, Viking retains sole discretion to determine what, if any, coinvestment opportunities to offer, on what terms and to what persons, including whether Viking will establish any Co-Investment Vehicle for one or more co-investors, and whether Viking will earn fees, including asset-based fees and/or performance-based profit sharing, in respect of such co-investment opportunities (which fees and profit sharing may differ from and would be in addition to any Management Fees or Incentive Allocation borne by the investors in any Fund). For example, in 2023, Viking established Viking Structured Capital Sidecar (Onshore) LP, a Delaware limited partnership, Viking Structured Capital Sidecar (Offshore) LP, a Cayman Islands exempted limited partnership, and Viking Structured Capital Sidecar (Offshore 2) LP, a Cayman Islands exempted limited partnership (collectively, the “Structured Capital Sidecars”), which are Co-Investment Vehicles that are generally expected to co-invest alongside the Structured Capital Funds in select investment opportunities with overflow capacity, as determined by Viking in its sole discretion. However, Viking has no duty to offer all or any portion of any investment opportunity to the Structured Capital Sidecars and is not required to and does not undertake to allocate investment opportunities among the Structured Capital Sidecars and other Funds, including the Structured Capital Funds, in a fair and equitable manner over time. Each co-investment opportunity (should any arise) is likely to be unique, and the allocation of any such opportunity will depend upon the facts and circumstances of that situation (e.g., timing, industry, size, geography, asset class, projected holding period, exit strategy, and counterparty). Given the Funds’ investment programs, it may not be possible for Viking to determine, when exploring an investment opportunity at a preliminary stage, whether it would be appropriate to allocate and/or offer the full amount of such opportunity to a Fund or whether to attempt to allocate a portion of it to co-investors. As a general matter, Viking, in determining the allocation of discretionary co-investment opportunities, expects to take into account various factors and circumstances it deems relevant. Such additional factors are likely to include: whether Viking has established an expectation with the co-investor (contractually or otherwise) to receive certain allocations of co-investment opportunities (including in

connection with the fundraising of a Fund); whether a co-investor adds strategic value, industry expertise or other synergies; whether a potential co-investor has sourced investment opportunities for the Funds; whether Viking believes that the co-investor has the ability to review the co-investment opportunity and provide capital within the timeframe required under the circumstances; the size of the potential co-investor’s interest to be held in the investment; and such other factors as Viking deems relevant under the circumstances. In addition, with respect to co-investment opportunities that are within a Fund’s Non-Core investment mandate, Viking may consider additional factors, including factors that benefit Viking and/or other Funds, when determining whether to allocate some or all of an investment opportunity to coinvestors (who may or may not be investors in the Funds) ahead of a Fund, which it may do in its sole discretion. Such factors are likely to include: whether a potential co-investor has expressed an interest in evaluating co-investment opportunities; whether a potential co-investor has a history of participating in co-investment opportunities with Viking; whether a potential co-investor is a current or prospective investor in one or more Funds; the size of a potential coinvestor’s current or potential aggregate investment in the Funds; whether a potential coinvestor has demonstrated a long-term and/or continuing commitment to the potential success of Viking, the Funds, and/or other co-investments; a potential co-investor’s potential impact on the reputation or strategic positioning of Viking and the Funds; the economic terms (such as management fees and carried interest) on which a potential co-investor will invest in the coinvestment opportunity; and other factors relevant to Viking or its affiliates. Because third-party co-investors may have the ability to evaluate and selectively participate in co-investment opportunities that are Non-Core to the Funds before such opportunities are made available to the Funds, there can be no assurance that the investments ultimately allocated to the Funds will not consist disproportionately of those opportunities that co-investors have elected not to pursue. The Funds may therefore bear a greater concentration of less favorable investment opportunities than would be the case absent allocation practices. Some of the co-investors with whom a Fund may co-invest may have pre-existing investments with Viking and/or other Funds, and the terms of such pre-existing investments may differ from the terms upon which such persons may co-invest with such Fund. Viking may (or may not), in its sole discretion, charge carried interest, incentive allocation, management fees, transaction fees, or other similar fees to co-investors. Differing compensation arrangements between Funds and co-investors may at times create an incentive for Viking to preferentially allocate investment opportunities. For example, any asset-based fees and/or performance-based profit sharing in respect of co-investments may differ from the Management Fee and carried interest borne by the investors and will not be shared with the investors nor offset the Management Fee. In certain cases, Viking may earn greater aggregate compensation (including the prospect of future compensation or benefits) by allocating a portion of an investment opportunity to a co-investor rather than to the Funds. Viking personnel are permitted to co-invest with the Funds from time to time, although they have not done so historically. Specifically, Viking received approval of an Independent Advisory Committee to allocate, in Viking’s sole discretion, up to 2.5% of each investment forming part of the Opportunities Funds’ illiquid investment program to certain Viking personnel, regardless of whether the Opportunities Funds have received their complete allocation. Although Viking expects that the ability to allocate investments to its personnel in this manner will further align its interests with the interests of its investors, the exercise of these investment rights may still give rise to conflicts of interest in connection with the allocation of any particular investment opportunity and in connection with the ongoing management and disposition of such investments. For example, Viking has an incentive to allocate to its personnel a larger percentage of investment opportunities that it believes have a higher

potential for positive performance (known as “cherry picking”). In the event Viking personnel co-invest with the Funds pursuant to this arrangement, Viking expects to implement policies and procedures designed to mitigate this and other potential conflicts of interest, but Viking expects that conflicts of interest will still arise from time to time. Preliminary investment allocations and co-investment arrangements are subject to change, and Viking is permitted to alter a preliminary allocation determination in its discretion. Allocation determinations typically take into consideration a number of factors, including the relative available capital of the participating Funds and co-investors, that change prior to an investment’s closing (for example, due to another investment being contemporaneously pursued by any Fund not ultimately being consummated, a change in the terms of the investment, or due to potential co-investors electing not to pursue the investment), and Viking is permitted to re-allocate the relevant investment among the Funds and co-investors to account for such changes. Viking likely will not be able to determine the amount of co-investor capital available for an opportunity at the same time it determines the amount of the Funds’ capital available for such opportunity; therefore, it is likely that Viking may pursue and commit to potential investment opportunities based on presumed allocations among the Funds. Such presumed allocations may differ materially from the final investment allocations made after Viking has determined the participation level of co-investors, and a Fund could ultimately receive a smaller allocation than initially contemplated – or no allocation at all, in the case of Non-Core investment opportunities. Regardless of whether an investment offered, or expected to be offered, to co-investors is consummated by such co-investors, such co-investors may not agree to pay or otherwise bear fees, costs, or expenses related to such co-investment opportunity, and such fees, costs, and expenses that are not borne by co-investors may be borne in whole or in part by a Fund. Certain Funds may have the right or ability to syndicate a potential co-investment after closing. In the event a Fund fails to syndicate a potential coinvestment, Viking is permitted to re-allocate the portion of the investment that was not syndicated. Further, in the case of any co-investment opportunity that is warehoused by the Funds, if co-investors purchase their interest in such a warehoused co-investment opportunity from the Funds after the Funds have consummated the relevant investment, such interest will typically be purchased either at cost plus a proportionate share of expenses or at fair market value. The price paid by such co-investors for their interest in such a co-investment opportunity may not reflect the full cost incurred by the Funds in connection with the relevant investment, including any carrying costs on such a co-investment opportunity, the cost of establishing a credit facility utilized to acquire the relevant investment (if applicable), or the risk borne by the Funds in connection with purchasing and warehousing the investment. C. Investment Expenses; Broken-Deal Expenses. The Funds’ investments have required and will in the future likely require extensive due diligence and legal analysis and will likely require that the Funds incur legal and other costs prior to their consummation. For example, when assessing whether to make an investment in a market in which the Funds have not previously transacted, Viking will typically engage with local counsel, tax experts, other advisors, and the Funds’ trading counterparties to better understand the rules, regulations, and practices applicable to that market, and illiquid investments will generally require the negotiation of definitive documentation prior to consummation. The financial position of the Funds may give Viking an incentive to allocate such fees and expenses to one Fund and not another. For example, it would be advantageous to Viking to allocate broken-deal fees and expenses to a Fund that is not expected to make carried interest

distributions or Incentive Allocation to Viking, as the fees and expenses would not affect the amount of carried interest distributions or Incentive Allocation made by such Fund. Conversely, it typically would be disadvantageous to Viking as an economic matter to allocate broken-deal fees and expenses to a Fund that makes carried interest distributions or Incentive Allocation, as doing so would delay and reduce the amount of carried interest distributions or Incentive Allocation made to Viking. As with other allocation decisions, Viking’s allocation procedures and principles are designed to help mitigate the risk that financial incentives influence the allocation of broken-deal fees and expenses.

Short positions constitute an integral component of the VGE Funds’ investment program. These positions are generally intended to contribute positively to the performance of the VGE Funds. In addition, they may lessen the impact on the VGE Funds of a major stock market decline. Over the long term, Viking aims to achieve returns for the VLF Funds that exceed those of the broad market indices, including the MSCI World Index. The VLF Funds’ investment ideas are drawn predominantly from the universe of long equity positions in which the VGE Funds invest, although Viking may determine that certain investments not contained in the VGE Funds’ portfolio are appropriate for the VLF Funds and vice versa. Viking believes that its investment staff is capable of identifying long opportunities that, on a consistent basis, exceed the capacity of the VGE Funds to make long investments in light of the VGE Funds’ mandate to hedge long exposure with profitable short positions. Viking established the VLF Funds to take advantage of such opportunities. The VLF Funds generally replicate the long equity positions in the portfolio of the VGE Funds, with certain exceptions. Historically, the VLF Funds have replicated the majority of the VGE Funds’ long positions, with the VLF Funds’ exposure to each position typically matching its proportional capital weighting within the VGE Funds. However, Viking may adjust this methodology in its sole discretion, including by investing on behalf of the VLF Funds in some or all of the VGE Funds’ long positions based on factors other than capital weighting—such as the VGE Funds’ net exposure to specific sectors—or in such other proportions and amounts as it determines. The VLF Funds typically do not use leverage, although they are permitted to do so. Viking seeks to maximize the Hybrid Funds’ risk-adjusted returns primarily by making attractive liquid and illiquid investments globally. The Hybrid Funds’ illiquid portfolio may include a wide variety of illiquid investments, but has historically been concentrated in private equity investments. Investor capital contributions are initially fully invested in a liquid capital account, which is generally invested in liquid, public securities and used to fund illiquid opportunities as they are identified. When these illiquid investments are realized, the proceeds generally are reinvested in the investor’s liquid capital account and made available for subsequent illiquid opportunities. The proportion of an investor’s capital that is invested in illiquid investments will vary over time and relative to that of other investors in the Hybrid Funds. At any given time, nearly all of an investor’s capital may be allocated to illiquid investments and not liquid investments, or vice versa. The Hybrid Funds’ liquid portfolio generally replicates the “most liquid” long and short positions in the VGE Funds and uses leverage in that portfolio to magnify the effects of its investment selections. The Hybrid Funds’ illiquid investments may include securities in privately held companies, privately issued or restricted securities of public companies (including PIPEs), and other investments. Viking seeks to maximize the Vintage Funds’ risk-adjusted returns by making what it deems are attractive illiquid investments in companies that operate in a wide range of industries

globally. During their respective investment periods, the Vintage Funds will generally pursue the same illiquid investment opportunities as the Hybrid Funds. The Hybrid Funds’ illiquid investment decisions generally drive capital deployment by the Vintage Funds, thereby providing a structural link between Viking’s public and private investment efforts. This should ensure that any potential illiquid investment opportunity of the Opportunities Funds is implicitly assessed against Viking’s public market opportunity set. Viking seeks to generate attractive risk-adjusted returns for the Structured Capital Funds by investing in instruments that Viking believes offer significant upside potential with meaningful downside protection. Viking expects the Structured Capital Funds to focus on primary, structured financings in hybrid, credit, and credit-like investments, although the Structured Capital Funds may also make secondary investments in hybrid and credit instruments, including in periods of market dislocation, and may pursue other adjacent opportunities. Structured capital investments target capital appreciation, contractual returns, or any combination thereof. The Structured Capital Funds pursue structured capital investments in private and public companies that operate across industries globally. In employing its fundamental approach to investment selection for the Funds, Viking generally performs a number of tasks that may include the following: detailed review of a company’s products and services; market analyses to estimate the size of the future market for such products and services; analyses of a company’s financial information; evaluations of the effectiveness of a company’s management team; discussions with a company’s potential customers and competitors; consultations with industry experts; reviews of alternative data; quantitative analyses and reviews of other quantitative inputs, including through artificial intelligence; and reviews of the macroeconomic, regulatory, and technological dynamics affecting a company’s prospects. Viking also seeks to incorporate environmental, social, and governance (“ESG”) considerations into its investment process to the extent it believes they are material to a company’s business model, management practices, or intrinsic value. Viking believes that ESG issues have the potential to impact the operations and valuation of a company, and it seeks to incorporate material ESG considerations into its analysis to manage risks, identify opportunities, and facilitate well-informed decision-making. Viking places a particular emphasis on governance by evaluating the quality of management and a company’s ability to formulate and execute strategy, allocate capital, align management’s interests with those of its shareholders, and create and maintain independent boards with appropriate oversight. Viking may also hold discussions with and provide feedback to companies on a broad range of topics, including their material ESG issues and sustainability practices and disclosures. Viking’s ESG integration efforts are evolving; Viking does not necessarily identify all material ESG factors, nor does Viking identify ESG factors for all investments. Viking approaches each investment individually, and the types of inputs assessed, as well as the importance assigned to each, are specific to each investment. While Viking views ESG integration as an important element of its fundamental research, ESG factors are not necessarily determinative factors in its investment decisions, it does not invest with the goal of obtaining specific ESG impacts or outcomes, nor does it apply any ESG-related exclusions to its investible universe. Viking employs a Head of Investigative and ESG Research to assist the investment team on deeper dives into the material ESG issues that are identified for further analysis. Viking encourages, trains, and provides its investment team members with various resources to identify and incorporate ESG issues that they believe are material into their research; however, each of them determines whether and how to do so in any particular case. Viking aspires to continue to evolve its integration of material ESG issues over time. In evaluating investments, Viking may place greater emphasis on certain criteria depending on the nature of the relevant company and the associated investment terms. For

instance, Viking will typically focus on different factors when evaluating a potential investment in an early-stage company as compared to a late-stage investment in an established business. In addition, to evaluate liquid investments, Viking typically develops multi-year financial models forecasting a company’s earnings, cash flow, and prospective growth rates, which are then used to forecast a target price for that company’s securities. The duration of the holding period for liquid investments is generally determined by how quickly the security’s price approaches Viking’s target price and any new or changed data points that call the original thesis into question. Other factors may include Viking’s view of the effectiveness of the company’s management, the company’s potential growth trajectory, and market liquidity. Viking reevaluates the Funds’ liquid investment positions frequently as circumstances change and resizes positions due to factors such as changes in fundamental performance or outlook, stock price, market news, or macroeconomic conditions. Moreover, each position is consistently evaluated not only on its own merits, but relative to other opportunities; accordingly, positions may be resized or closed out based on changes in Viking’s broader investment universe. An investment in a Fund is speculative and involves a significant degree of risk. The Funds are designed for sophisticated investors that are able to bear a substantial loss of capital and for which an investment in the Fund is not a complete investment program. B. Material, Significant, or Unusual Risks Relating to Investment Strategies. The following is a non-exhaustive summary of certain material, significant, or unusual risks associated with the Funds’ significant investment strategies and Viking’s methods of analysis. Investment and Trading Risks. The Funds’ investment programs carry significant inherent risks. Investors may lose all or part of their investments in the Funds. Viking believes that the Funds’ investment programs and research techniques moderate this risk through a careful selection of securities and other financial instruments. No guarantee is made that the Funds’ investment programs will be successful. The Funds’ investment programs employ investment techniques that may include short sales, leverage and options on securities, swaps, futures, and forward contracts, the use of which can, in certain circumstances, increase the investment losses to which the Funds may be subject. The risks of these various techniques may be cumulative, potentially resulting in greater losses than might result from any single technique used in isolation. Moreover, the risk exists that despite its best efforts, Viking will make mistakes in investment selection. This risk is heightened in the case of “thematic” investments. From time to time, Viking may make a series of investments, long or short, in a particular geography, industry, or asset class, and there is a risk that the overall “theme” on which such investments are based may prove to be wrong. These investments generally will not be hedged. If, for example, Viking developed the investment thesis that a particular product was in “secular” decline (meaning sales would decline over a long period, regardless of general economic activity), Viking might take significant short positions in the stocks of several companies that sell such products, or certain components of such products. If that thesis proved wrong, the applicable Funds could suffer significant losses in connection with those investments. Viking is not limited in the types of investment strategies it may pursue or the types of instruments in which it may cause the Funds to invest. Moreover, the Funds’ investments may be concentrated at various points in time in a particular segment of an industry or geography. Any new investment strategies, risk management techniques, and investment tactics used by Viking for the Funds may not be thoroughly tested before being employed and may involve

material, and as-yet-unanticipated, risks and increase the likelihood of operational error, which could result in losses to the Funds. Limited Diversification. There is no assurance as to the degree of portfolio diversification that will be sought or achieved by the Funds. The Funds will at times hold relatively large concentrations in a particular issuer, market, industry, sector, geographic region, currency, or type of financial instrument. These portfolio concentrations may be made intentionally, for instance, if Viking develops investment theses or identifies investment opportunities in issuers with shared characteristics, or may be unintentional, such as when one or more existing positions appreciate significantly more than the rest of a Fund’s investments. The Funds’ portfolios are expected to have high concentrations in sectors, geographies, and issuers in which Viking’s most senior investment personnel have prior experience covering or have designated as areas of focus. Further, the Funds do not invest in certain sectors or geographies, for instance when there is limited or no investment analyst coverage (with respect to the liquid portfolio) or where the Head of Private Investments or deal captains have little or no investment experience (with respect to the illiquid portfolio). Limited diversification could expose investors to losses that are disproportionate to market movements in general. Furthermore, even if a Fund achieves significant diversification, individual investors may not participate in all the Fund’s investments and may participate in different investments in different proportions. Thus, an individual investor’s interest in a Fund may be significantly less diversified (and thus have greater exposure to certain specific investments) than the Fund’s overall investment portfolio. Competition; Availability of Investments. The markets in which the Funds invest are extremely competitive, and there can be no assurance that Viking will be able to identify or successfully pursue attractive investment opportunities. Competitive investment activity by other investment managers and financial institutions will reduce the Funds’ opportunity for profit by generally making higher bids for desired assets, reducing the frequency of attractive opportunities in the market as well as the returns available on those investments that can still be pursued. This may also increase the need or desire to utilize leverage, which has become increasingly expensive relative to prior periods. Market conditions also impact the availability of investment opportunities. For instance, different types of investment opportunities with different timelines for realization may be more available during periods of economic growth than in recessionary periods. Viking’s reputation, aggregate investment sizes, and trading volumes, each of which may impact Viking’s access to investment opportunities, depend on the size, strategies, and performance of the Funds. In addition, Viking’s ability to fund its internal operations and compensate (and thereby retain) its personnel is impacted by the amount of fees received by Viking, which is impacted by the performance of the Funds. To the extent a Fund experiences adverse results, another Fund’s capital base and performance may be adversely affected, as well. Liquid Portfolio Replication (Hybrid Funds only). The Hybrid Funds’ liquid portfolio generally replicates the “most liquid” investments in the VGE Funds, which are generally selected from a defined universe of public securities. In addition, the aggregate gross exposure and net exposure of the Hybrid Funds’ liquid portfolio are generally expected to correspond with those of the VGE Funds. Viking actively manages the VGE Funds’ gross exposure, incorporating investment-related and non-investment related factors as Viking deems appropriate. There are times when Viking will adjust the gross exposure of the VGE Funds, and thus indirectly also the gross exposure of the Hybrid Funds, due to factors which are not otherwise relevant to the Hybrid Funds. For instance, if the VGE Funds reduce their gross

exposure in anticipation of investor capital outflows, while not required to, Viking may, as it has in the past, similarly reduce the gross exposure of the Hybrid Funds’ liquid portfolio, even if the Hybrid Funds are not also experiencing capital outflows. As a result, the Hybrid Funds will incur different (and potentially greater) trading costs and experience different (and potentially lower) investment performance than if the Hybrid Funds’ liquid portfolio had not replicated this trading activity. In addition, the VGE Funds may make “pair trades,” in which the VGE Funds hold a linked long position and short position within the same industry. Viking has flexibility in how it replicates any such “pair trade.” For instance, if the pair trade involves one “most liquid” position and a paired position that is determined to be “non-most liquid,” the Hybrid Funds may replicate (a) both positions, (b) only the “most liquid” position, or (c) neither position. There are instances where the Hybrid Funds do not replicate a “most liquid” investment in VGE, for instance, when a law or regulation applicable to an investment impacts the Funds differently. Use of Leverage (VGE Funds, VLF Funds, and Hybrid Funds Only). The Funds sometimes leverage their liquid investment positions, including by borrowing funds from broker-dealers, banks, or other sources or by using the proceeds of short sale transactions to make additional investments. In addition, the Funds invest in derivatives and other financial instruments that are inherently leveraged. While leverage presents opportunities for increasing the Funds’ total return, it can have the effect of significantly increasing losses as well. The Hybrid Funds are also permitted to borrow funds in order to acquire illiquid investments, fund a hedging or similar transaction relating to an illiquid investment, or pay expenses and other liabilities related to an illiquid investment. For example, the Hybrid Funds have made investments in special purpose acquisition companies (“SPACs”) that were initially funded with leverage obtained by pledging liquid assets. While the VLF Funds do not generally engage in substantial borrowing or margin financing, they may do so when deemed appropriate by Viking, including for cash management purposes. Use of Leverage (Vintage Funds and Structured Capital Funds Only). Viking expects to utilize various forms of leverage in connection with the Funds’ investments and operations and is permitted to cause the Funds or any direct or indirect subsidiaries of the Funds to incur indebtedness of any kind and for any purpose. The use of borrowed funds creates the opportunity for greater total returns and allows the Funds to better manage respective cash flows, but at the same time involves risks and potential conflicts of interest. Certain of the significant risks and conflicts are described below. The Funds may leverage their investment positions, including by borrowing funds from broker-dealers, banks, or other sources or by using the proceeds of a realized investment to make additional investments. The Funds may also borrow funds in order to acquire an investment, fund a hedging or similar transaction relating to an investment, or pay expenses and other liabilities related to such investment. In addition, the Funds invest in derivatives and other financial instruments that are inherently leveraged. While leverage presents opportunities for increasing the Funds’ respective total returns, it can have the effect of significantly increasing losses as well. Accordingly, any event that adversely affects the values of the Funds’ investments would be magnified to the extent the Funds are leveraged. Fund-Level Borrowing (Vintage Funds and Structured Capital Funds Only). Viking expects to cause the Funds to borrow funds, directly or indirectly, for any purpose, including to pay fund liabilities (including Management Fees), make or facilitate new or follow-on investments, guarantee or provide other credit support for third-party obligations, make payments under a guarantee, credit support arrangement, or hedging transaction, fund the payment of any withholding or other tax on behalf of or with respect to any partner, cover any

shortfall in capital contributions resulting from default, excuse, or exclusion, and facilitate distributions. Borrowings incurred directly by the Vintage Funds and Structured Capital Funds are generally referred to herein as “Fund-level borrowing.” Fund-level borrowing may result in realization of unrelated business taxable income (“UBTI”) as defined in Section 512 of the Internal Revenue Code for certain investors. The Funds have separately entered into credit facilities pursuant to which they incur borrowings secured by pledges of the right to call capital from, and the right to receive amounts funded by, their respective investors (commonly referred to as “credit facilities,” “subscription lines,” or “subscription facilities”). The partnership agreements specifically permit the Funds to make such pledges, and any investor claim against a Fund would likely be subordinate to such Fund’s obligations to its credit facility creditor. Each Fund’s credit facility is used and managed independently from any other Fund’s credit facility, even if investments are shared between such Funds, which might result in different investment internal rates of return reported by multiple Funds for the same investment. Asset-Based Borrowing. Leverage arrangements, including any Fund-level borrowing and guarantees and borrowings that are secured in whole or in part by any or all of a vehicle’s (or any of its subsidiary’s) assets including one or more portfolio companies or distributions in respect thereof (“Asset-Based Borrowing”) could have implications under the Funds’ partnership agreements, and Viking will have the discretion to determine the treatment of such leverage at or below the Funds for various purposes, including the allocations of the costs and benefits of such leverage among the investors and the calculation of Management Fees and Incentive Allocation. This is expected to give rise to conflicts of interest. In addition, if a Fund (or a special purpose vehicle or other subsidiary of a Fund) enters into an Asset-Based Borrowing arrangement or similar financing that is cross-collateralized across multiple investments of such Fund, Viking will exercise discretion in determining the allocation and treatment of the costs and benefits of such leverage among the relevant investments (and the investors therein). Because not all investors will necessarily have the same pro rata indirect interest in each investment, Viking’s determination on how to allocate the costs and benefits of any cross-collateralized leverage could significantly impact the returns realized by an investor. Additionally, Viking will be entitled to make determinations that impact the calculation of Management Fees and Incentive Allocation. For example, allocating leverage proceeds or costs to a particular investment (or investments) can result in earlier or greater amounts of Management Fee than if a different allocation were determined. In addition, in the event of a default under any such loan or facility, where the lender forecloses on the pledged assets or exercises other rights with respect thereto, Viking expects to need to determine how to allocate the resulting losses or other impairments among the relevant investments, which will impact calculations of invested capital, which impacts Management Fees. Viking will make these allocations and determinations in its discretion and does not need to make such allocations on a pro rata basis among the cross-collateralized assets. Certain Risks and Costs of Borrowing (Vintage Funds and Structured Capital Funds Only). Borrowing subjects investors to risks and costs. For example, because amounts borrowed under a credit facility are secured by pledges of Viking’s right to call capital from investors and can also be secured by other assets of the Funds, a lender could foreclose on the pledged collateral, including the investors’ capital commitments if the Funds fail to repay the amounts borrowed under their respective credit facilities or experience an event of default. In addition, borrowing will result in incremental fund liabilities that will be borne by the investors and Viking. Additionally, the cost of borrowing could become more expensive and the availability of borrowing more limited than anticipated due to a variety of factors, including

those that are outside of Viking’s control. For example, concerns regarding the safety or soundness of U.S. or international financial systems, or of a particular financial institution, could result in less favorable commercial financing terms, including higher interest rates or costs and tighter financial and operating covenants, or systemic limitations on access to credit and liquidity sources, thereby making it more difficult to acquire financing on acceptable terms or at all. Any decline in available funding or access to cash and liquidity resources could adversely impact the Funds and their investments. Borrowing involves a number of additional risks. For example, drawing down on a credit facility allows Viking, on behalf of the Funds, to fund investments and pay fund liabilities without calling capital, potentially for extended periods of time. Calling a large amount of capital at once to repay the then-current amount outstanding under a credit facility could cause liquidity concerns for investors that would not arise had Viking 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 investors to meet the accumulated, larger capital calls at the same time. Viking has incentives to engage in Fund-level borrowing notwithstanding the expense and risks that accompany it. For example, Viking presents certain performance metrics in the Funds’ periodic reports and marketing materials. These performance metrics measure investors’ actual cash outlays to, and returns from, the Funds and thus depend on the amount and timing of investor capital contributions to the Funds and fund distributions to investors. To the extent the Funds use borrowed funds in advance or in lieu of calling capital, investors make correspondingly later or smaller capital contributions, which could result in higher performance metrics. Cross-Default Risk. The Funds can borrow (or cause their subsidiaries to borrow) on a joint, several, or joint and several, cross-collateralized, or cross-defaulted basis, or on any other basis that Viking determines, with other related vehicles, including any parallel funds, alternative investment vehicles (“AIVs”), and vehicles formed to facilitate co-investment, including by Viking employees and affiliated personnel. The Funds and these vehicles can engage in fund- or asset-level financing whereby (a) the Funds and/or such vehicles are jointly responsible on a cross-collateralized basis for the repayment of the financing and/or (b) the capital commitments of investors in the Funds and/or such vehicles are pledged to secure the financing obtained for the benefit of such other vehicles. For purposes of applying Fund-level borrowing limits, only a Fund’s proportionate share of any borrowing will be taken into account, even if a Fund has greater potential exposure as a result of the crossed borrowing structure, and as a result, a Fund could have exposure in amounts that exceed its borrowing limits. In addition, to the extent multiple assets or investments are pledged to support a single borrowing, multiple assets of a Fund will be at risk. As a result, negative performance of a single asset may materially and adversely impact the performance of other Fund investments or a Fund as a whole. Investors may have interests in certain investments that are disproportionate to their interests in other investments (for example, due to excuse or exclusion). As a result, an investor may be indirectly exposed to leverage risks associated with investments in which they do not participate, or in which they participate to a lesser extent, and the distributions they receive may be reduced, and their investment in a Fund may be materially and adversely impacted, by the negative performance of one or more investments in which they do not otherwise have an interest.

Cross-Collateralization Risk; Losses from Other Partners’ Investments (Hybrid Funds only). Investors in the Hybrid Funds will generally be subject to liabilities arising in connection with investments from which they did not stand to benefit. Viking expects this to arise, from time to time, for example, in connection with any illiquid investments or related transactions (including associated leverage or hedging positions) for which the Hybrid Funds grants one or more counterparties a security interest or other collateral in assets, including its liquid portfolio; this could be motivated by the counterparties’ unwillingness to accept illiquid or nontransferable assets as security, or an ability to obtain more favorable financing terms for the Hybrid Funds. In addition, new investors may indirectly bear tax liabilities associated with certain investments (or the Hybrid entities through which such investments are held) imposed as a result of an audit adjustment, even in cases in which the investors did not stand to benefit from the applicable investments. Other types of liabilities arising from investments could also cause losses to investors with no exposure to the positive performance of those investments. In certain recent cases, for example, bankruptcy trustees and other plaintiffs have sought to hold private funds liable for the obligations of their portfolio companies (such as pension fund shortfalls). In any such case, investors may bear liabilities or losses associated with investments from which they did not stand to benefit (including tax liabilities). The Hybrid Funds could also pledge interests in certain investments, including liquid investments, to facilitate redemptions or distributions in respect of other investments, including illiquid investments. In addition, the Hybrid Funds could use liquid investments or other illiquid investments to incur leverage more generally in respect of a liquid investment or an illiquid investment. Viking believes that, over time, the benefits of having the ability to cross-collateralize (including any such guarantees) will inure to the overall benefit of the investors and generally outweigh the costs associated with this imperfect alignment of risks and benefits. The losses associated with this cross-collateralization risk, however, could be significant. Counterparty Risk. The Funds’ assets are held in accounts maintained for the Funds by certain counterparties, including their prime brokers, custodians, and foreign exchanges, futures, and swap counterparties. In addition, the Funds post cash and securities to various trading counterparties as collateral for short sales, margin borrowing, and derivatives trades. Although Viking regularly monitors counterparty relationships, if one or more of the Funds’ counterparties were to become insolvent or the subject of liquidation proceedings, there exists the risk that the recovery of the Funds’ securities and other assets from such counterparty could be delayed or be of a value less than the value of the securities or assets entrusted to such party. In addition, the Funds transact and hold assets with counterparties located in various jurisdictions outside the U.S. For example, the Funds’ U.S.-based custodians and prime brokers generally engage sub-custodians and depositories to hold the Funds’ non-U.S. assets. Such counterparties are subject to various laws and regulations that are designed to protect their customers in the event of their insolvency. However, the practical effect of these laws and their application to the Funds’ assets are subject to substantial limitations and uncertainties. Investors in the Funds should assume that the insolvency of a counterparty could result in a loss to the Funds that could be significant. Some of the markets in which the Funds trade are “over-the-counter” or “inter-dealer” markets. The participants in such markets may not be subject to the same levels of regulatory oversight as members of “exchange-based” markets. This exposes the Funds to the risk that a counterparty will not post collateral due to a credit or liquidity problem, thus causing the Funds to suffer a loss. In addition, in the case of a default, the Funds could become subject to adverse market movements while replacement transactions are executed. Investments by the Funds in over-the-counter markets may increase the potential for losses by the Funds.

Additionally, certain counterparties may process, store, and transmit large amounts of electronic information, including information relating to the transactions and positions of the Funds. If a counterparty fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks (including a bank’s SWIFT interbank messaging system), information relating to the transactions or positions held by the Funds may be lost or improperly accessed, used, or disclosed. The loss or improper access, use, or disclosure of the Funds’ proprietary information may cause Viking or the Funds to suffer, among other things, financial loss, the disruption of their business, liability to third parties, regulatory intervention, or reputational damage. Hedging Transactions. The Funds are permitted to use a variety of derivatives and other financial instruments both for investment and risk management purposes, and may use boxed positions (i.e., holding a long and short position in the same investment) for similar purposes, though it is not required to do so. Viking may determine not to hedge any risks for a Fund, or it may determine only to hedge against certain risks in certain circumstances for each Fund. Moreover, Viking will not be able to anticipate every risk that could be hedged. While Viking may seek to enter into hedging transactions to reduce risk for a Fund, such transactions may result in a poorer overall performance for the Fund than if it had not engaged in any such hedging transactions. Such hedging transactions generally involve financing costs and may not successfully mitigate the risks that they are intended to limit. Moreover, each Fund’s portfolio will always be exposed to certain risks that will not be hedged. Foreign Exchange Risk. A portion of the Funds’ assets is expected to be invested in securities denominated in currencies other than the U.S. dollar. The Funds, however, value their securities in U.S. dollars. It can be extremely difficult to determine how to hedge the currency risk associated with a particular company, especially when the company’s underlying earnings are made in multiple currencies. To the extent unhedged or incorrectly hedged, the value of the Funds’ assets will fluctuate with U.S. dollar exchange rates as well as with price changes of the Funds’ investments in the various local markets. In addition, the Funds invest in U.S. companies with material foreign currency exposure. The Funds generally seek to hedge against currency fluctuations and generally use forward contracts to hedge against currency exposure, but there can be no assurance that such hedging transactions will be effective. Short Selling. The investment portfolio of the VGE Funds and the liquid investment portfolio of the Hybrid Funds include short positions as part of those Funds’ investment strategies. In addition, any Fund’s investment portfolio may include short positions, for instance, as a hedge to another position or exposure in such Fund’s investment portfolios. Short selling involves selling securities which are not owned and borrowing the same securities for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. A short sale creates the risk of unlimited loss, in that the price of the underlying security could theoretically rise without limit, thus increasing the cost to the Funds of buying those securities to cover the short position. For instance, a so-called “short squeeze” can occur if multiple short sellers seek to cover their short positions by purchasing the security and the price of a security starts to rise rapidly. If enough short sellers buy back the security, the price is pushed even higher, thereby making it more expensive for other short sellers to cover their short positions. Certain market participants, such as retail investors, may speculate by purchasing securities subject to a short squeeze, thereby driving the price even higher. If such speculation is conducted in a coordinated or targeted manner, for example through social media platforms, the losses to the Funds could be material. Moreover, any regulatory response to such activity could also have a negative impact on the Funds. For instance, certain jurisdictions have enacted restrictions on short selling (including wholesale bans, at times) as well as public disclosure requirements. The SEC had previously adopted rules that would have required public

disclosure of short positions on an aggregated basis by issuer. Although such rules were recently remanded following legal challenge, if similar short-selling restrictions and disclosure requirements are enacted (whether by the SEC or by regulators in other jurisdictions), the prices of the instruments in which the Funds invest may be materially affected and the ability of Viking to take advantage of opportunities for short selling may be significantly reduced. In addition, stock loan fees charged to the Funds for borrowing securities sold short may be substantial and will reduce any gains (or increase losses) associated with the short position. Lending of Portfolio Securities. The Funds lend securities from their portfolios to securities firms and financial institutions from time to time, for example, after a private company in which the Fund has invested goes public. The Funds also borrow portfolio securities from third-party lenders from time to time, for example, to facilitate their short selling activity. While a securities loan is outstanding, the lender will generally continue to receive the equivalent of the interest or dividends paid by the issuer on the securities, as well as interest on the investment of the collateral and/or a fee from the borrower. The lender will generally also receive collateral from the borrower. The primary risks associated with lending securities consist of possible delay in, or failure of, the return of borrowed securities (which, among other things, could result in a failure to meet settlement obligations on securities sold while out on loan), a decline in the value of collateral received in relation to the value of the securities loaned, possible loss of voting or other rights associated with the loaned securities, and the insolvency of the borrower. As a borrower, the primary risks relate to possible delay in, or failure of, the return of collateral, the value of the collateral exceeding the value of the securities loaned, and the insolvency of the lender. General Macroeconomic and Market Risk. General economic and market conditions (such as interest rates, availability of credit, inflation rates, currency exchange controls, and national and international political circumstances) may affect the performance of the companies in which the Funds invest, the level and volatility of securities prices, and the performance and liquidity of the Funds’ investments. Volatility and/or illiquidity could impair the Funds’ profitability or result in losses. Markets for the financial instruments in which the Funds seek to invest can correlate strongly with each other at times or in ways that are difficult for Viking to predict. An individual country or region’s economic problems may have a significant impact on global economic conditions. For example, a significant deterioration of the U.S. or European economy could result in disruptions in global capital markets. Similarly, if China were to experience a further economic slowdown, it could have wide-ranging impacts on other economies and capital markets in the rest of the world. Any of these or other adverse macroeconomic developments, such as rising inflation, heightened competition for workers, supply chain issues, and rising energy and commodity prices, could severely negatively impact the performance of the Funds. In addition, distress, illiquidity, insolvency, or failure of a bank, financial institutional, or other company in the financial services industry, or concerns among market participants of such an event or circumstance, have in the past and may in the future lead to market-wide liquidity problems that may impact the Funds’ or any Fund’s portfolio company’s access to liquidity. Market Stability. In recent years, the global financial markets, including in Europe and the U.S., have experienced significant fluctuations, including periods when there has been speculation as to the possibility of a default by a sovereign state in Europe in respect of its debt obligations (and as to the consequences of such a default or the action that will be taken by European central banking authorities to prevent, or to mitigate the impact of, such a default), and the prices of publicly traded securities throughout the world have, at times, become more

volatile. Geopolitical concerns and other global events, including trade conflict, national, and international political circumstances (including wars, civil unrest, international and U.S. domestic terrorist acts, and security operations), and pandemics or other severe public health events, have contributed and may continue to contribute to volatility in global markets. For example, 2025 was a year of significant geopolitical events, including among other things, the armed conflict between Russia and Ukraine, continued tensions with North Korea over its ballistic missile testing and nuclear programs, ongoing hostilities in the Middle East and the possibility of their escalation, and political tension and uncertainty in Latin America. Such concerns have contributed and may continue to contribute to instability and volatility in global financial markets. In addition, certain European Union (“EU”) countries with high levels of sovereign debt have had difficulty refinancing their debt, and concern that the Euro common currency might be devalued, or that sovereign default risk may become more widespread, has led to significant volatility in the exchange rates among the Euro, U.S. Dollar, and other currencies. These and similar factors could have an adverse effect on the liquidity and value of the Funds’ investments. Reliance on Company Management, Directors, and Substantial Shareholders. The Funds invest in minority positions of companies and in companies for which the Funds have no right to appoint directors or otherwise exert significant influence to protect their position. The Funds may also determine not to appoint a director or exert influence even in circumstances in which the Funds may have the right or ability to do so. In all cases, the Funds will rely significantly on such companies’ management and board of directors, which may include representation of other significant investors with whom the Funds are not affiliated and whose interests may conflict with the interests of the Funds. There can be no assurance that the Funds will be able to protect their rights in an issuer relative to significant shareholders with superior rights or that any Fund will exercise the rights it may have as a significant shareholder. Although the Funds will attempt to invest in companies with strong management teams, there can be no assurance that any company’s management team will be able to operate successfully or that any particular manager or key individual will continue to be employed by or involved with such company. Instances of fraud, including fraudulent conveyances, and other deceptive practices committed by the management team of companies in which the Funds have an investment may undermine Viking’s due diligence efforts with respect to such companies. Any such fraud could adversely affect the valuation of the Funds’ investments and contribute to overall market volatility that can negatively impact the Funds. Illiquidity; Market for the Funds’ Investments. The Funds invest in financial instruments and assets for which no public market exists, including privately held entities, restricted securities, and certain derivative instruments. Portfolios are also likely to include relatively illiquid investments in thinly traded issuers. The Funds’ ability to dispose of such investments is often limited by contractual restrictions and the specific agreements entered into in connection with the investment. Furthermore, the ability to sell or distribute securities and realize gains depends largely on favorable market conditions, including a receptive environment for initial public offerings (IPOs) and an active mergers and acquisitions (M&A) market. These exit opportunities may be limited or non-existent for extended periods due to economic, regulatory, or other factors, and illiquidity may persist even if an underlying entity obtains a listing on a securities exchange. Consequently, the Funds may not be able to sell illiquid investments at the time or price they desire, or realize what they perceive to be fair value. The sale of these assets often requires more time and results in higher transaction costs and related expenses than the sale of securities traded on national exchanges. Additionally, because price indications for illiquid investments may not be readily attainable, valuation involves significant uncertainty. Investors should be aware that at any given time, nearly all of

the capital of an investor in the Hybrid Funds may be allocated to illiquid investments. There can be no assurance that the Funds will be able to exit these positions successfully or on a timeline that meets their objectives. Valuation Risk. The Funds’ assets and liabilities are valued in accordance with Viking’s valuation policy, including based on comparisons and qualitative evaluations of private information (including information from portfolio companies). Viking’s determination of an investment’s fair value may differ materially from the value that would have been determined if a ready market for the securities or other investments had existed and from the valuations other parties ascribe to the same investment. There is no guarantee that the value assigned to a particular investment will reflect the value ultimately received by a Fund or an investor upon realization of the investment. Valuations are inherently subjective in certain respects and rely on a variety of assumptions, including assumptions about projected cash flows, market conditions, and/or any anticipated disposition or other realization of the investments; legal and contractual restrictions on transfers that would limit liquidity; and any transaction costs related to, and the timing and manner of, any anticipated disposition or other realization of the investments. Incomplete data, market instability, and financial model assumptions that are based on judgment may contribute to valuation uncertainties. There is a risk that a Fund’s assets and liabilities may be undervalued and/or overvalued relative to where they might trade if the investment had an active market. Investing in Non-U.S. Companies and Developing Markets. The Funds invest in securities of non-U.S. companies, including companies in developing markets. Investing in the securities of non-U.S. companies involves certain additional risks and considerations not usually associated with investing in securities of U.S. companies, particularly when investing in developing markets. These risks may include political and economic considerations, such as greater risks of expropriation and nationalization, imposition of withholding tax or other taxes on dividends, interest, capital gains, other income or gross sale or disposition proceeds, the potential difficulty of repatriating funds; general social, political, and economic instability; application of the rules relating to “controlled foreign corporations” or “passive foreign investment companies,” each as defined in the Code; the small size of the securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and in price volatility; and fluctuations in the rate of exchange between currencies and the potential risk of the imposition by non-U.S. regulatory authorities of restrictions on currency conversion. In addition, accounting and financial reporting standards that prevail in non-U.S. countries generally are not equivalent to standards in the U.S. and, consequently, less information may be available to investors in companies located in non-U.S. countries than is available to investors in companies located in the U.S. Certain non-U.S. countries may have less regulation (or less predictable regulation) of their securities markets than the U.S. In the event the Funds become engaged in litigation in a non-U.S. country, the Funds may be unable to enforce legal rights that would be enforceable in the U.S. Investing in Early- and Growth-Stage Companies. The Funds expect to invest in the equity, debt, or hybrid securities of growth-stage companies or entirely new companies. Investments in such early stage or newly formed companies may involve greater risks than generally are associated with investments in more established companies. These companies are frequently private companies and thus may offer illiquid securities and may not be subject to the same level of regulation as public companies. Less established companies tend to have lower equity capitalizations and fewer resources and, therefore, often are more vulnerable to financial failure. Such companies also may have shorter operating histories on which to judge future performance and in many cases, if operating, have negative cash flow. Start-up enterprises may not have significant or any operating revenues, and any such investment should

be considered highly speculative and may result in the loss of the Fund’s entire investment therein. Start-up enterprises are generally highly dependent upon one or more key individuals, and the departure of any key individual or the occurrence of adverse events affecting any key individual could negatively impact the value of the Funds’ investment in the enterprise. Investing in Small- and Medium-Capitalization Companies. The Funds expect to hold investments in the securities of companies with small- to medium-sized market capitalizations, for example, after a private company in which the Funds have invested goes public. Those securities, particularly small-capitalization securities, involve higher risks in some respects than do investments in securities of larger companies. For example, prices of smallcapitalization 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 for larger, more established companies. In addition, due to thin trading in some small-capitalization securities, an investment in those securities may be illiquid, and therefore difficult to exit quickly or at the market-quoted price. Investing in SPACs. The Funds have invested and may continue to invest in the debt, equity, or hybrid securities of SPACs, including through IPOs and PIPEs. The Funds may also sponsor or co-sponsor a SPAC or otherwise invest in a SPAC sponsor. A SPAC is a publicly traded company formed for the purpose of raising capital through an IPO to fund the acquisition of one or more operating businesses. Following an acquisition, the SPAC may exercise control over the management of the target company or, alternatively, the existing management team of the target company may continue to manage the resulting public operating company. Moreover, private companies in which the Funds invest may seek to become public companies by merging with a SPAC. Investors in SPACs and their sponsors are subject to many risks, including that: (a) if the SPAC is unable to locate or acquire a target company, investors in the SPAC will effectively have their capital locked-up through the SPAC’s acquisition deadline (except to the extent they sell their shares to recoup their capital outlay in whole or part); (b) the SPAC may be unable to consummate its IPO, resulting in losses for its sponsors; (c) sponsors of SPACs may incur expenses in their search for, and acquisition and management of, a target company, that exceed the capital set aside by the SPAC for such purposes, which may result in insufficient funds with which to complete an acquisition; (d) sponsors of SPACs typically acquire a significant percentage of the SPAC’s shares at the time of its IPO or in the years after a target business is acquired for a relatively minimal purchase price, which may provide an incentive for sponsors to complete an acquisition regardless of the relative attractiveness of a target business or the reasonableness of the proposed purchase price; (e) in connection with the acquisition of a target business, a SPAC may issue additional equity to third-party investors or to current owners of a target business, either of which may dilute existing SPAC investors; (f) the promote for the sponsor may be payable in shares and may dilute other SPAC investors; (g) the acquisition of a target business may not be subject to a stockholder vote or the ability for SPAC investors to redeem prior to the consummation of the acquisition; (h) most SPACs are relatively illiquid and have a concentrated shareholder base, which may lead to greater market volatility and greater risk of loss upon selling shares; (i) the securities of a SPAC may be subject to de-listing to the extent the issuer fails to satisfy applicable exchange listing requirements, including with respect to the number of record holders, upon completion of its acquisition of a target business; and (j) in the event creditors are successful in accessing the IPO proceeds held in a SPAC’s escrow account prior to completion of its acquisition of a target business, shareholders who redeem in connection with that acquisition will receive a smaller amount per share than would otherwise be expected. The Funds may invest in a SPAC that, at the time of investment, has not selected or approached any prospective target businesses and

the Funds may not have control over the ultimate acquisitions. These investments may include PIPEs, which are considered restricted securities under the Securities Act of 1933, as amended. The sponsors of any particular SPAC may have significant control and discretion with respect to consummating acquisitions and managing the combined companies. To the extent that a SPAC acquires a target company, it may be affected by any risks inherent in the business of that target company, including that the management team of the target business may be inexperienced in operating a publicly traded company. Moreover, because companies that become publicly traded as a result of a SPAC merger may not be subject to a traditional IPO underwriting and due diligence process, broker-dealers may be less willing or unwilling to facilitate secondary market trading of shares of such companies, which may limit the ability of the Funds to dispose of its investments in these companies. For these and additional reasons, investments in SPACs are speculative and involve a high degree of risk. Activist Investments. Viking has engaged in investment strategies that may be considered “activist,” or that involve the filing of a Schedule 13D with the SEC. Viking may choose to do so in the future on behalf of the Funds, for instance, in order to promote changes that it believes would enhance or protect the value of an existing investment. Such strategies may include attempts to influence change with respect to the management, governance, or capital structure of a company. The success of activist investments depends on a variety of factors, including (a) Viking’s ability to avoid triggering anti-takeover and regulatory obstacles while aggregating positions for the Funds; and (b) the response to Viking’s proposals by the portfolio company’s management and other security holders. In the event Viking pursues an activist investment strategy that fails, the investment losses to a Fund may be compounded by the fact that a Fund’s holdings have been publicly disclosed and/or by expenses incurred by such Fund to pursue this strategy. Any such investment losses may be substantial. In addition, Viking and the Funds may suffer reputational damage that negatively impacts Viking, the Funds, and the investors in the Funds. The Funds have engaged and may continue to engage in investment strategies that involve the formation of a “group” under the Exchange Act or otherwise involve agreements or coordination (or the appearance of coordination) among the Funds and third parties, including in connection with pre-insolvency reorganizations and out-of-court restructurings. The Funds may also be alleged or deemed to be a part of a group in situations where they did not intend to be a part of a group and undertook procedures to avoid the formation of a group. Viking has limited experience in participating as part of a “group” and with the associated regulatory considerations, which continue to evolve. Follow-On Investments. Viking has broad discretion to allocate follow-on investments among the Funds and, in the case of the Hybrid Funds, among investors in the Hybrid Funds. Follow-on investments by the Funds in a given issuer or instrument will generally be allocated to investors in accordance with the allocation procedures for new illiquid investments, but may alternatively be allocated based on participation in the existing investment. Thus, an investor participating in a follow-on investment may not have participated in the original, related illiquid investment. The participation of new investors in follow-on investments may effectively dilute the ownership of existing investors in the original, related illiquid investment. If an illiquid investment were in distress, Viking may have an incentive to support that illiquid investment through a follow-on investment that is riskier or more speculative than other investment opportunities available to the Funds at that time. If allocated to all existing investors, the investment risk of doing so could be borne disproportionately by newer investors who did not participate in the original illiquid investment. If allocated to the original investors in the related illiquid investment, then such original investors could suffer disproportionate losses relative to other investors in the Funds.

Diversity of Partners. Viking may, but is not obligated to, consider tax implications when structuring investments, together with other relevant legal and commercial considerations. To the extent Viking is able to do so given commercial, legal, and other constraints, Viking generally seeks to structure investments in a manner that it expects to be tax-efficient for the investors in the Funds. However, Viking may not be able to achieve a structure or outcome that is tax efficient, or that is equally tax-efficient for all investors. The nature and diversification of the Funds’ investments, as well as the manner in which they make, structure, hold, and exit them, will therefore likely lead to a more favorable economic, legal, tax, or regulatory outcome for some investors as compared to others. In selecting investments appropriate for a Fund, Viking generally considers the investment, tax, or other objectives of the Fund as a whole, not the investment objectives or structural circumstances of any Fund vehicle or investor individually. To the extent Viking is able to structure certain investments based in part on the structural, legal, tax, and regulatory constraints or circumstances of investors, it will not take into account such interests as they relate to each individual investor, except where required, and certain decisions by Viking may benefit or harm certain investors more than others. The portfolios and performance of the Funds, including vehicles that are part of the same Fund, may diverge from each other due to tax-related reasons. In addition, Viking’s receipt of performance-based profit sharing may create a conflict of interest between Viking and its partners, members, and employees, on the one hand, and the other direct and indirect investors in the Funds, on the other hand. Specifically, Viking has an incentive to cause a Fund to hold an investment for longer than three years, or to engage in recapitalizations or other transactions, in order for the gains underlying Viking’s incentive allocation to be taxed in the United States at long-term capital gain tax rates. This over three-year holding period does not benefit or have relevance for the tax treatment of the Funds or their investors. An investor generally bears its share of the costs and expenses incurred for a Fund as a whole, even if the cost or expense is related to or otherwise incurred in respect of certain investors, for example the costs and expenses associated with a structure designed to address the concerns of certain investors, regardless of whether the investor bearing the costs itself benefits therefrom. In addition, to the extent an investor is subject to statutory or other limitations on indemnification as a result of its sovereign status or otherwise, other investors may be subject to increased losses or be required to bear an increased portion of such indemnification amounts. Environmental Matters. The ordinary operation of, or the occurrence of an accident with respect to, a Fund’s portfolio company asset could cause reputational harm and major environmental damage, which may result in significant financial distress to such asset or portfolio company if not covered by insurance. Certain environmental laws and regulations may require that an owner or operator of an asset address prior environmental contamination, which could involve substantial cost. Such laws and regulations often impose liability without regard to whether the owner or operator knew of, or was responsible for, the release or presence of environmental contamination, and changes in environmental laws or regulations or the environmental condition of an investment may create liabilities that did not exist at the time of its acquisition and that were not foreseen. In addition, persons who arrange for the disposal or treatment of hazardous materials may also be liable for the costs of removal or remediation of these materials at the disposal or treatment facility, whether or not that facility is or ever was owned or operated by those persons. In addition, changes in climatic conditions could have a significant impact on the revenues, expenses, and conditions of certain investments. While the precise future effects of

climate change are unknown, it is possible that climate change could create risks such as (a) regulatory/litigation risk (e.g., changing legal requirements that could result in increased zoning and compliance costs, changes in business operations, and the discontinuance of certain operations and related litigation); (b) market risk (e.g., declining market for products and services perceived as greenhouse gas intensive); and (c) physical risk (e.g., risks to the plants or property owned, operated, or insured by a company, such as risks posed by severe weather events, including rising sea levels, increased severity or frequency of storms, drought, changes in precipitation levels, wind levels, annual sunshine levels, and other meteorological occurrences). ESG Risks. Viking believes that ESG issues have the potential to impact the operations and valuation of a company. The decline in the value of an investment due to an ESG event or condition will vary and depend on several factors including, but not limited to, the type, extent, complexity, and duration of the event or condition, prevailing market conditions, and the existence of any mitigating factors. Viking seeks to incorporate ESG considerations that it believes are material into its analysis to manage risks, identify opportunities, and facilitate wellinformed decision-making; however, there is no guarantee that Viking will necessarily do so or that it will be able to accurately assess ESG-related risks or that these measures will mitigate or prevent ESG risks from materializing in respect of the Funds or their investments. For instance, Viking seeks to utilize data when analyzing ESG issues, including data provided by third parties based on historical analysis. To the extent such data is incomplete or inaccurate, Viking may be limited in its ability to identify material ESG issues or properly assess the impact of such issues. This analysis is also dependent upon companies disclosing relevant data, and the availability of this data is often limited. Furthermore, the subjective nature of non-financial ESG criteria means a wide variety of outcomes is possible, and the data available may not adequately address material ESG factors and considerations. Viking encourages, trains, and provides its investment team members with various resources to identify and incorporate material ESG issues into their research; however, each determines whether and how to do so in any particular case. Even if Viking determines that a company is impacted by a material ESG issue, it may nonetheless cause a Fund to make an investment in the company, or in respect of the VGE Funds, the VLF Funds, the Hybrid Funds, and the Structured Capital Funds, establish a short position in the company. If such a short position is established, the VGE GP, VLF GP, Hybrid GP, and Structured Capital GP, as applicable, will ultimately be obligated to purchase the company’s securities to close out the short position. Viking has previously made investment decisions that did not take ESG issues into account and is likely to do so again in the future. Viking is limited in its ability to influence companies to improve their ESG practices, particularly in cases where the Funds do not have special governance rights. Viking’s level of engagement with a particular company on ESG issues will vary depending on a variety of factors, including the size of the Funds’ position and Viking’s willingness or desire to seek to influence a company’s management. Assumption of Catastrophe Risks. The Funds are subject to the risk of loss arising from direct or indirect exposure to various catastrophic and other force majeure events, including the following: hurricanes, earthquakes, and other natural disasters; war, terrorism, and other armed conflicts; cyberterrorism; major or prolonged power outages or network interruptions; public health crises, including infectious disease outbreaks, epidemics, and pandemics; and “acts of God.” To the extent that any such event occurs and has a material effect on global financial markets or specific markets or companies in which the Funds invest (or has a material negative impact on the operations of Viking, the Funds, or any of their respective service providers), the losses could be substantial and could have a material adverse effect on the Funds’ investments.

Public Health Emergencies Risks. Any public health emergency, including related to COVID-19 and any outbreak of SARS, H1N1/09 flu, avian flu, other coronaviruses, Ebola, or other existing or new epidemic diseases, or the threat thereof, could have a significant adverse impact on the Funds and their investments and could adversely affect the Funds’ abilities to fulfill their investment objectives. The extent of the impact of any public health emergency on the Funds and their investments’ operational and financial performance will depend on many factors, including the duration and scope of such public health emergency, the extent of any related travel advisories and restrictions implemented, the impact of such public health emergency on overall supply and demand, goods and services, market liquidity, investor liquidity, consumer confidence, and levels of economic activity, and the extent of its disruption to important global, regional, and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. The effects of a public health emergency could materially and adversely impact Viking’s ability to source, manage, and divest the Funds’ investments and also the value and performance of such investments, which could result in significant losses to the Funds. In addition, the operations of Viking and the Funds’ investments may be significantly impacted, or even temporarily or permanently halted, as a result of government quarantine measures, voluntary and precautionary restrictions on office attendance, travel, or meetings, and other factors related to a public health emergency, including potential adverse impacts on the health of any such entity’s personnel. No previous success by Viking in dislocated markets or during the COVID-19 pandemic is any guarantee of the Funds’ success in respect of investing and managing any investment during and after any public health emergency. Regulatory Burdens. Legal, tax, and regulatory changes are occurring and are likely to occur during the terms of the Funds, and some of these changes may have a material adverse effect on the Funds. The financial services industry generally, and the activities of private funds and their managers, have been subject to intense and increasing scrutiny from lawmakers and regulators. Any newly adopted rules and proposed rules have impacted (and are likely to continue to impact) Viking, the Funds, and their respective affiliates in a variety of ways, and could have a material adverse impact on Viking, the Funds, and their respective affiliates. Such scrutiny, and any proposals that become effective, may increase Viking’s exposure to potential liabilities and to legal, compliance, and other related costs. Increased regulation and oversight (whether promulgated under securities laws or any other applicable law) may also impose additional administrative burdens on Viking, including responding to inquiries and investigations, and implementing new policies and procedures. Such burdens may direct Viking’s time, attention, and resources away from portfolio management activities. Additionally, any changes in the regulatory framework applicable to the Funds may impose additional expenses, require the attention of senior management, and/or result in limitations in the manner in which the Funds’ business is conducted. It is impossible to predict what, if any, changes in regulation applicable to the Funds, Viking, or their respective affiliates, the markets in which they trade and invest or the counterparties with which they do business may be instituted in the future. The effect of any future regulatory change on the Funds or investors could be substantial and adverse. For instance, regulations may restrict the types of investments the Funds may make, prevent the Funds from exercising voting rights with regard to certain securities, or require the Funds to disclose the identity of its investors, its positions or otherwise. Viking may, in its sole discretion, cause the Funds to become subject to such regulations if it believes that an investment or business activity is in the Funds’ interests, even if such regulations may have a detrimental effect on one or more investors.

Data Privacy and Security Laws. Jurisdictions in which the Funds operate have adopted, or are considering adopting, stringent data privacy and cybersecurity laws, including the General Data Protection Regulation in the EU and equivalent UK legislation, the California Consumer Privacy Act and the California Privacy Rights Act, the New York SHIELD Act, the Data Protection Act (As Revised) of the Cayman Islands, and a range of proposed additional laws at the federal level and in Texas, Utah, Washington, and other states. The cumulative effects of the adopted laws include: an enhanced ability of individuals, relative to companies, to control the use of their personal data; increased obligations to maintain the security of data; and additional exposure to fines or damages for companies that do not accord individuals their specified privacy rights, that experience data breaches, that do not timely disclose data breaches, or that fail to maintain cybersecurity at certain levels. Viking endeavors to maintain systems that promote compliance with data privacy and security laws, both those adopted to date and those that may be adopted in the future, but there can be no assurance that these systems will be effective. Failure to comply with such laws could result in disclosure of confidential information and/or significant fines or damages that could have a material adverse effect on the Funds. Systems and Operational Risks. Viking relies heavily on financial, accounting, and other data processing systems. Many of these systems require manual inputs and processing that are susceptible to human error. In addition, the Funds rely on information systems to store sensitive information about the Funds, Viking, their affiliates, and the Funds’ investors. Certain of the Funds’ and Viking’s activities are dependent upon systems operated by third parties, including prime brokers, the Funds’ administrator, market counterparties and other service providers. Failures in the systems employed by Viking and such third parties could result in significant harm to Viking, the Funds, and the Funds’ investors. Dependence on Key Individuals. The successes of the Funds are expected to be dependent upon the expertise of Viking’s personnel, including its CEO, CIO, Head of Private Investments, portfolio managers, deal captains, and other members of the investment team. The CEO and his delegates have the authority to make determinations that may significantly impact the Funds and their investors, such as investment allocation and risk management decisions. The Funds’ governing documents do not contain any “key person” provisions, and investors are not entitled to cause a cessation of investment activities or withdrawal of capital in the event any one or more particular persons cease to be involved with the Funds. In addition, Viking employees are hired at-will and are not subject to employment agreements of any defined duration, and compensation arrangements, including year-end bonus compensation, for Viking employees may not be subject to vesting periods or other forms of deferral. Viking employees are highly mobile. The temporary or permanent loss of key individuals—due to departure, death, sickness, illness, or physical injury, or other reasons—could adversely affect the Funds’ performance or, in the case of certain key individuals, the Funds’ capital base and ability to deploy capital. Moreover, sickness, illness, or physical injury can lead to temporary or permanent loss of key individuals. The investments made by the Funds and the strategy, management, and disposition determinations related to such investments are highly dependent upon the firm’s investment team. The hiring, promotion, or termination of investment team members, and the specific coverage areas in which they operate may have a significant impact on the performance of the Funds. For example, when a portfolio manager leaves the firm, Viking typically transfers certain of the positions managed by that portfolio manager to other portfolio managers, while liquidating or hedging other such positions. Any such liquidation may cause losses for the Funds or prevent the Funds from participating in future gains on the liquidated positions. Moreover, if a liquidation results in the VGE Funds reducing their gross exposure, Viking will generally also reduce the gross exposure of the Hybrid Funds’ liquid

portfolio, which may result in a rebalancing of the Hybrid Funds’ liquid portfolio, although the Hybrid Funds may maintain such reduced exposure for an extended period of time. Since different portfolio managers may manage the same investments for different Funds differently, the performance of the Hybrid Funds as compared to non-Hybrid Funds may vary based on the decisions of the relevant portfolio managers managing each Fund. An investment team member’s responsibilities are expected to change from time to time without notice to or consent of the investors, and certain investment team members may not be assigned to manage any of the Funds’ investments. In certain instances, a Viking individual or subset of Viking individuals, which may include the CEO or Head of Private Investments and/or other investment team members, may be excluded from participating with respect to certain investment decisions if deemed necessary by Viking, and the Funds may still participate in such investment. For example, certain Viking individuals may be and sometimes are walledoff from specific investment decisions when Viking determines they have received relevant material non-public information (“MNPI”) or that they are conflicted for some other reason, such as the holding of a personal investment in a prospective or current portfolio company or issuer by such individual or by a family member (or employer thereof) of such individual. Independent Advisory Committee Considerations. An Independent Advisory Committee, if established by Viking, is permitted to review and approve of any matter placed before the Independent Advisory Committee by Viking. Viking may contemporaneously or sequentially form (and subsequently dissolve) separate Independent Advisory Committees to address separate matters, each of which may have distinct or overlapping membership. The Independent Advisory Committee members can be, but are not required to be, representatives of investors. Investors (if any) that serve on an Independent Advisory Committee may have interests that differ from, or conflict with, the interests of other investors due to different legal, tax, or regulatory regimes, their interests in the Funds (e.g., their portfolio of Illiquid Investments), their overall relationship with Viking, and/or other individual circumstances relevant to the investor. Independent Advisory Committee members that are not representatives of investors likely also have interests that differ from, or conflict with, the interests of other investors. In general, there can be no assurance that an Independent Advisory Committee will approve or disapprove of the same matters that other investors would approve or disapprove of were such matters placed before such investors. An Independent Advisory Committee can make decisions that benefit its members, the Funds, or Viking, even if they are adverse to other investors, and such decisions will be binding on all investors (including those adversely affected thereby). The selection of members of an Independent Advisory Committee could present conflicts of interest and create an incentive to select members that Viking believes are most likely to support a matter brought to it for approval. Viking Information. In connection with its services to the Funds and their investments, Viking expects to receive certain tangible and intangible benefits. For example, in the course of Viking’s operations, including research, due diligence, investment monitoring, operational improvements, and investment activities, Viking and its personnel expect to receive and benefit from information, “know-how,” experience, analysis, and data relating to the Funds, and also operations, terms, trends, market demands, customers, vendors and other metrics of the Funds’ portfolio companies (collectively, “Viking Information”). In many cases, Viking Information will include tools, procedures and resources developed by Viking to organize or systematize Viking Information for ongoing or future use. Although Viking expects the Funds and their portfolio companies generally to benefit from Viking’s possession and use of Viking Information, it is possible that any benefits will be experienced solely by certain Funds or their portfolio companies, or by Viking and its personnel, and not by the Funds or the portfolio company from which Viking Information was originally received.

Viking Information will be the sole intellectual property of Viking and solely for the use of Viking. Viking reserves the right to use, share, license, sell, or monetize Viking Information, without offset to Management Fees, and none of the Funds or their portfolio companies will receive any financial or other benefit of such use, sharing, licensure, sale, or monetization. Cybersecurity and Technology Risks. Viking relies on the use of technology in the operation and administration of Viking and the Funds, including, but not limited to, internetbased programs, data storage applications and certain artificial intelligence technologies (as described further below). These technologies, however, expose Viking and the Funds to operational and other risks, including through the potential for breaches of Viking’s information and technology systems or those of third-party service providers. Despite the security measures established by Viking and third parties to safeguard the information in their systems, such systems may be breached due to attacks by hackers, employee error or malfeasance, or other disruptions. Third parties may also attempt to fraudulently induce employees, customers, third-party service providers, or other users of Viking’s systems to disclose sensitive information in order to gain access to data belonging to Viking, the Funds, or the Funds’ investors. Any such breach could compromise these systems and result in the theft or loss of assets or the theft, loss, or public dissemination of the information stored therein. Moreover, although Viking’s business continuity plan seeks to address local disruptions of telecommunications, internet access, and other electronic communication methods (such as private data and voice circuits for electronic trading and broker communications) and other means of electronic communication, the Funds remain vulnerable to the direct and indirect effects of any broad-based disruptions. The service providers of Viking and the Funds are also subject to electronic information security threats. These threats could impact investors both because these service providers maintain sensitive information and because their systems can be misused by hackers to access Viking’s systems. Investors could also be exposed to losses resulting from unauthorized use of their personal information. If there were a breach of a service provider’s networks, sensitive information (including relating to the transactions of the Funds and personally identifiable information of investors) may be lost or improperly accessed, used, or disclosed. Any of the foregoing failures or disruptions could have a material adverse effect on the Funds. Similar types of cybersecurity risks also are present for issuers of securities or other assets in which the Funds invest, which could affect their business and financial performance, resulting in material adverse consequences for such issuers, and causing the Funds’ investments in such securities or other assets to lose value. Phishing and Impersonation of Viking Personnel. Unaffiliated actors have in the past fraudulently presented themselves, through messaging apps and deceptive websites, as representatives or personnel of Viking, and these or other unaffiliated actors continue to, and may in the future, engage in similar fraudulent activity. Impersonators may seek personal information, financial details, or payments under the guise of Viking’s name in a practice commonly known as “phishing.” Such phishing attempts, other impersonation scams, and similar fraudulent activity pose a significant risk to the potential victims. Additionally, the use of Viking’s name and likeness in fraudulent schemes could negatively affect Viking’s reputation, diminish investors’ trust in Viking, and create potential confusion among the Funds’ existing and prospective investors. This reputational damage may adversely affect Viking’s ability to attract and retain investors, potentially impacting its ability to manage the Funds. Although Viking generally takes certain steps to protect its investors, the Funds, and Viking’s reputation from the negative effects of such fraudulent schemes, Viking ultimately has no control over unaffiliated actors’ propagation of such schemes and its efforts to halt such scheme may be ineffective.

Artificial Intelligence Risks. Developments in artificial intelligence such as ChatGPT and similar large language models, chatbots, agents, and other technologies (collectively, “Artificial Intelligence”) can pose risks to Viking, the Funds, and the Funds’ portfolio companies. Viking uses Artificial Intelligence in various processes, including to assist with certain investment research and operational functions. Viking is also exposed to the risks of Artificial Intelligence through third parties (including, but not limited to, Viking’s or the Funds’ service providers or counterparties) that use Artificial Intelligence, and Viking may not be aware of such use. Viking cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Artificial Intelligence is highly reliant on the collection and analysis of large amounts of data, and in many instances, it may not be possible or practicable to incorporate all potentially relevant data into the dataset that Artificial Intelligence utilizes or to fully evaluate and verify the source and the reliability of the data being analyzed. Further, the outputs of Artificial Intelligence may be inaccurate or unreliable and are also susceptible to errors in such outputs’ creation or subsequent analysis. Additionally, the use of Artificial Intelligence may involve (a) cybersecurity risks (including the increased likelihood that Viking, the Funds and the Funds’ portfolio companies become a victim of cybercrime), (b) threats to proprietary, personally identifying, and confidential information, (c) intellectual property violations, and (d) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats, and/or violations could have adverse impacts on Viking, the Funds, the Funds’ portfolio companies, and investors. Artificial Intelligence continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments. Due to the rapidly evolving nature of Artificial Intelligence and its widespread potential uses, Viking expects that its policies, procedures, and practices will continue to evolve in response to challenges presented by Artificial Intelligence in a manner reasonably designed to match Viking’s use of, and interaction with, such technologies. Rules-Based Strategies. Viking may and sometimes does use rules-based strategies to increase the Funds’ exposure to certain positions or portfolios. These strategies may use rulesbased methods to generate trade orders, which orders may be executed using algorithmic trading strategies and may or may not be reviewed by human traders (see “Algorithmic Trading” below). Such strategies and the associated methods are likely to change over time and they (and the computer programs upon which they may and sometimes do rely) may need to be updated to remain effective. There can be no assurance that Viking will be able to continue to develop, update, maintain, or utilize effective rules-based strategies, and any changes that are made in an attempt to optimize the strategies in light of changing conditions (or otherwise) may be unsuccessful. While Viking’s employees endeavor to minimize the occurrence and effect of errors, including by testing rules-based strategies and related trade execution procedures, Viking cannot provide any assurance that such strategies will operate in all instances in the intended manner or that they will produce the desired investment results, and there may be trade errors (or similar errors) which could have significant adverse consequences. Algorithmic Trading. Viking uses customized algorithmic trading strategies, which employ computer-programmed algorithms (typically designed and operated by the Funds’ brokers, sometimes with input from Viking) to execute trades based on a set of pre-determined rules and objectives. Short selling allows an investor to profit from declines in the prices of securities. A short sale creates the risk of unlimited loss, in that the price of the underlying security could theoretically rise without limit, thus increasing the cost to the Funds of buying those securities to cover the short position. There can be no assurance that the security necessary to cover a short position will be available for purchase. Purchasing securities to close

out the short position can itself cause the price of the securities to rise further in the event of a lack of supply, thereby exacerbating the loss. Errors of design or implementation (which may become apparent only in certain market conditions) may cause the Funds to trade in ways that are aberrant and contrary to the intention of Viking. Errors in an algorithm may reveal a Fund’s trading activity to the market (for instance, by comprising too large a percentage of total market participation during a period) thereby allowing other market participants to anticipate and detect the Fund’s trading logic and compromise the strategy, which can lead to an increase in the implicit cost of trading by the Fund. An error in an algorithm could also cause the Funds, for instance, in a “flash crash” scenario, to execute trades at prices that were not intended or anticipated by Viking and diverge significantly from the intrinsic value of the relevant security. The Funds may also use one or more customized “routing algorithms” designed by Viking to route orders to specific brokers. These routing algorithms may be and sometimes are utilized with limited human involvement. An error in these “routing algorithms” could result in losses to the Funds, for instance, due to a failure to achieve best execution or failure to function as designed. Although Viking has taken steps to ensure that the algorithms it uses (directly or indirectly through brokers) will work as intended, there can be no assurance that they will in all cases. Any breakdown in algorithmic trading could cause substantial losses to the Funds. Trade Errors; Human Error. Viking’s process for making investments, including placing orders and executing trades, is subject to the risk of error. For example, human errors may include keystroke errors that occur when entering trades into an electronic trading system, failures of oral communication between the investment staff and trading staff, or typographical or drafting errors related to investment transaction documents, derivative contracts, or similar agreements. Trade Errors may also arise from programs or algorithms designed to operate with limited human involvement. Investors should assume that trading errors (and similar errors) will occur and that the cost of trade errors may be significant. Under Viking’s trade error policy, the Funds will bear any and all losses resulting from trade errors and similar human errors, absent fraud, willful misconduct, or gross negligence on the part of Viking. Viking attempts to exercise reasonable care in hiring and training its personnel and its retention of third-party service providers. Nonetheless, the risk exists that any employee of Viking, and any employee of a service provider, may make errors—of omission or commission—that cause significant losses to the Funds and their investors. Human error might occur in any of the following examples: the calculation of net asset values; the handling of assets and wiring of withdrawal proceeds; the handling of personal information; the negotiation of contracts; the maintenance of data or models; the safeguarding of one or more of Viking’s systems; developing, coding and implementing new software and other technologies, and innumerable other potential errors, including ones that could impact the quality or accuracy of information provided to the investment team and that may impair their ability to make sound decisions. In addition, effective execution requires not only top performance by employees, but also effective coordination and communication among employees. Failures in communication and coordination can also cause significant errors. Misconduct by Personnel of Viking and Service Providers. The Funds rely on a substantial number of personnel of Viking, counterparties, and other service providers. Misconduct by such personnel, or even unsubstantiated allegations of misconduct, could cause significant reputational and financial damage to Viking and the Funds. Misconduct may involve, for instance, the entering into of unauthorized trades, the sending of unauthorized wire transfers, the concealment of unsuccessful trading activities (which could result in unknown and unmanaged risks or losses), or the intentional mis-valuing of illiquid investments. Misconduct may also arise in more subtle ways, including failures to disclose conflicts of interest, the making of investment decisions designed to defer recognition of losses on an

investment and thus increase near-term Incentive Allocation, or the use of unauthorized electronic communication platforms to conduct Viking’s business. Personnel may also improperly use or disclose MNPI in violation of insider trading laws, or the SEC’s interpretation of such laws, including inadvertently (if, for example, Viking obtains MNPI through an alternative data vendor, despite its efforts to avoid receiving such MNPI). In addition, losses could result from other deceptive, manipulative, or otherwise inappropriate conduct, including front running the Funds’ activities; failing to book or recognize trades appropriately; causing intentional systems damage or data loss; misappropriating assets; and engaging in harassment. For example, if a portfolio manager leaves the firm and Viking decides to liquidate positions previously managed by that portfolio manager, information regarding the departure and liquidation may be made public before Viking is able to complete the liquidation, which may result in losses for the Funds. Although Viking has adopted certain measures to prevent and detect misconduct of its personnel and attempts to ensure that the Funds transact with reliable counterparties and third-party service providers, such efforts may not be effective in specific cases. Additionally, Viking may be exculpated and indemnified by the Funds from and against losses resulting from such misconduct. Exposure to Material Non-Public Information. From time to time, Viking receives actual or potential MNPI with respect to an issuer and will have to restrict the Funds from buying or selling securities of the issuer to which such information relates. For instance, Viking may, and sometimes does, inadvertently receive actual or potential MNPI during its normalcourse, fundamental research of public issuers. Viking may also receive actual or potential MNPI (a) because certain Viking personnel serve on the boards of directors or in other similar capacities of Viking’s portfolio companies, (b) through other officer or director positions held by Viking personnel, or (c) as a result of information Funds receive in connection with their investments in portfolio companies. Furthermore, the nature of a Fund’s investment program may cause Viking to acquire MNPI through channels that were not relevant to Viking’s acquisition of MNPI in connection with other Funds. For example, Viking is likely to engage in conversations with issuers of publicly traded securities or securityholders of such issuers in connection with amendments to or modifications of an issuer’s loans or debt instruments. This possibility presents an acute risk of Viking receiving MNPI, particularly in cases where a Fund invests in one part of the capital structure of an issuer and one or more other Funds invests in another part (or other parts) of the capital structure of the same issuer, as the information available to Viking by virtue of those investments will likely be greater than if Funds only invested in one part of such issuer’s capital structure. In addition, the Funds invest from time to time in private companies that have or may seek to develop business relationships with public companies in which the Funds may invest. As a result, the private companies sometimes receive actual or potential MNPI with respect to the business and operations of the public companies. This gives rise to a number of risks, including that Viking may receive such actual or potential MNPI through such private company investments and have to restrict its Funds from buying or selling securities of the public issuer to which such information relates. Such restrictions and others imposed under or by law, regulation, regulatory bodies, and governmental bodies (and the policies and procedures Viking has implemented to mitigate them as described below) could result in the loss of attractive investment opportunities for the Funds, require the sale of part or all of certain portfolio companies, or require Viking to take (or not take) certain actions in respect of a portfolio company, including on a timeline or in a manner deemed undesirable by Viking, or may limit the ability of one or more portfolio companies from conducting their intended business in whole or in part. For example, if these restrictions arise in respect of securities in which the Funds have existing positions, they could give rise to substantial investment losses or opportunity costs, since the Funds will be unable to trade the positions for so long as such restrictions are in place. This risk of loss would be

particularly acute in the event the Funds were to become restricted in a security in which they have a short position, since the risk of loss in short positions is theoretically unlimited. Consequently, there can be no assurance that the Funds will be able to participate in all potential investment opportunities that fall within their investment objectives or that the Funds will be able to liquidate or exit an opportunity in the same manner or on the same timing as would be the case if such restrictions did not apply. Viking has implemented policies and procedures designed to mitigate the risk of receiving actual or potential MNPI, including through private company investments. Those policies and procedures include, but are not limited to, (a) the discretion to implement information barriers, including between Viking (but not, in some circumstances, its Legal & Compliance department) and a private company in which the Funds are invested or in which they may invest (including for commercial reasons, e.g., if a portfolio company requires that a Fund keep information about the portfolio company confidential and not disclose it to other Funds, or for other reasons (e.g., to benefit other Funds)) and (b) declining to receive all information available with respect to a private company. When implementing an information barrier with respect to a private company, Viking’s Legal & Compliance department has the ability to (i) designate an appropriately qualified professional who will be walled-off from the rest of Viking, to receive MNPI from the private company, and who will have delegated decision-making authority with respect to that private company investment while the information barrier is in place; and (ii) retain an external valuation expert, who will be similarly walled-off from the rest of Viking, and who will have delegated responsibility to produce a fair valuation of the Funds’ investments in the relevant private company. If any such walled-off individual, or other individuals, are precluded from providing services to the Funds or from being involved in specific investment-related activities or decisions because of certain confidential information available to those individuals or to other Viking personnel, the Funds could be adversely impacted. Viking may also choose not to receive information from a private company that may constitute MNPI. The use of such information barriers and other policies and procedures give rise to a number of risks, including that: (a) Viking’s ability to manage certain investments may be impeded; (b) there may be operational disruptions and additional costs, including possible costs related to hiring an external valuation expert; (c) the use of an external valuation expert could result in a fair valuation for a private company investment that is different from the valuation that might otherwise have resulted; and (d) the Funds’ valuation of a private company may not comply with GAAP. In instances where an information barrier is erected, the Funds’ abilities to benefit from Viking’s expertise outside any such barrier will be limited. In addition, in any particular situation Viking may be unable to implement this process, for instance, if the individuals intended to be “walled off” from the firm are unavailable or otherwise prevented from taking on the necessary responsibilities. There is also no guarantee that this process will function as intended and, despite Viking’s efforts to implement such an information barrier, the Funds may nonetheless become restricted from trading certain securities. In certain situations, Viking may permit an investment professional on one side of an information barrier to participate in certain investment advisory activities involving a business on the other side of the information barrier. To the extent such investment professional acquires MNPI in connection with such activities, the Funds on both sides of an information barrier may be restricted from making certain investments. It is also anticipated that Viking and its affiliates could obtain nonpublic information regarding target companies and other investment opportunities and trade securities and debt instruments in the secondary market. This is expected to lead to many of the same conflicts of interest as described above.

Use of Alternative Data. Viking obtains and uses alternative data in its investment process. Alternative data may consist of datasets that have been culled from a variety of sources, such as internet usage, payment records, financial transactions, weather and other physical phenomena sensors, applications, and devices (such as smartphones) that generate location and mobility data, data gathered by satellites, government and other public records databases, and data purchased from third party vendors or collected through web scraping. Viking uses alternative data in a variety of ways, including by incorporating it into Viking’s fundamental research of companies. The analysis and interpretation of alternative data involves a high degree of uncertainty and may entail significant expense, including technological efforts, that are expected to be borne—in whole or in part—by the Funds. No assurance can be given that Viking will be successful in utilizing alternative data in its investment process. The use of alternative data involves an inherent risk that Viking may rely on data outputs that reflect faulty system logic or that are based on inaccurate or incomplete data inputs. Moreover, there has been scrutiny from a variety of regulators regarding the use of alternative data for investment purposes, and its use or misuse under current or future laws and regulations could create liability for Viking and for the Funds in various jurisdictions. Firms that buy alternative data from vendors could face enforcement actions if a regulator determines that they have not done adequate diligence on such vendors to mitigate the chance of receiving and using MNPI. Viking cannot predict what, if any, regulatory or other actions may be asserted with regard to alternative data, but any regulatory investigations or formal actions could cause reputational, financial, or other harm to Viking and/or to the Funds. Any future limitations on the use of alternative data could have a material adverse impact on the performance of the Funds. Cryptocurrency and Digital Assets Risks. The Funds may, through their investments, be exposed to risks relating to virtual currencies, decentralized application tokens, protocol token and other cryptofinance coins, tokens, and digital assets and other instruments that are based on blockchain, distributed ledger or similar technologies (“Cryptocurrencies and Digital Assets”). These risks have the potential to materially and adversely impact companies and investment vehicles whose business models are focused on or have direct exposure to products or services relating to Cryptocurrencies and Digital Assets. Similarly, these risks have the potential to adversely impact companies and investment vehicles whose business models are not focused on such products or services, but who are exposed to price volatility or security risks as a result of indirect exposure to Cryptocurrency and Digital Assets through their revenue streams or investment holdings. C. Risks Associated with Particular Types of Instruments. The following is a summary of certain material risks involved with the types of instruments in which the Funds invest. Equity Securities Generally. The Funds invest in equity securities and equity-related securities. Equity securities fluctuate in value in response to many factors, including the activities and financial conditions of individual companies. As a result, a Fund may suffer losses if it invests in equity instruments of issuers whose share price performance diverges from Viking’s expectations. The Funds also may be exposed to risks that issuers or agents will not fulfill contractual obligations, such as in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities, registering restricted securities for public resale, or other trade settlement failures. Privately offered equity securities have limited liquidity and may never become publicly traded or otherwise freely tradable. Debt Instruments. The Funds invest a portion of their assets in bonds and other fixedincome instruments, including U.S. Treasury securities, bank loans, and leveraged loans. The

value of fixed income instruments changes in response to fluctuations in interest rates. When interest rates rise, the value of debt instruments can be expected to decline. Debt instruments with longer maturities tend to be more sensitive to interest rate movements than those with shorter maturities. Debt instruments in which the Funds invest may be unrated, and whether or not rated, the debt instruments may have speculative characteristics. Fixed income securities are also subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to factors including interest rate sensitivity, market perception of the creditworthiness of the issuer, and general market liquidity. Corporate debt instruments may suffer from increased interest rates and/or diminished performance of issuing companies. Even when Viking attempts to incorporate downside protections in the terms of an investment for a Fund, for example, by seeking restrictive covenants or a favorable loan-to-value ratio in the case of a credit investment, such downside protections may be inadequate to protect the Fund from losses on such investments. Certain Funds expect to invest in debt securities and private debt instruments, including those of unrated or non-investment grade companies, which could include investments in leveraged loans, high yield bonds, senior secured bank debt, junior loans, subordinated loans, syndicated bridge commitments, and unsecured loans. Investments in such debt securities and private debt instruments are subject to the ability of the issuer or the borrower to meet principal and interest payments on the obligation and may be subject to price volatility due to such factors as interest rate sensitivity, as discussed above, market perception of the creditworthiness of the issuer or the borrower, and general market conditions. Such risks are greater for investments in non-investment grade, non-rated, or lower credit quality debt than for investments in higher rated debt. In addition, private debt instruments have significant liquidity risks and market value risks since they are not generally traded in organized exchange markets but are traded by banks and other institutional investors. Forward Contracts. The Funds may invest in forward contracts (on currencies or other assets) and options thereon, which, unlike futures contracts, are not traded on exchanges and are not standardized; rather, banks and dealers act as principals in these markets, negotiating each transaction on an individual basis. Forward and “cash” trading have historically been less heavily regulated than trading on exchanges; there is no limitation on daily price movements and speculative position limits are not applicable. The principals who deal in the forward contract markets are not required to continue to make markets in such contracts. Market illiquidity could result in significant losses to the Funds. Equity Swaps. The Funds may make use of equity swaps to gain exposure to the value of the underlying security, particularly when it is impractical or impossible to trade the underlying security directly or where using equity swaps provides financing, regulatory, or tax benefits relative to trading the underlying security. A swap is a contract under which two parties agree to make periodic payments to each other based on the value of a security, specified interest rates, an index, or the value of some other instrument, applied to a stated or “notional” amount. An equity swap is a customized derivative instrument that entitles the counterparty to certain payments on the gain or loss on the value of an underlying equity security. Equity swaps, as with many other financial instruments, are subject to various types of risk, including market, liquidity, counterparty credit, legal, and operational risk. Options and Futures. The Funds may invest in options and futures contracts. These instruments can be highly volatile and involve risks such as leverage, illiquidity, and counterparty default. Options trading, whether covered or uncovered, can result in substantial or unlimited losses, particularly for sellers of uncovered options. Futures contracts are subject to price volatility, position limits, and potential suspension or restriction of trading by

exchanges or regulators. Both options and futures may be illiquid, making it difficult to exit positions at favorable prices. The use of derivatives for hedging or investment purposes may result in disproportionate profits or losses due to the high leverage involved. These risks can significantly impact the Funds’ performance and may cause investors to lose a substantial portion or all of their investment. Credit Default Swaps. The Funds may invest in credit default swaps (“CDS”) transactions, including index CDS, for hedging and/or investment purposes. The “buyer” in a credit default 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 obligation has occurred. If a “credit event” occurs, generally the seller must pay the buyer an amount intended to permit the buyer to recover the full notional value, or “par value,” of the obligation. If the Funds are buyers and no credit event occurs, the Funds will have made a series of periodic payments and recovered nothing of monetary value. If the Funds are sellers and a credit event occurs, the Fund will be obligated to pay the difference between the full notional value of the reference obligation and the value of the reference obligation as calculated pursuant to the terms of the CDS either through cash or physical settlement. In addition to these risks of loss, CDS carry, like all derivative contracts, the additional risk that even if the value of the CDS contract increases, the counterparty to the CDS trade may default on its obligation to pay the amount due, potentially causing large losses to the Funds. There have recently been allegations that CDS protection buyers have negotiated with reference entities to trigger credit events under standard CDS documentation or have otherwise sought to manipulate prices in CDS auctions, and certain regulators have indicated that such behavior may constitute market manipulation. Such allegations, behavior, and regulatory actions related thereto may affect the value of the Partnership’s CDS positions directly and could affect liquidity and prices in the CDS market more generally.

Viking Performance serves as the general partner or investment manager of each of the VGE Funds; VLF GP serves as the general partner or investment manager of each of the VLF Funds; Hybrid GP or Hybrid Portfolio GP serves as the general partner of each of the Hybrid Funds; Drawdown GP serves as the general partner of each of the Drawdown Funds; Vintage IV GP serves as the general partner of each of the Vintage IV Funds; and Structured Capital GP or Structured Capital Portfolio GP serves as the general partner of each of the Structured Capital Funds. Each of Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP is exempt from registration as a commodity pool operator. VGI’s relationship with each of Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP does not create a conflict of interest for VGI with its clients. VGI engages certain of its affiliates to provide investment research, analysis, recommendations, and/or advice to VGI with respect to the Funds. VGI assumes full responsibility for any and all fees payable to its affiliates in connection with their provision of services. Such affiliates include Viking Europe and Viking Hong Kong. Viking Europe is registered with the Financial Conduct Authority in the UK and Viking Hong Kong is registered with the Securities and Futures Commission in Hong Kong. Viking Europe and Viking Hong Kong are each authorized to exercise discretionary investment authority over a portion of the assets of certain Funds. VGI’s relationships with Viking Europe and Viking Hong Kong do not create a material conflict of interest for VGI with its clients. D. Material Conflicts of Interest Relating to Other Investment Advisers. VGI does not recommend or select other investment advisers for its clients.

employees may not take inappropriate advantage of their positions. This means that employees may not personally take opportunities that are discovered through the use of corporate property, information, or position for personal gain, or compete with Viking or the Funds.

The Code of Ethics includes, among other things, provisions relating to conflicts of interest, acceptance of significant gifts, reporting of certain gifts and business entertainment items, political contributions, charitable contributions, and personal securities trading. All employees at Viking must acknowledge annually that they understand and agree to the terms of the Code of Ethics. Certain other individuals, such as Viking’s principals and certain consultants, have also agreed to comply with the Code of Ethics as if they were Viking employees. Throughout this Item 11, the term “employees” shall be deemed to include such other individuals. Clients and prospective clients may request a copy of Viking’s Code of Ethics by contacting Viking Investor Relations at (212) 672-7000 or inquiries@vikingglobal.com. B. Securities In Which Viking or a Related Person Has a Material Financial Interest. Cross Trades. Viking routinely rebalances the Funds’ liquid portfolios in proportion to their respective net asset values or to maintain exposure levels consistent with each Fund’s objectives. Rebalancing may result in cross trades, which are transactions in which the buyer and seller are managed by the same investment manager. Viking determines in its discretion whether rebalancing should be performed. None of Viking, its affiliates or any related party receives any compensation in connection with these rebalancing transactions. Except as described below, these cross trades are made without brokerage commissions being charged. Viking’s policy is to avoid cross trades involving the VGE Employee Fund and to execute trades for the VGE Employee Fund in the public market whenever possible (and thus brokerage commissions are generally charged). If Viking determines to rebalance the Funds’ portfolios at the start of a given month in response to subscription and redemption activity, this will generally be accomplished by means of a journal entry with the applicable prime broker or swap counterparty on the first business day of the month, at the close-of-day prices from the last day of the prior month. Positions are

transferred amongst the Funds (other than the VGE Employee Fund) in this manner to reduce transaction costs. If the VGE Employee Fund is involved in a rebalancing of this kind, Viking will generally seek to execute the VGE Employee Fund’s portion of the rebalancing transaction in the public market on the first business day of the given month. If Viking determines at any time to rebalance a Fund’s portfolio to adjust its exposure levels, this will generally be accomplished by executing trades in the public market on the first business day following the day Viking determines to conduct such rebalance. If there is an offsetting portfolio manager order for another Fund (other than the VGE Employee Fund), these transactions will generally be executed as cross trades in the public market. If there is an offsetting portfolio manager order for the VGE Employee Fund, Viking will generally seek to execute such order in the public market following the execution of the rebalancing transactions for the other Funds. If trading is restricted in a security that would be part of a rebalancing, the position will be rebalanced as soon as practicable after the restriction is lifted. In addition, Viking may occasionally cause the Funds to enter into cross trades on equity swap positions other than as part of a rebalancing in order to correct for shifting allocations over time, usually when closing out a position. Principal Transactions. A principal transaction occurs when an investment adviser, acting for its own account (or the account of an affiliate), buys a security from, or sells a security to, a client’s account. Viking generally does not expect to cause the Funds to enter into principal transactions, but it is possible given the investment strategy and investor base of the Funds, in particular the Structured Capital Funds, that the Funds may enter into one or more principal transactions. If the Funds were to enter into any principal transactions, Viking would satisfy the requirements of Section 206(3) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to the extent required by law, which require an investment adviser to provide written disclosure to a client and obtain the client’s consent prior to settlement of any principal transaction. When calculating a Fund’s internal ownership percentages for this purpose, Viking is not required to include accrued, but unrealized, Incentive Allocation and Priority Profits Allocation amounts. Viking may also cause the Funds to engage in transactions that pose potential conflicts of interest similar to principal transactions. For example, Viking has previously caused a Fund to make an investment that involved providing a loan to a company that is controlled by another Fund. In this case, Viking elected to provide written disclosure to, and obtained the consent of, the lending Fund’s board of directors prior to consummating the transaction. Viking may take similar steps if and when it identifies similar potential conflicts in the future, although Viking does not undertake to do so in cases where it is not required by law or the Funds’ organizational documents. Additionally, Viking may cause a Fund to invest alongside another Fund in which Viking Affiliates hold more than 25% of the interests in circumstances where such Fund would not have been able to participate but for the Fund’s participation (e.g., due to investment size), or determine that the Fund will pass on an investment opportunity to which it has priority (e.g., a follow-on opportunity that Viking does not believe is appropriate for the Fund) and then allocate all or a portion of such opportunity to such Fund. From time to time, an investment by a Fund may be sold or otherwise disposed to another Fund. For example, a portfolio company of one Fund could evolve into a company with a lower risk and return profile and/or longer expected holding period targeted by another Fund, or a Fund may sell their post-IPO shares in a portfolio company to another Fund. In such cases, Viking could effect a purchase or sale of an investment between the Funds. Consent of the investors or an Independent Advisory Committee may not be required for such a transaction, even though such transactions involve conflicts of interest.

C. Investing in Securities That Viking or a Related Person Recommends to Clients. Viking’s Code of Ethics generally prohibits Viking individuals from investing in singlename, publicly traded stocks, or corporate bonds. Exceptions to this prohibition require preclearance by Viking. Nonetheless, there have been circumstances in which, for a variety of reasons, Viking individuals, including members of the investment staff, have acquired investments in securities and other assets in which the Funds were, or could have been, invested. Other such circumstances may arise in the future. Thus, there is a possibility that Viking individuals will benefit from market or investment activity by the Funds. Viking’s Code of Ethics requires each Viking individual to notify VGI’s Chief Compliance Officer if the individual is, or is considering, evaluating, or recommending, on behalf of the Funds: (a) securities of an issuer in which the individual has an existing personal investment; or (b) securities of an issuer that, to the individual’s knowledge, has a material business arrangement with an issuer in which the individual has an existing personal investment. However, there can be no assurance that Viking will be aware of all apparent or actual conflicts of interest involving an individual’s personal investments and the individual’s activities on behalf of the Funds. Viking has established policies and procedures to monitor, mitigate, and/or disclose conflicts with respect to investment opportunities in a manner it deems fair and equitable, including the restrictions placed on personal trading in the Code of Ethics, as described above, and regular monitoring of individual transactions. D. Conflicts of Interest Created by Contemporaneous Trading. Viking manages investments on behalf of six types of pooled investments funds: the VGE Funds, the VLF Funds, the Hybrid Funds, the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds. As further described in Item 8, the investment programs of the VGE Funds, the VLF Funds, the Hybrid Funds, the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds overlap and therefore, the Funds may participate with each other in investments. In addition, the Funds may co-invest alongside non-clients, including Viking personnel and/or certain Fund investors. Viking’s investment allocation and co-investment policies are detailed in Item 6. E. Other Conflicts of Interest. Expenses. When allocating expenses, Viking must first determine whether such expenses are a Fund’s “own” expenses and therefore are to be borne by such Fund (or a portfolio company) or whether such expenses are expenses of a portfolio company, another Fund, or Viking, to be borne by them, as applicable. Determining whether to engage a third party or an employee of Viking to provide certain services to the Funds gives rise to potential conflicts of interest since Viking typically bears the compensation costs of its employees who render such services, whereas amounts paid to third parties are typically a Fund expense borne by all partners. Viking therefore has an incentive to retain third parties rather than hire additional employees of Viking and to outsource to third-party service providers’ functions that employees of Viking could perform or have previously performed. Furthermore, Viking will be required to determine whether expenses of the Funds should be allocated pro rata to all investors or only to certain investors, and investors can be allocated a portion of certain expenses even if they did not directly benefit from the relevant expense. For instance, interest and expenses associated with borrowings by a Fund, including borrowings for Management Fees and investments, can be allocated pro rata to all investors even if the underlying use for the borrowing does not benefit all investors proportionately, for example, due to differing management fee terms and/or an investor’s excuse or exclusion from an investment. Expenses

relating to any potential illiquid investment that is not consummated (other than commitments for which the investors’ relative participation had already been determined by Viking) will generally be borne by all partners on a pro rata basis in accordance with their liquid capital account balances or capital commitments, as applicable, regardless of whether such partners would have participated in such illiquid investment. In certain situations, such determinations may be inherently subjective and, in some situations, may give rise to conflicts of interest, particularly to the extent Viking Affiliates have varying levels of investments in the Funds. Viking incurs some expenses on an aggregate basis for the benefit of multiple Funds and/or Viking. Viking allocates the aggregate costs of these items across the applicable Funds and Viking in a manner it determines to be fair and equitable in its sole discretion. Generally, the allocation method is pro rata in accordance with assets under management, capital commitments, or invested capital, as applicable. Viking is permitted to vary this approach in particular instances if it believes another method is more equitable, but it may not necessarily do so if it believes the allocation methodology will result in a fair and equitable allocation over time, even if a specific expense is allocated in a manner that does not best reflect the benefit received by the various parties. For instance, when allocating amounts (including firm-wide insurance) to Viking, Viking’s allocable portion may be based on a metric not identified above, such as a fixed percentage that Viking determines to be equitable. In addition, although some expenses are incurred on behalf of the Funds, they are likely to benefit Viking more broadly. For example, information Viking obtains in connection with the Funds’ research, due diligence, and investment activities will be valuable to Viking’s other funds and businesses. In addition, tools and resources developed at the Funds’ expense will be the intellectual property of Viking and not the Funds. If Viking licenses or sells such intellectual property to third parties in the future, the Funds will not benefit from such license or sale. Viking has an incentive to categorize costs, expenses, and other liabilities as Fund expenses rather than overhead expenses or liabilities of Viking. Investments in Different Parts of an Issuer’s Capital Structure. The Funds expect to make investments in the same portfolio companies and could acquire interests in different parts of the capital structure of a portfolio company (including different series of preferred equity or different tranches of debt or otherwise different seniority or priority than the investment by another Fund), or in different or successive financing rounds of a portfolio company. When multiple Funds hold investments in different levels of the capital structure and conflicts of interest arise between the holders of different types of investments as to what actions the relevant portfolio company should take, the ability of Viking to take actions in the best interests of a Fund might be impaired. Previously, a Fund made a debt investment in a company in which another Fund held an equity investment. A similar transaction in the future might require Viking to take certain actions for one Fund that could be adverse to the interests of another Fund (for instance, if the company underwent a reorganization or other major corporate event, conflicts could arise between debt holders and equity holders, and, accordingly, between the Funds). Likewise, the Funds may invest in different debt instruments or series of preferred equity of the company in question, giving rise to conflicts concerning their respective entitlements or priority in a bankruptcy proceeding or other transaction. Moreover, if a Fund holds separate investments in the same issuer, it may choose to make different investment decisions with respect to each such investment. Viking reserves the right to give advice and make investment recommendations to any Fund that differs from advice given to, or investment recommendations made to, any other Fund (including with respect to the timing of the purchase or sale of investments), even the investment objectives of such Funds are the same or similar. Viking could express inconsistent

views on commonly held investments or on market conditions more generally. Viking will seek to resolve such conflicts of interest in a fair and equitable manner. Such conflict resolution may, however, result in a worse outcome for a Fund than may have resulted in the absence of such a conflict. Ultimately, it is possible that the outcome for a Fund will be less favorable than might otherwise have been the case if Viking did not owe duties to other Funds. Such conflicts will be more difficult if multiple Funds hold significant or controlling interests in competing or different tranches of a company’s capital structure. For example, a Fund could acquire a significant equity stake in a company whose debt securities are already held by another Fund. As a creditor of the company, such other Fund could take actions, consistent with its obligations to maximize the return to its investors, that would be adverse to the interests of the Fund as a holder of more junior securities. Another Fund, for instance, could cause the acceleration of the company’s debt or exercise other rights it has that could precipitate a sharp decline in the company’s available capital and the value of the equity held by the Fund. Such other Fund would be under no obligation to take any action or refrain from taking any action to prevent or mitigate any losses by the Fund or take into account the Fund’s interests in advising its respective companies or otherwise managing their assets. The existence of such investments by other Funds may also create an incentive for Viking to concentrate in certain companies more than it would have in the absence of such investments by other Funds. The Funds have in the past acquired debt securities in a company in which another Fund holds an equity stake, and the Funds may again do so in the future. As a creditor of the company, the Funds could take actions, consistent with their obligations to maximize the return to their investors, that would be adverse to the interests of the other Fund as a holder of more junior securities. The Funds would be under no obligation to take any action or refrain from taking any action to prevent or mitigate any losses by the other Fund (and vice versa) or to take into account the other Fund’s interests in advising its respective portfolio companies or otherwise managing its assets (and vice versa). Moreover, from time to time, a Fund may also participate in releveraging and recapitalization transactions involving investments in which other Funds have invested or will invest. Similarly, a Fund may provide financing to a third party that is transacting with another Fund, including a third party that is acquiring or refinancing (directly or indirectly) a portfolio investment held by another Fund. Conversely, a Fund may provide financing to a third party or portfolio companies in circumstances in which another Fund is disposing of, refinancing, or otherwise being repaid in respect of, a portfolio investment. These transactions are likely to present conflicts of interest, including as to whether existing investors, which could include the Funds, are receiving value which is higher or lower than fair market value or are otherwise transacting on arm’s length terms. Where the Funds participate as existing investors in an investment that is undergoing these types of transactions, there is no guarantee that the Funds will participate as new investors in the same relative proportion as the initial investment or at all, which will depend, among other things, on the Funds’ investment objectives, strategies, and structure. With respect to companies in which a Fund holds equity investments, a Fund may hold, or seek to acquire, controlling or significant influence positions in such companies. Certain actions of a company that a Fund is in a position to control or influence may be in the interests of the Fund but adverse to other Funds. For example, a Fund could have an interest in pursuing an acquisition that would increase indebtedness, a divestiture of revenue-generating assets, or another transaction that, in the Fund’s judgment, could enhance the value of the Fund’s investment, but would subject the investment made by other Funds to additional or increased

risk. Likewise, to the extent a company in which a Fund invests experiences distress or becomes insolvent, Viking may have an incentive to cause other Funds to make an investment in such company that it would otherwise not make so as to avoid or mitigate the reputational harm associated with making a failed investment. A Fund is also likely to have the ability to determine (or significantly influence) the outcome of all matters requiring stockholder approval and to cause or prevent a change of control of such company, or a change in the composition of its board of directors and could, among other things, preclude any unsolicited acquisition of such company or the incurrence or repayment of indebtedness or other liabilities by such company. The interests of a Fund with respect to the management, investment decisions, or operations of a company may at times be in direct conflict with those of other Funds, which will not have the same level of control or influence over the company by virtue of its portfolio investment. Additional Viking Clients. Viking currently provides investment management services to the VGE Funds, the VLF Funds, the Opportunities Funds, and the Structured Capital Funds and, in the future, expects to provide investment management services to additional Funds, including other collective investment vehicles or separate accounts established primarily for third-party investors and/or Viking Affiliates. The Drawdown Funds and Vintage IV Funds generally pursue the same “illiquid” investment strategy as the Hybrid Funds and generally invest in parallel with the Hybrid Funds. New Viking Funds may or may not employ investment strategies that are similar to or overlapping with (or competing with) the investment strategies of the Funds, which could conflict with the activities and strategies of the Funds and affect the prices and availability of the securities and instruments in which the Funds invest. For example, although the Opportunities Funds are permitted to (and may) make illiquid credit or real property investments, credit and structured capital investments that would have been allocated to the Opportunities Funds will now more likely go to the Structured Capital Funds, which have priority allocation over certain credit and structured capital investment opportunities, although, in Viking’s sole discretion, the Opportunities Funds may still invest alongside the Structure Capital Funds. Furthermore, existing and future Funds may share personnel and resources with the Funds. Viking is not required to seek investor consent or grant investors withdrawal rights prior to the formation or engagement of any new Fund. In connection with the formation or engagement of any new Fund, Viking may utilize information regarding the portfolios and performance of the Funds or particular investment team members for evaluation, marketing, and/or other purposes. Investments by Multiple Funds. Given the breadth of Viking’s portfolio across platforms, a Fund may invest in a competitor or customer of, or service provider or supplier to, a portfolio company of a different Fund. This would give rise to a variety of conflicts of interest. For example, a Fund or its portfolio companies may take actions for commercial reasons that have adverse consequences for the other Fund or its portfolio companies, such as seeking to take market share from a portfolio company of the other Fund (as a competitor), withdrawing business from the other Fund’s portfolio company in favor of a competitor that offers the same product or service (as a customer), increasing prices (as a supplier), or commencing litigation against the other Fund’s portfolio company (in any capacity). Another Fund may also obtain information while dealing with its portfolio companies that it is prohibited from acting on or disclosing to the Funds or another portfolio company as a result of confidentiality requirements or applicable law, even though such action or disclosure would be in the Funds’ interests. In addition, to the extent not restricted by confidentiality requirements, Viking generally will apply the experience obtained by managing a Fund to benefit other Funds. The Funds are under no obligation to take into account another Fund’s interests in advising their portfolio companies or otherwise managing their assets.

Strategic Transactions. Viking could, for any reason, engage in strategic transactions, including the investment in, acquisition of, or combination with, other investment platforms, including other investment platforms that currently or may in the future sponsor, manage, or advise funds, vehicles, or accounts with investment mandates that are the same as, or similar to, that of the Funds. Nothing in the Fund partnership agreements prohibits or restricts such strategic transactions. For example, Viking is authorized to make investments for its own account to further grow and expand its business and/or engage in other strategic acquisitions or transactions. Viking is also permitted to acquire and hold other assets used in the development of its business, including seed capital for the purpose of developing, evaluating, and testing potential investment strategies, products, or new strategies. Viking may also make other opportunistic investments and utilize investment strategies that mirror, or are similar to, in whole or in part, investment strategies implemented by Viking on behalf of the Funds. Investments by Viking may be made in lieu of or alongside the Funds, and Viking is subject to conflicts of interest in determining that an investment opportunity is appropriate for Viking in priority to the Funds. Such strategic transactions and the continued operations of any such investment platform may result in the re-allocation of the time and attention of Viking personnel (either on a temporary or permanent basis), including to the detriment of the Funds, or the allocation of investment, sale, or other exit opportunities or liquidity options which otherwise would be allocated to or benefit the Funds to instead be allocated to or benefit any such funds, vehicles, or accounts and will otherwise give rise to the same conflicts of interest among the Funds. To the maximum extent not prohibited by applicable law (including the Advisers Act), Viking does not have any obligation to give any consideration to any interest of or factor affecting the Funds in connection with any such transaction (e.g., whether the Funds would otherwise be interested in pursuing such transaction or whether such transaction involves funds, vehicles, or accounts with investment mandates that are the same as, or similar to, that of the Funds), and Viking is permitted to consider only the interests and factors that it desires, including Viking’s own interests. Continuation Vehicles. A Fund could in the future seek to sell one or more portfolio companies to an investment vehicle established to purchase a portfolio company or companies and in which the investors of the Fund are given the opportunity to continue their investment in the relevant assets, in whole or in part (a “Continuation Vehicle”). A Continuation Vehicle could also involve participation by Viking proprietary entities, other Funds, and/or third parties, which would indirectly acquire the portion of the relevant assets relating to the interests of investors that do not seek to continue their participation in whole or in part. Depending on the elections made by the investors, the sale of an investment to a Continuation Vehicle will likely result in Viking and/or Viking Affiliates disposing of their investments in the underlying assets at a different time than some or all investors and otherwise taking actions with respect to such investment that are different than the actions taken by investors that do not make the same elections. As such, Viking and Viking Affiliates could ultimately receive a return on their share of the relevant investment that is higher than the return achieved by other investors in the Fund. In addition, Viking and/or Viking affiliates likely will be entitled to receive fees in connection with the consummation of the transaction and/or in connection with continuing to hold the relevant investment through the Continuation Vehicle. With the exception of portfolio fees, none of any such fees received by Viking will be shared with the Fund or will offset Management Fees or Incentive Allocation payable to Viking in respect of the Fund. Although the sale of a portfolio company to a Continuation Vehicle could in some cases constitute a transaction subject to Limited Partner Advisory Committee (or equivalent) consent, such transactions could be structured in a manner that does not constitute such a transaction (for example, if each investor receives an in-kind distribution of its share of the relevant asset and the opportunity to either contribute such asset to a Continuation Vehicle or sell its share of such

asset for cash). In the event that a Fund proposes to sell any assets to a Continuation Vehicle and that sale fails to close for any reason, the Fund would typically bear the broken-deal expenses relating to the proposed transaction, including fees for services that would only have accrued to the benefit of certain subsets of investors, such as investors electing to continue their participation, if the transaction had closed. Different Advice or Decisions. Viking gives advice to, and makes decisions for, certain Funds, which sometimes differs from advice given to, or decisions made for, other Funds. It is possible that the activities or strategies used for a Fund could conflict with the activities and strategies employed in managing the assets of such other Funds and affect the prices and availability of the securities and instruments in which such other Funds invest. A Fund, for example, may make (or continue to hold) an investment at the same time that one or more other Funds is disposing of the same or a similar investment (or vice versa). In addition, a Fund may make an investment after one or more other Funds has established a position in the same or a similar investment. The fact that a Fund holds a position in the same company or financial instrument as another Fund may impact such Fund’s exit opportunities or exit strategies with regard to its position. For example, if a Fund holds a large block of the same security as another Fund, Viking is permitted to cause the Fund to engage in a block sale of the security together with such other Fund, potentially at a discount or with incremental expense, even if such other Fund would have otherwise sold the security in the market in the normal course. Similarly, a Fund may dispose of an investment at a different time or in a different manner than another Fund, and such disposition may negatively affect the value of the asset held by such other Fund. For example, one Fund may sell an investment for cash while another Fund may distribute an investment in kind. Viking may also make different decisions with respect to each of a Fund’s investments in the same portfolio company. For example, a Fund may hold both a liquid investment and one or more illiquid investments in the same portfolio company. In these situations, different sets of investors in the Fund may have different levels of exposure to these investments. In this instance, a decision to sell only the liquid investment or any such illiquid investment may impact some investors in the Fund more than others. In addition, any such decision may impact the amount and timing of Incentive Allocation, Management Fees, and Priority Profits Allocation received by Viking, as well as the ability of investors to withdraw capital from the Fund. The decision of which investments to realize will be made on a case-by-case basis by Viking in its sole discretion, and Viking is under no obligation to seek to realize all investments in the same portfolio company concurrently or on a pari passu basis. In determining which investments to realize, Viking considers a variety of factors, including the holding periods and tax characteristics of the various investments, the type of securities available for sale (e.g., common or preferred shares and their economic features), and what Viking considers to be in the best interests of the Fund as a whole. Different portfolio managers often manage separate investments in the same company or financial instrument. Although portfolio managers are encouraged to share their views and research, they may act independently of one another. For example, one portfolio manager may take a long position in a company while another portfolio manager takes a short position in the same company. This could result in the Funds incurring expenses without receiving market exposure to either portfolio manager’s position, due to the offsetting positions of the other portfolio manager. As another example, if two portfolio managers are responsible for a portion of the same illiquid investment, and Viking identifies an exit opportunity for that investment, the exit opportunity generally will be made available to all portfolio managers responsible for managing any part of the investment. However, each portfolio manager need not act in the same manner. As a result, one portfolio manager may decide to dispose of his or her portion of

such investment, while another portfolio manager may continue to hold (or even acquire more of) the investment. In addition, different portfolio managers may choose to vote their shares in an issuer differently with respect to matters requiring shareholder consent, such as in voting whether to approve an acquisition offer for the issuer. Valuations Provided by Viking. The Management Fee, the Priority Profits Allocation, and the Incentive Allocation are calculated based on valuations ascribed to the Funds’ holdings by applying the valuation policy. In addition, Viking’s valuation of the Funds’ liquid and illiquid portfolios will impact the value of subscriptions and withdrawals of investors. The Management Fee, the Priority Profits Allocation, the Incentive Allocation, and the anticipated occurrence of subscriptions or withdrawals of internal and/or external capital may create an incentive for Viking to assign biased valuations to the Funds’ holdings. Similarly, to the extent a Fund has or is seeking Asset-Based Borrowing, Viking will have an incentive to apply higher valuations to such Fund’s holdings to obtain or maintain increased borrowings and/or to avoid breaches and defaults. In addition, when marketing certain Funds to potential investors, Viking will likely provide such potential investors with the Funds’ performance information in connection with their investment analysis and decision process, which may create an incentive for Viking to assign higher valuations to the Funds’ holdings and/or to make investments it might not otherwise choose to make. In addition, selecting a valuation methodology involves conflicts of interest because Viking might pick a method that results in a higher value than other methods would. This could impact the Management Fee, the Priority Profits Allocation, and the Incentive Allocation (as applicable) for a particular Fund. Additionally, Viking may change the valuation methodology for some investments while they are held by the Funds. There can be no assurance that a third party or investor would agree with one or more of the factors, assumptions, or inputs used by Viking in selecting a valuation methodology or in valuing an investment. Viking, in its sole discretion, may determine to amend the valuation policy as it deems appropriate to better reflect fair values. Any amendment to the valuation policy, for this reason or any other reason, may have a material effect on the valuations of assets of the Funds’ portfolios. All valuations of the Funds’ assets by Viking will be final and conclusive. Management Fee Calculations. The Management Fee is calculated as discussed in Item 5. With respect to the Vintage Funds and the Structured Capital Funds, invested capital counts the full cost basis of investments (including, for the avoidance of doubt, expenses attributable to such investments), even if Viking’s then-current valuation of an investment is significantly below cost (or continues to be so over multiple calculation dates), including having zero value, so long as Viking determines the investment is not likely to remain impaired permanently. As a result, a conflict of interest exists because Viking has an incentive to refrain from permanently writing off an investment to ensure investors continue paying Management Fees on such investment. Similarly, because the Management Fees and Priority Profits Allocation with respect to illiquid investments in the Hybrid Funds are calculated based on the lower of cost or fair value, Viking is incentivized not to mark an illiquid investment below its cost. Service Providers. Viking will select the Funds’ service providers. Service providers may provide services to both the Funds and one or more Viking individuals. While such arrangements have the potential to give rise to conflicts of interest, Viking will attempt to ensure that service provider selection for the Funds is not impacted from any provision of services to Viking personnel. Furthermore, Viking personnel may be related to, or a friend of, the Funds’ service providers or their respective owners, members, principals, officers, or employees. Viking addresses these conflicts of interest by taking reasonable measures to ascertain whether each service provider is qualified and appropriate to provide its services to

the Funds, taking into account factors such as expertise, availability, and quality of service and the competitiveness of compensation rates in comparison with other service providers satisfying Viking’s service provider selection criteria. In making these assessments, Viking may also consider whether a service provider or its affiliates provide prime brokerage services to the Funds, as these firms tend to consider all revenues derived from the Funds in assessing the overall profitability of their relationship with the Funds, which in turn may impact the pricing and availability of financing and other services provided to the Funds. Average Price Accounts. Viking may open “average price” accounts with brokers. In an “average price” account, contemporaneous purchase and sale orders placed on behalf of the Funds are combined, and securities bought and sold pursuant to such orders are allocated among such accounts on an average price basis, with transaction costs being shared pro rata based on participation in the transaction. Subsequent orders for such securities that are placed on behalf of the Funds during such trading day are combined with any prior orders to the extent such prior orders have not been executed, and securities bought and sold pursuant to all such orders are allocated among such accounts on an average price basis. When Viking encounters limited investment opportunities that are appropriate for multiple Funds or when an aggregated order is only partially filled, then Viking generally allocates the filled portion of the order pro rata in proportion to the size of the order placed for each of the Funds (as applicable). Other Activities of Viking. The success of the Funds will depend on Viking’s investment professionals’ and other Viking personnel’s ability to, among other things, source, underwrite, structure, complete, finance, and manage investments; improve the operations, governance, and performance of the companies and assets acquired by the Funds; and acquire and exit investments at the appropriate time and at attractive valuations. Viking and its members, shareholders, partners, officers, and employees devote as much of their time to the activities of the Funds as Viking deems necessary and appropriate. The foregoing, however, also spend time assisting other Funds with their investment activities or working on other projects, including on matters related to Viking as a firm. By the terms of the Funds’ partnership agreements, Viking and its affiliates are not restricted from forming additional investment funds, from entering into other investment advisory relationships, or from engaging in other business activities, even though such activities may be in competition with the Funds and/or may involve substantial time and resources of Viking. These activities will reduce the amount of time such persons have to dedicate to the Funds and could also be viewed as creating a conflict of interest in that the time and effort of the partners or members of Viking and its officers and employees are not devoted exclusively to the business of the Funds, but are allocated between the business of the Funds and other business activities of Viking and its affiliates. For example, the Head of Private Investments manages Viking’s private equity and credit and structured capital strategies. In this capacity, he is principally responsible for overseeing the investment process for both the Opportunities Funds and the Structured Capital Funds. In addition, members of the investment staff supporting the Head of Private Investments are similarly responsible for sourcing, structuring, conducting diligence, and negotiating investment opportunities for both the Opportunities Funds and the Structured Capital Funds. This not only creates conflicts of interest regarding the allocation of such personnel’s time, but is likely to exacerbate other conflicts of interest, including those described herein, such as in situations where the Structured Capital Funds pursue credit and structured capital investments in companies in which the Opportunities Funds hold, or will hold, an equity interest. In such situations, Viking strives to manage such conflicts so as to achieve a fair and equitable result for each Fund, including by engaging with Viking’s Conflicts Committee or, if Viking deems

necessary or appropriate, by consulting with an Independent Advisory Committee and/or a Limited Partner Advisory Committee. In addition, employees of Viking may have personal relationships (whether immediate family members or otherwise) engaged in business activities that would either benefit from, or compete with, the activities of Viking and/or the Funds. Any such employees could be viewed as having a conflict of interest as they may take into account the potential impact on persons with whom they have personal relationships when making decisions that could affect such persons. Master-Feeder Structure. The use of a “master-feeder” structure by certain Funds also presents certain conflicts of interest. For example, different tax considerations applicable to a Fund’s onshore feeder fund, on the one hand, and its offshore feeder fund or intermediate fund, on the other hand, may result in such Fund’s master fund structuring or disposing of an investment in a manner or at a time that is more advantageous (or disadvantageous) for tax purposes to such Fund and its investors. In addition, notwithstanding the “master-feeder” structure, for tax, regulatory, or other reasons, Viking sometimes causes a Fund’s onshore feeder fund and its offshore feeder fund to make investments directly, and other times causes them to invest through special purpose vehicles. Viking may also cause investments to be made exclusively by either a Fund’s offshore feeder fund (through its intermediate fund) or its onshore feeder fund. Arrangements with Portfolio Companies. Viking and the Funds have in the past entered, and may in the future enter, into commercial or financing arrangements with portfolio companies of the Funds. Such arrangements from time to time will involve the payment and receipt of fees, expenses and other compensation or benefits. For example, on an arm’s length basis, Viking pays for and utilizes the software technology of a portfolio company of the Opportunities Funds. Viking has in the past caused the Opportunities Funds, and may in the future cause the Funds, to enter into arrangements with one of the Opportunities Funds’ portfolio companies and certain other investors to facilitate investments by the Funds (together with the Opportunities Funds and such other investors) in newly formed subsidiaries or joint ventures sponsored by the portfolio company, which newly formed entities may have strategic or commercial arrangements with the sponsoring portfolio company. Such arrangements may give, and at times have given, rise to conflicts of interest between Viking and the Funds or between different sets of investors within a Fund, particularly with respect to the valuation of such investments and related products and services. Although Viking strives to manage such conflicts, and often the terms of such arrangements may be considered arm’s length, there can be no assurance that Viking will be successful in resolving such conflicts in a fair and equitable manner. In addition, the Opportunities Funds have made an investment in a portfolio company that operates as an investment adviser and broker-dealer, and Viking has used the services of this portfolio company to identify prospective investors in the Funds. This portfolio company or one of its affiliates may also source co-investors or market interests in the Funds and has acted as a placement agent for a Fund in the past. Finally, from time to time, Viking has also introduced representatives from the Funds’ portfolio companies to one another for the purpose of promoting business opportunities between such portfolio companies, and expects to do the same for the Funds. These arrangements, and any associated revenues, fees, or other compensation, create conflicts of interest. When the Funds or portfolio companies of the Funds are responsible for a particular payment, these fees and expenses will generally be borne by the investors either directly or indirectly, and in the case of a portfolio company, generally only by investors

invested in that portfolio company. Any compensation received by Viking or a Fund under these arrangements, if any, will not offset or reduce Management Fees. If Viking or a Fund receives compensation for the relevant services, it seeks to do so at levels that Viking reasonably believes are arm’s length market terms at the time of entering into the engagement. However, there can be no assurances that amounts charged by the portfolio company (whether to Viking, a Fund, or another portfolio company) will be consistent with market rates or that any benchmarking, verification, or other analysis will be performed with respect to such charges. This is the case even in situations where Viking or a Fund has control over the portfolio company or has other “protective” rights such as negative control rights, board representation, or other reporting and consultation rights that afford Viking the ability to influence the portfolio company. Viking receiving compensation and other benefits from such arrangements may create an incentive to retain its interest in the relevant portfolio company longer than it otherwise would in the absence of such arrangements. Moreover, these arrangements generally do not require the review or consent of an Independent Advisory Committee, a Limited Partner Advisory Committee, or the investors more generally. Even if such arrangements would stand to benefit the Funds overall, they may benefit one set of investors to the detriment of another. Additional Conflicts. Investors in the Funds should understand that (a) the relationships among the Funds, Viking, and their respective affiliates are complex and dynamic and (b) as Viking’s and the Funds’ businesses change over time, Viking and its affiliates may be subject, and the Funds may be exposed, to new or additional conflicts of interest, including as related to the establishment of other Funds. There can be no assurance, and indeed it is unlikely, that this Brochure addresses or anticipates every possible current or future conflict of interest that will arise or that is or could be detrimental to the Funds or their investors. Investors should be aware that it is impossible to predict the full range of situations in which actual or potential conflicts of interest could arise among the Funds and Viking. Accordingly, this discussion cannot be, and is not intended to be, exhaustive.

Access to underwritten offerings, private investment opportunities, and secondary market liquidity;

Reliability and strength of salespeople;

Commissions, mark-ups, mark-downs, or spreads;

Ability to manage market impact and trading costs;

Value of brokerage or research services;

Provision or payment (or rebate to Viking for payment) of costs of brokerage or research products or services;

Willingness to correct mistakes;

Size and volume of the broker’s order flow;

Responsiveness of the broker-dealer;

Accommodation of special needs;

Frequency and amount of price improvement;

Stability of borrow and financing access and costs;

Ability to generate and maintain balance sheet efficiency; and

Robustness of operational process.

1. Research and Other Soft Dollar Benefits. In connection with a portion of its trading, Viking agrees on behalf of its Funds to pay brokerage commission rates that are more costly than “execution only” rates. In doing so, Viking pays commissions, in part, to obtain research and other products and services to be used for the benefit of Viking and/or its other Funds, a practice referred to as “soft dollar”

expenditure. Viking has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services (whether for Viking’s own benefit or for the benefit of its other Funds) rather than the interest of the applicable Fund in receiving most favorable execution. Broker-dealers may provide research or other products or services in exchange for such “soft dollar” expenditure that are beneficial to Viking and/or certain Funds, but not necessarily beneficial to all Funds. Viking may also engage in “soft dollars” arrangements through “commission sharing,” which is a practice whereby Viking pays a broker-dealer for trade execution and requests that the broker-dealer allocate a portion of the commissions to third-party providers of research or other products or services. Viking endeavors to use soft dollars to pay for eligible research or brokerage products or services to the extent such products or services fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Under Section 28(e), eligible research or brokerage products or services obtained with soft dollars generated by one Fund may be used by Viking to service other Funds. Section 28(e) does not provide a “safe harbor” with respect to transactions effected on a principal basis (with the exception of certain riskless principal transactions), or transactions effected in futures, currencies, or certain derivative instruments. Where a product or service obtained with “soft dollars” is “mixed-use” to Viking, Viking will make a reasonable allocation of the cost which may be paid for with “soft dollars.” Viking seeks to ensure that its use of soft dollars results in a fair and equitable allocation among its Funds over time. However, the amount of soft dollars generated by a Fund may not necessarily be commensurate with the benefits derived by such Fund. Moreover, Viking and one or more Funds are expected to derive substantial direct or indirect benefit from these services, particularly to the extent Viking uses soft dollars to pay for expenses which it would otherwise be required to pay, or a Fund does not generate “soft dollars” during a period through its own activities. The investment information and soft dollar benefits received from brokers may be used by Viking in servicing Funds, and not all such information and soft dollar benefits may be used by Viking in connection with a particular Fund, including research and brokerage services obtained by the use of commissions arising from a Fund’s investments. Accordingly, a Fund will not necessarily, in any particular instance, be the sole direct or indirect beneficiary of the research or brokerage services provided. Likewise, Funds may receive benefits from the use of commissions arising from other Funds’ investments without compensation or other benefit to the other Fund whose information is being used. This practice gives rise to conflict of interest in allocating brokerage business and benefits received from such allocation, including an incentive to cause the Funds to effect more transactions than they might otherwise do to obtain those benefits. Research products or services provided to Viking may include data services (such as those providing stock quotes, last sales price, and trading volumes), research reports on particular industries and companies, alternative data (i.e., “big data”), economic surveys and analyses, recommendations as to specific securities, and other products and services related to investment decision-making. Brokerage services provided to Viking must be sufficiently related to the execution, clearing, and settlement of securities transactions effected on behalf of Viking’s Funds to satisfy the SEC’s temporal standard for brokerage. As a general matter, direct connectivity services between an adviser and an executing broker will satisfy this temporal standard, but any products or services provided by an executing broker that are part of an adviser’s overhead, including administrative and marketing expenses, would not satisfy this standard. Even if Viking determines an expense is not eligible to be paid with soft dollars, such expense may be allocated to the Funds to the extent otherwise permitted under the Funds’ organizational documents.

With respect to Viking Europe, the rules of the UK Financial Conduct Authority (“FCA”) require charges for third-party investment research and related products and services provided by executing brokers to be identified and paid for separately from execution costs. In order to comply with the FCA rules, Viking Europe pays for research and related products and services it consumes using a research payment account or one or more other methods permitted under FCA rules, such as under a commission sharing arrangement. In general, these research expenses represent operating expenses of the Funds. Investment personnel evaluate Viking’s broker-dealers that provide research products or services through a “broker vote” twice a year. The “broker vote” is a qualitative and quantitative assessment of the value of research services the broker-dealers provide and determines amounts paid for this research. In addition, there are other providers of research or brokerage services payable with soft dollars who are paid amounts that are agreed upon prior to the provision of services. 2. Brokerage for Client Referrals. Neither Viking nor any related person receives client referrals from any broker-dealer or third party. However, from time to time, brokers may assist the Funds in raising additional funds from investors, and representatives of Viking may speak at conferences and programs sponsored by such brokers for prospective investors. Through such “capital introduction” events, prospective investors have the opportunity to meet with representatives of Viking. Neither Viking nor the Funds compensate any broker for organizing such events or for any investments ultimately made by prospective investors attending such events. The Funds may accept subscriptions from investors who also provide services to the Funds, including brokers and their affiliates. Relationships such as these could be viewed as creating a conflict of interest that potentially could affect Viking’s ability to seek best execution. Viking conducts periodic best execution reviews in an effort to identify and mitigate compliance risks associated with brokerage relationships, and to determine that Viking is obtaining best execution for the Funds. 3. Directed Brokerage. Viking does not recommend, request, or require that a client direct Viking to execute transactions through a specified broker-dealer. Further, Viking does not permit any client to direct brokerage. B. Order Aggregation. Viking generally executes transactions on an aggregated basis in light of the fact that the VGE Funds generally trade pari passu. To the extent the VLF Funds, Opportunities Funds, or the Structured Capital Funds purchase or sell the same position as the VGE Funds, Viking executes orders for the Funds concurrently. Each Fund participates in an aggregated order at the average price of the execution and shares the transaction costs pro rata based on its participation in the transaction. When Viking encounters limited investment opportunities that are appropriate for more than one Fund or when an aggregated order is only partially filled, then Viking generally allocates the filled portion of the order pro rata in proportion to the size of the order placed for each Fund. Viking generally combines subsequent orders placed during the same trading day with orders that have not yet been executed or completed. C. Trade Errors. Absent fraud, wilful misconduct, or gross negligence, the Funds generally will bear losses resulting from trade errors, human errors, or other similar errors. Viking has a conflict of interest in determining whether losses resulting from an error will be borne by the Funds, since any losses not borne by the Funds will be borne by Viking.

The Chief Executive Officer/Risk Manager is responsible for determining capital allocation, setting applicable risk limits, and monitoring and managing aggregate portfolio risks, including increasing or decreasing liquid portfolio risk with respect to specific positions or portfolios. Private investments generally must be approved by an investment committee comprising the Chief Executive Officer, the Head of Private Investments, and one or more other investment team members. VGI’s Chief Executive Officer may delegate approval authority for investments to others within certain constraints and conditions, as VGI’s Chief Executive Officer deems appropriate. The investment staff structure, personnel, roles, responsibilities, and coverage areas may change from time to time. B. Factors Prompting Review of Client Accounts Other than a Periodic Review. A review of a client account may be triggered by any unusual activity or special circumstances. C. Content and Frequency of Account Reports to Clients. All investors in the Funds currently receive quarterly investor letters and an annual report including audited financial statements with a report thereon by the independent auditors. Depending on the specific Fund in which they are invested, investors also receive additional periodic reporting. Investors in Funds that are treated as partnerships for U.S. federal income tax purposes receive annual Schedule K-1s, and tax estimates are made available once a year.

VGI is not required to comply with, or is deemed to have complied with, certain requirements of the Custody Rule with respect to each Fund because it relies on the so-called “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that each such Fund be subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and that each such Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year.

In order to facilitate the proxy voting process with respect to publicly traded issuers, Viking has retained an independent proxy voting service (the “Proxy Service”) to provide recommendations and manage the process of voting proxies in a timely manner for the Funds. For publicly-listed securities, the relevant investment team member(s) receive the Proxy Service Benchmark recommendation, Proxy Service Global Board-Aligned recommendation, and Proxy Service Sustainability recommendation, along with the relevant issuer’s feedback and recommendation. The relevant investment team member(s) are responsible for reviewing the recommendations and ensuring that each vote is cast in the best interests of the Funds. Viking operations-side professionals generally further engage with the investment team in instances where the Proxy Service Benchmark, Global Board-Aligned, and/or Sustainability recommendations do not align. Viking investment team member(s) maintain the responsibility to cast each vote in the best interests of the applicable Fund(s). For operational ease, within the Proxy Service’s system, votes are “preset” to the Proxy Service Benchmark recommendation, and Viking effects an “override” when deviating from the Proxy Service Benchmark recommendation. The investment team member(s) will override any Proxy Service Benchmark recommendation (including, where appropriate, by abstaining from voting) that, in the investment team member’s discretion, is determined not to be in the best interests of the Funds. In order to effect an override, the investment team member(s) must document in advance in writing to VGI’s Chief Compliance Officer the analysis supporting the override and must certify to VGI’s Chief Compliance Officer that the investment team member is aware of nothing that would suggest the existence of an actual or potential conflict of interest. The investment team member(s) responsible for the position also must make such a certification regarding actual or potential conflicts of interest. For private securities, Viking manages the process without use of the Proxy Service. The relevant investment team member(s) will review each vote and reach a determination whether and how to vote in the best interests of the Fund(s), and also will certify that the investment team member(s) is (or are) not aware of anything that would suggest the existence of an actual or potential conflict of interest. If an investment team member seeks to override an individual recommendation by the Proxy Service where voting a proxy this way may also benefit, or be perceived to benefit, the investment team’s or VGI’s own interest, then (a) the voting decision for such proxy proposal may be delegated to an independent third-party or an independent committee of partners, members, shareholders, directors, or other representatives of the Funds, as applicable; (b) the investors in the investing Funds may be informed of the conflict of interest and provide majority consent to vote the proxy as recommended by VGI; or (c) approval of the decision must be obtained from VGI’s Chief Compliance Officer or designee.

The Proxy Service discloses to Viking information regarding its conflicts of interest. Such a conflict may arise, for example, if the Proxy Service or one of its affiliates receives compensation from the issuer for providing advice on corporate governance issues. If Viking determines that the Proxy Service is not sufficiently independent with respect to any proxy, Viking will engage another independent proxy service to provide voting recommendations for such proxy. If Viking is unable to identify an independent proxy service for such proxy (or determines that such a substitute would be impractical), Viking will vote such proxy according to investment team members’ recommendations, provided that, in advance, such investment team members document their reasons in writing and certify their lack of awareness of an actual or potential conflict of interest. Viking also conducts periodic due diligence to confirm that the Proxy Service has the expertise, staffing, and technology needed to analyze proxy voting matters and support Viking’s fiduciary duties. This review includes the Proxy Service’s policies, methodologies, use of information sources, issuer engagement, conflict management, data accuracy procedures, responsiveness to identified deficiencies, and communication of business or methodology changes. Investors in the Funds may not direct Viking’s vote on any proxy solicitation. Clients and prospective clients may request information about specific proxy votes or a copy of Viking’s proxy voting policies and procedures by contacting Viking Investor Relations department at (212) 672-7000 or inquiries@vikingglobal.com.