Lighthouse Investment Partners, LLC: investment adviser

Ownership Lighthouse is an indirect wholly owned subsidiary of Navigator Global Investments Limited (ASX:NGI), a publicly traded Australian Securities Exchange listed company. NGI owns Lighthouse through intermediate holding companies. Blue Owl Capital, Inc. (NYSE:OWL), a publicly traded New York Stock Exchange listed company, indirectly controls approximately 37% of NGI’s voting securities. A detailed description of Lighthouse’s ownership is provided in Schedule A and Schedule B of Form ADV Part 1A.

What We Do

We organize and manage investment strategies through privately offered funds, including single-manager and multi‑portfolio manager strategies. In most cases, we allocate capital among internal portfolio managers (our employees) and third‑party portfolio managers under contracts that set investment guidelines and risk limits. We oversee risk, set mandates, and may add or remove portfolio managers.

Business Lines

Platform Hedge Funds – Proprietary, single manager or multi‑manager strategies we operate through Lighthouse and our Relying Advisers.

Hedge Fund Solutions – Multi‑manager solutions that allocate to our Platform Hedge Funds and to external managers.

Platform Services – Global investment support offerings for institutional investors and certain Funds. These services include risk management and analysis, data processing, and assistance with direct hedge fund and long-only investments, along with related reporting and operational support. Lighthouse may also provide Platform Services for investments not held through its managed Funds in the future.

Types of Clients and Vehicles Our clients are primarily private funds organized in the United States and outside the United States (“Funds”). Some Funds are structured for multiple investors; others are customized for a single investor or a related group of investors (a “Custom Fund”). Funds may invest through master-feeder structures or through "Fund Accounts.” A Fund Account is the portfolio within a Fund that is managed by one or more Portfolio Managers. Where more than one Portfolio Manager manages a Fund Account, it is divided into ”Sub-Accounts,” with each Portfolio Manager generally exercising discretion over its own Sub-Account. Investors do not invest in a Fund Account directly; they invest in the Fund that holds it. Some Funds that hold Fund Accounts accept only other Lighthouse Funds as investors and operate as internal allocation vehicles. Others also accept investment from outside investors. In either case, Lighthouse's client is the Fund, not the Fund Account or the Portfolio Managers who manage it. Lighthouse's marketing and investor materials commonly refer to Fund Accounts as “managed accounts” and to the Funds that hold them as the “managed account platform.” Depending on strategy, regulatory requirements, or mandate, certain Funds may invest a substantial portion of assets in unaffiliated funds managed by third‑party portfolio managers (“Unaffiliated Funds”). We also manage customized portfolios for certain investors

4|P a g e

through SMAs held with independent custodians. For ease of reference, unless otherwise indicated or the context otherwise requires, references to “Funds” in this Brochure include SMAs.

Fund Level Terms and Classes Within Funds

Our Funds vary by investment objectives and guidelines, liquidity (including redemption rights), minimum investment amounts, and other fund‑level terms. Many Funds issue multiple series or share classes that differ by fees, base currency, or hedging/portfolio exposure. Some Funds also offer series or classes that correspond to distinct portfolios; in some cases, a class holds a customized portfolio for a single investor or a related investor group (for example, where investors are advised by the same consultant or wealth manager). See the Cross‑Class and Cross‑Fund Liability Risk factor in Item 8 of this Brochure for additional information.

Our Role and Legal Structures

We typically serve as an investment manager, manager, general partner, or in a similar capacity to our Funds. For Fund Accounts, we typically enter into an investment advisory agreement (also referred to as a “Subadvisory Agreement”) with a portfolio manager for each legal structure or segregated cell within a structure that limits liability among its cells (for example, Cayman Islands segregated portfolio companies, Ireland unit trusts, Delaware series limited liability companies, and Irish Collective Asset‑management Vehicles). For purposes of this Brochure, the term ‘Subadvisory Agreement’ also includes any employment agreement, compliance requirement, or other governing arrangement that establishes the portfolio manager’s discretionary authority and applicable investment restrictions. In some cases, a single fund structure or segregated cell is further divided into separate accounts (or Sub‑Accounts), each managed by a different portfolio manager. See the Fund Legal Structures Untested risk factor in Item 8 of this Brochure for additional information.

Co‑Advisory and Limited‑Scope Advisory Relationships

We may serve as a co‑investment adviser, co‑manager, or provide limited‑scope advisory services (such as platform services) for certain private funds. In these arrangements, we may share responsibility for investment decisions and portfolio management or provide advisory input without full discretionary authority. These relationships can create conflicts of interest in allocating investment opportunities and resources. See Item 10 for additional information regarding co-advisory relationships and related risks.

Fund Objectives and Customization

Most Funds are designed for multiple investors, and we set each Fund’s investment objectives and guidelines. Custom Funds are tailored for a single investor or a related group of investors (for example, where investors are advised by the same consultant or wealth manager). A Fund’s investment objectives—and any applicable investment limitations, restrictions, or guidelines—are described in its governing and offering documents (e.g., private placement memorandum, partnership or limited liability company agreement, subscription documents, investor side letters, or similar constitutional documents). Investment guidelines for Fund Accounts are generally established in the applicable Subadvisory Agreement between Lighthouse and the portfolio manager.

Portfolio Managers In this Brochure, “Portfolio Manager” means a group, typically comprised of one to five individuals but sometimes many more, operating as a single team to manage a Fund’s or Fund Account’s assets or a portion thereof. A Portfolio Manager team may include portfolio managers, traders, analysts, risk and research personnel, technologists, data scientists, information technology staff, operations and accounting staff, and other professionals. Teams may consist of:

employees of Lighthouse or its affiliates,

independent third‑party managers engaged under Subadvisory agreements,

independent third‑party managers whose vehicles our Funds invest in directly; or 5|P a g e

individuals seconded to Lighthouse under contract.

Third-party Portfolio Managers operate their trading groups and are responsible for trading decisions, staffing, and day‑to‑day operations, subject to our risk management, investment guidelines, and oversight. We retain authority to approve mandates, set risk limits, and terminate or reassign trading authority for the Funds and Fund Accounts they manage. We may also provide certain administrative and operational support to third-party Portfolio Managers. Certain third-party Portfolio Managers also manage capital for unaffiliated clients. Portfolio Managers who are Lighthouse employees are subject to Lighthouse’s supervision and control.

Regulatory Status of Funds

All private funds we manage are exempt from registration as investment companies in reliance on Section 3(c)(7) of the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”).

Assets Under Management (“AUM”) As of June 30, 2026, Lighthouse’s total AUM was approximately $19.8 billion. Approximately $14.1 billion were discretionary assets. Approximately $5.7 billion were non-discretionary assets, based on certain investment restrictions imposed in relation to certain Funds. See Item 16 of this Brochure for further information on how “discretionary” and “non-discretionary” AUM are determined.

Wrap Fee Programs We do not participate in any wrap fee programs.

The Performance Fee is typically subject to a loss carryforward or “high water mark” and, if applicable, a “hurdle rate” as set forth in the offering documents or constitutional document of our Funds. Certain share classes within the Funds place additional limitations on the calculation or payment of the Performance Fee related to such share classes, series of interests, and/or Funds. If an investor in a Fund that is subject to a Performance Fee redeems all or part of its shares or interests in the fund other than as of the date that a Performance Fee is calculated, a Performance Fee is paid with respect to the redeemed amount at the time of redemption. We may waive, reduce, or rebate the Management Fee or Performance Fee with respect to any investor, either in whole, or in part. In addition, we may enter into side letters with certain investors granting them preferential fee terms. Our determination to offer lower fees may be based on the relevant investor’s investment size or the aggregation of accounts for investors sourced from a certain investment advisor, consultant, or other third party, although we also may consider other factors. Employees who are permitted to invest in our Funds are not subject to a Management Fee or Performance Fee. In certain circumstances, we invest directly in Funds that hold Fund Accounts and will not bear the costs and expenses of other Funds. Where we engage third parties to assist in the placement of interests or shares in our Funds, we pay part, or all, of our Management Fees and/or Performance Fees to such third parties.

6|P a g e

Fees for Platform Services (“Platform Services Fees”) are independently negotiated based on the type of service and size of the relationship. Platform Services Fees typically constitute a percentage of notional asset value of a Fund and will be paid in arrears, either monthly or quarterly. Generally, the administrator of the Funds calculates the Management Fee, Performance Fee, and Platform Services Fee and communicates the net asset value and fee calculation to us. We confirm the calculations, and then the administrator directs the bank of the applicable Fund to make payment to us. Fees are customarily deducted from investors’ assets. In certain limited circumstances, an investor may pay fees to Lighthouse in a manner outside those described above whereby Lighthouse submits a bill to the client and such client pays Lighthouse directly rather than having the fees deducted from their assets. In addition to the Management Fees, Performance Fees, or Platform Services Fees deducted from an investor’s assets, each investor also pays a portion of the ongoing investment and operating expenses of such Fund, most commonly on a pro rata basis. Such expenses include, without limitation, administrator fees; professional fees relating to investments; liability insurance premiums; legal and regulatory expenses; tax-related expenses; audit and accounting expenses; research; and software and technology expenses. All these are described more fully in the applicable offering document or relevant constitutional document of our Funds. Investors in our Funds also bear, directly or indirectly, the management, performance-based, advisory, sponsorship, administrative and other fees and expenses charged by Portfolio Managers and by Unaffiliated Funds and other investment vehicles in which our Funds invest. These fees and expenses are in addition to the fees payable to Lighthouse, are payable irrespective of a Fund's profitability and may be substantial even during losing periods. Because a Portfolio Manager's performance-based compensation is generally calculated on that Portfolio Manager's own results, a Fund may pay performance-based compensation to one or more Portfolio Managers in a period in which the Fund as a whole has not realized a profit. The expenses borne by our Funds vary based on the applicable Fund's governing documents. Certain Funds employ a broad pass-through expense model (“Pass-Through Funds”), under which a range of investment-related, operational, administrative and other expenses may be borne by the Fund as described below. Other Funds permit only certain categories of expenses to be borne by the Fund. For these Funds, expenses that are not permitted under the applicable governing documents are borne by Lighthouse rather than reallocated to other Funds. The particular expenses borne by each Fund are governed by its applicable offering and constitutional documents. Pass-Through Funds incur various expenses in connection with or otherwise related to the operations and activities at various levels of (i) the Pass-Through Fund, (ii) Lighthouse or one of its subsidiaries that manages such Pass-Through Fund (“Pass-Through Fund Manager”), (iii) a co-investment adviser, where applicable, and (iv) Portfolio Managers (collectively, “Pass-Through Expenses”). Each Fund that invests in a Pass-Through Fund will also be responsible for its share of such expenses. In addition, Lighthouse may elect and has elected in the past not to pass through certain expenses that otherwise could be borne by investors. Any such determination is made in Lighthouse’s sole discretion. Pass-Through Expenses include, but are not limited to:

Investment-Related Expenses. Investment expenses (e.g., expenses that the Pass-Through Fund Manager determines to be related to the investment of the Pass-Through Fund’s assets, such as brokerage commissions, expenses relating to short sales, financing charges, dividend expense, exchange fees, clearing and settlement charges, custodial fees, bank service fees, and interest and financing expenses); currency hedging expenses; costs associated with establishing and maintaining exchange memberships; legal expenses and professional fees (including, without limitation, expenses of third-party consultants, compliance consultants, expert networks, risk service providers, and portfolio finance and treasury service providers); proxy voting services, class action recovery and monitoring or tax reclamation service providers; valuation expenses, including the cost of valuation agents; performance-based compensation of Portfolio Managers (if any); asset-based compensation 7|P a g e

of Portfolio Managers (if applicable); and management fees, performance fees, and other costs and expenses payable in respect to any investment by the Pass-Through Fund in another investment vehicle (whether affiliated with Lighthouse or not).

Organizational and Operating Expenses. Administrator fees, administrative expenses, legal expenses, auditing and tax preparation expenses (including in connection with tax returns, tax estimates, Schedule K-1s, Schedule K-3s or similar forms or other communications with investors), expenses for tax or accounting services performed by any third parties; costs of preparing, printing, and mailing reports and notices, including customized reporting requested by investors; bonding costs required by Employee Retirement Income Security Act of 1974, as amended (“ERISA”), if applicable; taxes, including withholding tax, and similar amounts and other related interest, penalties, or other expenses; “Fund representative” fees and expenses; corporate licensing; costs of effecting and maintaining registrations and licenses in U.S. and non-U.S. jurisdictions; costs and expenses related to regulatory reporting of whatever nature and in whatever jurisdiction (including the costs and expenses incurred in the preparation and filing of Form ADV, Form PF, Form CPO-PQR, Schedules 13D, 13G, 13H, Form SHO, Form N-PX, blue sky filings, and other Fund-specific regulatory filings and Fund-specific costs and expenses related to AIFMD and other jurisdiction-specific filings); the fees and expenses of the Pass-Through Fund’s board of directors; advisory committee fees; the fees and expenses of the Fund’s anti-money laundering officers; the fees and expenses of the paying agent (if any); organizational expenses; costs and expenses incurred in connection with establishing and maintaining entities through which the Funds will conduct their investment activities; publicrelations consultants; expenses incurred in connection with the offering and sale of interests in the Funds (including the preparation and revision of disclosure documents and other constitutional documents, marketing materials, due diligence questionnaires, subscription agreements, negotiation and administration of side letters, negotiation and documentation of agreements with placement agents or marketers and travel expenses to meet prospective and existing investors and to attend industry events and conferences such as capital introduction events (including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses)); the cost of the Pass-Through Fund Manager’s and the Pass-Through Fund’s liability insurance premiums (including, without limitation, costs related to Errors & Omissions, Directors & Officers, commercial property insurance, employment practices liability insurance, cyber insurance, and general liability insurance, including those for the Portfolio Managers, the board of the directors of the Pass-Through Fund, and Investment Adviser Personnel); expenses related to the maintenance of the Pass-Through Fund’s registered office or future offices and other similar expenses; fees and expenses related to the Pass-Through Fund’s wind down and liquidation; costs and expenses associated with litigation and arbitration; costs of indemnification or contribution pursuant to a Fund’s constitutional document, any agreement with a Portfolio Manager or a service provider to the Funds or other agreements; and extraordinary expenses. “Investment Adviser Personnel” means the principals, members, officers, employees and consultants of the Pass-Through Fund Manager and the principals, members, officers, employees and consultants of its affiliates who devote any portion of their time to any aspect of the operation (including legal, compliance, accounting, operations, human resources, marketing, investor relations and reporting, tax, risk management, portfolio management or trade execution) of a Pass-Through Fund on behalf of the Pass-Through Fund Manager, as well as certain other personnel of the Pass-Through Fund Manager and its affiliates that the Pass-Through Fund Manager has designated as performing Corporate Service Functions on behalf of the Pass-Through Fund Manager and its affiliates. “Corporate Service Functions” include functions such as legal, compliance, finance, accounting, operations, tax and similar corporate services. The costs and expenses associated with Investment Adviser Personnel (including those performing Corporate Service Functions) will be charged to the Pass-Through Funds as a Fund Expense in accordance with the principles set out below under the heading “Determination of Allocation of Expenses”.

Research and Risk Related Expenses. Research-related expenses, including expenses related to Bloomberg and other similar subscription-based services; independent research reports or publications; periodicals; software, quotation, and related financial and market data services (including services providing alternative data, news data, and certain valuation, pricing and economic data); expenses related to various risk software and systems used by Portfolio Managers and the 8|P a g e

Pass-Through Fund Manager; corporate access charges; investment/research-related travel expenses of Portfolio Managers and the Pass-Through Fund Manager (including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses); consulting services regarding products, technologies, issuers or industries; and “Employee Costs” (as described below) related to risk and research personnel used by the Portfolio Managers and the Pass-Through Fund Manager.

Portfolio Manager and Fund Initial and Ongoing Investment Diligence and Onboarding. Costs and expenses associated with all Portfolio Manager relationships considered (whether or not consummated), evaluated or consummated by the Pass-Through Funds, including all fees and expenses associated with sourcing, negotiating, establishing investigating, researching, financing, structuring, acquiring and performing due diligence of all Portfolio Managers (including costs of third party consultants and service providers engaged to conduct diligence, as well as the costs of background checks, and costs in connection with traveling to and attending industry conferences and other activities in connection with sourcing potential new Portfolio Managers and ongoing monitoring of existing Portfolio Managers, including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses), whether or not such relationships are ultimately consummated (including third-party research, data, analytics, modeling, structuring, pricing, execution and other third-party information systems and software and service fees (including data feeds, subscriptions, reports and similar items)), in each case related to the Fund’s investment activities.

Technology Costs. The Portfolio Manager and the Pass-Through Fund Manager’s costs related to information systems, information technology consultants, equipment, software, and technology expenses, including expenses related to risk or trading software provided by third parties or developed internally by the Pass-Through Fund Manager or an affiliate thereof; hardware; Bloomberg; trading systems; order management systems and portfolio management systems; risk management systems; execution systems; middle- and back-office software systems; contract tracking systems; costs and expenses of establishing and maintaining connectivity with Portfolio Managers, brokers and counterparties; investor reporting systems; costs related to investor reporting; data warehousing expenses; artificial intelligence tools including enterprise versions of large language models and costs associated with the development and maintenance of proprietary AI tools; cyber security costs; costs associated with the development and maintenance of proprietary treasury and portfolio finance tools, rack space; storage costs; software development; technology build out; connectivity; and business continuity program/disaster recovery.

Employee Costs. The Portfolio Manager and the Pass-Through Fund Manager’s expenses related to Portfolio Managers and Investment Adviser Personnel, such as employee salaries and bonuses, including expenses associated with personal administrative support for certain employees; employee benefits (e.g., housing allowances, meals, medical benefits, dental benefits, payroll and statutory contributions, workers' compensation contributions, and retirement benefits, including matching costs for retirement plans); professional employer organization expenses; professional-development related expenses; professional dues and professional development-related expenses (such as costs in connection with industry conferences and tuition, continuing education obligations and costs related to licensing exams and exam preparation); corporate culture and brand development including teambuilding activities such as employee social events and related travel (including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses) and holiday/special occasion gifts; travel agency, including travel management and administration services; catering services; recruitment costs (including internal referral payments, fees paid to thirdparty recruiting firms related to the engagement of the Portfolio Managers and Investment Adviser Personnel, recruiting retainers, and both fixed and/or variable fees based on bonus pay-outs); severance payments; signing bonuses; deferred compensation; relocation arrangement costs; noncompete covenant costs (i.e., paying someone during a non-compete); buy-out payments; retention bonuses or payments; long-term compensation plans; employee-related legal costs (including, but not limited to, legal fees incurred by the Pass-Through Fund Manager and/or an employee or Portfolio Manager in negotiating employment agreements); pre-launch/initial buildout expenses; consultant costs and those related to the use of third-party human resources or professional employer 9|P a g e

organization service providers; costs related to background checks; key-man life insurance policies; and additional payments intended to compensate certain key personnel of Portfolio Managers for entering into a relationship with, and providing investment advisory services to, the Pass-Through Fund Manager and/or the Pass-Through Fund and/or to compensate key personnel of such Portfolio Managers for giving up certain compensation which they would have received had they not agreed to enter into a relationship with, and provide investment advisory services to, the Pass-Through Fund. Employee costs may be paid to Portfolio Managers and their staff, including Portfolio Managers and staff directly employed by the Pass-Through Fund Manager or an affiliate thereof, as well as Investment Adviser Personnel. For the avoidance of doubt, bonus/incentive compensation paid to Portfolio Managers and Investment Adviser Personnel and treated as employee costs may be calculated based on the performance of specific “books” or the relevant Pass-Through Fund (e.g., a bonus/incentive compensation equal to a certain percentage of the overall profits of specific books or the Pass-Through Fund). The foregoing employee costs may be fully or partially waived or reduced with respect to certain investors. The amount of any such waiver or reduction will be borne by the Pass-Through Fund Manager or an affiliate and not passed on to the other investors.

Compliance and Regulatory Costs. Costs related to the Portfolio Managers’ and Pass-Through Fund Manager’s compliance programs, including outside legal costs; costs related to the retention of compliance consultants; mock exam costs; costs incurred related to regulatory reporting, inquiries, investigations, subpoenas, exams, and other proceedings; costs incurred in relation to obtaining and maintaining any regulatory license or registration, compliance system, software and other compliance-related technology costs (e.g., trade and electronic communication surveillance, regulatory reporting systems, record retention and storage systems); costs and expenses relating to the Portfolio Managers’ and the Pass-Through Fund Manager’s U.S. and non-U.S. registration, regulatory and self-regulatory filings (including Form ADV and other filings and reports); costs and expenses of any service providers or consultants used to make filings on behalf of the Pass-Through Funds or the Pass-Through Fund Manager (including for Form ADV, AIFMD or other jurisdictionspecific filings); costs associated with regulatory and self-regulatory organization memberships; taxes and licensing and amounts used to enable the Portfolio Managers or the Pass-Through Fund Manager to establish appropriate capital adequacy buffers, as determined by the Pass-Through Fund Manager, or as may be required by non-U.S. regulators from time to time (e.g., if a non-U.S. regulator required a Portfolio Manager or the Pass-Through Fund Manager to maintain a certain amount of capital, the Pass-Through Funds would be responsible for providing such capital and would treat the provided capital as an expense of the Pass-Through Funds).

Facilities Costs. The Portfolio Manager and the Pass-Through Fund Manager’s costs related to rent, depreciation, furniture, and fixtures, including leasehold improvements; security deposits; fees and collateral letters of credit as well as insurance; utility; communications equipment, including expenses relating to standard and advanced telecommunications equipment and data transmission lines, cloudbased video communication services, mobile phones and other personal electronic devices and related costs pertaining to voice and data plans; internet access; and cleaning costs, etc. for current and future offices established in any jurisdiction by Lighthouse.

Onboarding and Diligence Costs. Due diligence and professional costs and expenses related to establishing, maintaining and performing initial and ongoing diligence of service provider relationships, including vendor due diligence service providers; vendor risk management software; and any travel-related costs, which may include first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses and legal costs and expenses incurred in connection with negotiating, establishing, maintaining and performing diligence of such arrangements.

Operational Costs. Costs and fees attributable to the general operation and administration of the businesses of the Portfolio Manager and the Pass-Through Fund Manager, including all legal, compliance, accounting, and auditing expenses incurred in connection with transfer pricing analyses and other professional services (including consulting services) related to the activities of the Portfolio Manager, Pass-Through Fund Manager, and Investment Adviser Personnel. 10 | P a g e

Determination of Allocation of Expenses

Pass‑Through Expense Model. Each Fund that invests in a Pass‑Through Fund will bear Pass‑Through Expenses in respect of its investments in such Pass‑Through Funds. There is no limit on the amount of Pass‑Through Expenses that may be charged to the Fund (and borne indirectly by investors), nor on the amount of Fund assets that Lighthouse may allocate to Pass‑Through Funds. Lighthouse may, in its sole discretion, elect not to pass through certain expenses, and has done so in the past. Pass‑Through Expenses Borne by the Fund. Lighthouse provides or arranges investment‑related, research, administrative, accounting, data processing, technology, and other services to the Fund. The costs of these services (among other things) are passed through to the Fund and investors as Pass‑Through Expenses. While Lighthouse believes the terms on which it provides (or arranges) these services are fair, the arrangements among Lighthouse and the Funds, involve inherent conflicts of interest. Use of Pass‑Through Expenses; Incentives and Potential Benefits to Lighthouse. Pass‑Through Expenses may be used to improve various aspects of Lighthouse’s business, including developing technology, data‑processing capabilities, investment models, information systems, and operations, and to enhance recruitment and retention of Portfolio Managers and other personnel. Although made in furtherance of the Funds’ investment objectives, these enhancements may also benefit Lighthouse (and/or a co‑investment adviser) in other aspects of their businesses; investors may not participate in or benefit from those other aspects. Because Lighthouse (or a subsidiary) manages each Pass‑Through Fund, Lighthouse’s discretion to allocate Fund assets to a Pass‑Through Fund or to such Fund’s share class(es) creates incentives and conflicts—including an incentive to allocate expenses to Pass‑Through Funds where Pass‑Through Expenses offset costs Lighthouse or its affiliates might otherwise bear (e.g., employee compensation, rent, and other overhead), and an incentive tied to the business improvements described above. The Pass‑Through Expense model may also provide less incentive for the Pass‑Through Fund Manager and Portfolio Managers to reduce operating and compensation expenses than an alternative structure (e.g., solely a fixed, asset‑based management fee). Ownership of Property and Intellectual Property. Any property purchased or intellectual property generated by Lighthouse (or the applicable Portfolio Managers) in connection with managing the Funds will be their sole property and may be used as they determine, without reimbursement to the Fund, even where the Fund and investors bore the costs of acquisition or development (and may also be used for the benefit of clients who did not bear their pro rata share of such costs). Shared Services among Funds; Allocation Methodologies. Certain Pass‑Through Expenses relate to services shared among multiple Funds or share class(es) within such Funds. Lighthouse will allocate such expenses on a basis it believes fair and equitable, including (i) pro rata by net asset value, (ii) relative benefit derived, or (iii) another reasonable method designed to achieve an equitable allocation under the circumstances. •

• •

Administration example. Administration fees are apportioned by the administrator, in consultation with Lighthouse, to each Fund based on the level and complexity of administration services received. Funds receiving fewer services are allocated a smaller percentage than those receiving more services. Non‑pro rata allocations. In some cases, Lighthouse may allocate all or a portion of specific Pass‑Through Expenses on a non‑pro rata basis if it determines in good faith that such allocation is more equitable than a strictly pro rata allocation. Subjective judgments; estimates. Expense allocations often involve the subjective judgment of Lighthouse (e.g., assessing the extent to which a Fund or other Lighthouse-managed Fund benefits from an expense) and may be based on estimates and assumptions that, while believed reasonable, may be imprecise and could result in the Fund bearing a larger portion of expenses than under different methodologies. Lighthouse will face conflicts of interest in making such allocation decisions (due to internal investment in a particular account, differing performance compensation rates between accounts, differing expense structures between accounts (including 11 | P a g e

advising non-pass-through expense accounts) or other reasons) and there may be alternative allocations of Pass-Through Expenses that would also be reasonable. Allocations of PassThrough Expenses may be based upon assumptions and estimates made by Lighthouse, which may result in differing allocations of Pass-Through Expenses than would be the case if exact figures were employed. While Lighthouse will allocate such expenses in good faith in accordance with its expense allocation policies and procedures, there can be no assurance that any PassThrough Expense will be allocated in a particular manner. Employee Time and Corporate Service Functions. Where an employee of Lighthouse or an affiliate devotes some but less than substantially all of his or her time to a Fund’s investment activities, related costs will be charged to the Fund as Pass‑Through Expenses either based on an estimated percentage of time devoted to the Fund and to other Lighthouse-managed Funds or based on other allocation methods deemed fair and equitable by Lighthouse. Determining the extent of such time and the method of allocating Corporate Service Functions involves the factors referenced in “Subjective judgments; estimates” referenced above. Administrator Provided Personnel and Related Costs. Certain employees of our primary fund administrator devote their full professional attention to Lighthouse and its Funds. Some of these employees work from our offices, and others perform their functions from the administrator’s offices. Such employees of the primary fund administrator provide support in many different areas, including, but not limited to: (i) middle and back-office services; (ii) collateral management; (iii) portfolio finance; (iv) trade capture and integration; (v) regulatory filings; (vi) financial statement reporting; (vii) tax; (viii) investor administration; (ix) measuring, monitoring and reporting of fund risk; (x) preparation of standard and custom reports for investors; (xi) investment vehicle onboarding and implementation; (xii) operations programming and risk data integration and management; (xiii) operations and risk software development and ongoing support; (xiv) operational due diligence; and (xv) managed infrastructure technology. The costs associated with these employees (e.g., compensation and benefits) are included in the primary administrator’s overall fees. In certain limited cases, fees associated with such services are charged to Funds not administered by our primary administrator. Fund‑Specific Limitations; Expenses Covered by Lighthouse. Some Funds have offering terms that limit or prohibit payment of certain expenses (e.g., research or other services otherwise allocated pro rata by NAV). In such cases, expenses that would have been allocated to those Funds will be covered by Lighthouse. At its discretion, Lighthouse may also cover all or a portion of expenses that otherwise would be borne by a Fund. Benefits Not Necessarily Proportionate to Expenses. Allocation of expenses does not guarantee that associated benefits are shared proportionately among Funds or investors. For example, certain investors may receive customized reporting and thus derive greater benefit from certain risk software, while the related software expense is allocated pro rata among Funds (and investors therein). Additional Conflicts Across Funds. When allocating expenses among different Funds or share class(es) within such Funds, a potential conflict of interest exists due to different fee terms, affiliations, or arrangements that Lighthouse maintains with our Funds. Lighthouse also determines the rates and allocation methodologies that clients and/or Portfolio Managers will pay for services received from certain service providers. Nonetheless, Lighthouse has established specific procedures in an effort to monitor expense allocations between accounts designed to mitigate any conflicts. Portfolio Manager Compensation; Interaction with Pass‑Through Expenses. In certain circumstances, Portfolio Managers may receive additional payments from our Funds intended to attract and retain key principals or to compensate them for foregone compensation. Portfolio Managers generally receive performance‑based fees that are independent of the performance of other Portfolio Managers or of overall product performance; thus, a Portfolio Manager with positive performance may receive performance compensation even if a Fund’s overall performance is negative.

12 | P a g e

Treatment of Pass‑Through Expenses in Sub‑Advisory Arrangements. Subadvisory agreements typically provide that Pass‑Through Expenses will either (i) reduce the relevant account’s net appreciation (on which the Portfolio Manager’s performance fee is calculated) or (ii) reduce, dollar‑for‑dollar, the performance fee payable to the Portfolio Manager. To the extent a Portfolio Manager has insufficient positive performance to absorb Pass-Through Expenses in a period, the shortfall is rolled forward to subsequent periods. As a result, investors who bore Pass-Through Expenses in a prior period may not benefit from the subsequent earn-back, or may be diluted by investors who subscribe in the later period. Lighthouse determines, in its sole discretion, the appropriate method and may agree with a Portfolio Manager that certain Pass‑Through Expenses will be paid by the client or Fund without reducing the Portfolio Manager’s net appreciation or performance fee. Personal Benefits and “Perks”; Service‑Provider Benefits. Lighthouse, its personnel, and Portfolio Managers receive certain personal benefits and/or “perks” arising or resulting from their activities on behalf of clients and Funds that will not otherwise be shared with the clients. For example, airline travel or hotel stays incurred as pass-through expenses typically result in certain benefits such as cash rebates, “miles,” or credit card “points” under credit card loyalty/status programs. Such benefits and/or amounts will, whether or not de minimis or difficult to value, inure exclusively to Lighthouse personnel or Portfolio Managers (and not to the Funds or clients), even though clients often will be bearing the underlying expenditures as Pass-Through Expenses. It is also possible that a service provider will offer certain benefits to Lighthouse or one or more personnel, because of such service provider’s relationship with Lighthouse or a Fund, even if such benefits are not afforded by this service provider to the Fund which can present conflicts of interest. Outside Business Activities; Familial Relationships. Certain personnel engage in outside business activities that could give rise to the appearance of or create actual conflicts of interest for Lighthouse and the Funds. In carrying out these outside business activities, personnel will use Lighthouse systems and resources on a limited basis to support such outside business activities. While Lighthouse does not incur additional expenses associated with an employee’s use of such systems/resources for these activities, the expenses for these systems and resources are Pass-Through Expenses. Lighthouse policies do not prohibit the hiring of employees who have familial relationships with current employees. Lighthouse has and may in the future hire employees who are related to other employees. In making personnel decisions relating to such hires, Lighthouse will be faced with conflicts of interest in terms of the hiring decision, ongoing supervision and determining such employees’ compensation, which is ultimately borne by investors as a Pass-Through Expense. Lighthouse has implemented policies reasonably designed to mitigate the conflicts of interest posed by such familial relationships. Investments in Other Lighthouse-managed Funds and Operating Expenses. When our Funds invest in our other Lighthouse-managed Funds, they are generally not subject to a Management Fee or Performance Fee (i.e., typically, there are no “double fees” paid to Lighthouse). However, they do bear their pro rata portion of expenses in such other Funds. Such expenses are not separately paid by any Fund invested therein but are incorporated into the calculation of the net asset value of such other Fund. Policies; No Assurance of a Particular Allocation. While Lighthouse will allocate expenses in good faith and in accordance with its expense‑allocation policies and procedures, no assurance can be given that any Pass‑Through Expense will be allocated in a particular manner. See each Fund’s offering or other relevant disclosure document for a summary of more specific expense disclosures.

13 | P a g e

In addition, because performance-based compensation is generally based on realized and unrealized gains and losses, Lighthouse, a co-adviser or a Portfolio Manager could earn performance-based compensation on gains that investors in certain Funds never realize. In some cases, a Fund issues more than one class or series of shares or interests where some classes or series are subject to a Performance Fee, while other classes or series are not. Similarly, a Fund that is subject to a Performance Fee and another Fund that is not subject to a Performance Fee may both invest through the same Fund. In those instances, all investors in the investing Funds are subject to the risks discussed in the preceding paragraph (not just the investors that are subject to the Performance Fee) because Lighthouse manages each such Fund as a single pool of assets. Moreover, the side-by-side management of some Funds that pay performance-based compensation and other Funds that do not pay performance-based compensation could create an incentive for Lighthouse to favor accounts from which Lighthouse receives performance-based compensation because Lighthouse stands to gain greater compensation from those accounts. Lighthouse addresses these conflicts through policies and procedures reasonably designed to provide fair and equitable treatment over time in the allocation of investment opportunities and transactions among our Funds. Allocations are not necessarily made on a pro rata basis among our Funds. Rather, Lighthouse allocates investment opportunities among our Funds on the basis of numerous considerations, such as: (i) different liquidity needs (e.g., investor inflows, investor outflows, foreign currency trading settlements, credit facility guidelines/limits, fund liquidity profile, or other reasons); (ii) the investment timeframe; (iii) the investment capacity of the investment opportunity; (iv) different strategy or investment needs (due to differing performance, changes in investment guidelines, differing capital bases, or other reasons); (v) the percentage of assets that the Fund has previously allocated to the same strategy as the investment opportunity; (vi) tax status and client type (onshore, offshore, and/or ERISA); (vii) intent to avoid our Funds having to pay withdrawal fees to Unaffiliated Funds; (viii) Funds not having sufficient cash or unfunded commitments on hand to make an allocation within the required timeframe; (ix) legal considerations; and (x) other considerations that Lighthouse deems appropriate in Lighthouse’s discretion. Lighthouse does not consider fees paid by an investor or a Fund when making allocation and redemption decisions. Certain Funds are treated as “plan assets” for the purposes of the fiduciary responsibility standards and prohibited transaction restrictions of the ERISA, and the parallel prohibited transaction excise tax provisions of Section 4975 of the Internal Revenue Code of 1986. For compliance and other reasons, certain investment funds or their investment managers limit the amount of the investment made by a plan assets fund or may prohibit such investments altogether. As a result, allocations of investments for “plan assets” and “non-plan assets” Funds are different due to the ability or inability of different investment funds or their investment managers to accept assets subject to ERISA.

14 | P a g e

Institutional investors include, but are not limited to, sovereign wealth funds, governmental and corporate pension plans, insurance companies, banks, corporations, government entities, healthcare organizations, charitable organizations, foundations, endowments (including those benefiting universities and colleges), religious entities, and other business entities. Lighthouse also provides limited-scope advisory services, including Platform Services, to certain private funds managed by unaffiliated investment advisers, as described in Items 4 and 10. Each investor in a Fund must generally be (a) an “accredited investor” as defined in Regulation D under the Securities Act of 1933, as amended (the “Securities Act”) and (b) either a “qualified purchaser” as defined in the Investment Company Act or a “knowledgeable employee” as defined in the regulations thereunder. In the case of certain offshore Funds, non-U.S. investors generally need not be “accredited investors” or “qualified purchasers” so long as each such non-U.S. investor is not a “U.S. person” as defined in Regulation S under the Securities Act, as amended. Minimum investment requirements for investors vary by Fund and are set forth in the applicable Fund’s offering documents. Lighthouse may waive or modify such minimum investment requirements in its discretion, subject to applicable legal and regulatory requirements.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis As described in Item 4, Lighthouse offers Platform Hedge Funds and Hedge Fund Solutions designed to meet a variety of investment objectives, as described more fully in the offering documents of the applicable Fund or other documents governing the applicable mandate. Depending on the strategy, Lighthouse and its Portfolio Managers may use fundamental, quantitative, systematic, macroeconomic, relative value and other forms of analysis in identifying investment opportunities, constructing portfolios and managing risk. Investment strategies implemented across Lighthouse include, but are not limited to, equity, credit, event-driven, fixed income, global macro, quantitative and systematic, relative value, opportunistic and multi-strategy approaches. There can be no assurance that a Fund will achieve its investment objective. For strategies implemented through Portfolio Managers, Lighthouse also evaluates Portfolio Managers through quantitative and qualitative analysis of factors that may include performance history, strategy differentiation, portfolio construction, risk management, personnel, systems and internal controls. Lighthouse's overall portfolio construction may also take into account current economic and market conditions, liquidity, diversification of strategy exposures, capacity constraints and other factors. The main strategies implemented by our Portfolio Managers include:

Credit Event-Driven Fixed Income Global Macro Long/Short Equity Market Neutral Equity Quantitative and Systematic Multi-Strategy Relative Value Opportunistic 15 | P a g e

The strategies described below may employ a variety of investment techniques, including taking both long and short positions, the use of leverage and derivatives, and other techniques described elsewhere in this

Fixed income strategies attempt to profit from movements in bond prices. Fixed income strategies, such as relative value arbitrage, involve the pairing of one instrument believed to be of higher value with another closely related instrument believed to be of lower value. Fixed income arbitrage can involve corporate, government, or mortgage assets.

Global Macro

Global macro strategies seek to identify investment opportunities arising from macroeconomic, market and geopolitical developments and trends. These strategies may take long or short positions in global interest rate, fixed income, equity, currency and commodity markets through securities, futures, swaps, options and other instruments. Global macro strategies may employ discretionary, systematic or a combination of approaches.

Long/Short Equity

Long/short equity strategies involve the purchase of a long basket of stocks hedged by a short basket of stocks. Unlike market neutral equity, there are no constraints on the percentage of long securities versus short securities. For example, a Portfolio Manager might be 80% long and 20% short or 60% long and 40% short, thus exposing the net portfolio balance to broader market risk factors. Long/short equity can be broad in terms of security selection or very focused on a particular sector or geography.

Market Neutral Equity

Market neutral equity strategies attempt to profit from discrepancies between a basket of long and short positions in similar proportions. The decision to purchase or sell a security can be driven by computer models or by fundamental research. Typically, the long equity portion of the portfolio will include stocks with solid balance sheets, improving earnings, and strong financial ratios. The short equity positions will include stocks with weak balance sheets, declining earnings, outdated products, and poor financial ratios. Some market neutral equity strategies concentrate on specific sectors or geographies.

Quantitative and Systematic

Quantitative and systematic strategies use quantitative analysis, statistical techniques, algorithms, models and other technology to identify investment opportunities, construct portfolios and/or generate trading signals. These strategies may incorporate a variety of data sources and may be implemented with varying degrees of human judgment or intervention. Certain strategies may also use artificial intelligence (“AI”) and machine learning technologies as part of the investment process.

16 | P a g e

Multi-Strategy

This strategy generally involves Portfolio Managers exercising discretion in allocating capital among several types of investment strategies. Capital is allocated to each strategy based on the possibility of an opportunity set changing with market conditions.

Relative Value

Relative value is an investment strategy that involves taking positions based on the pairing of one instrument that is believed to be overpriced with another closely related instrument that is believed to be underpriced. Examples include merger, credit, and convertible bond arbitrage. Merger arbitrage generally involves buying the common stock of a company involved in a takeover or merger attempt where the current market price is less than the offered price on the transaction’s expected closing date. Credit arbitrage seeks to take advantage of price discrepancies between common stocks, bonds, options, and credit derivatives of the same issuer or another related company or companies. Convertible bond arbitrage involves the purchase of a convertible bond while a short position is taken in the underlying company’s common stock. This allows for trading of both the convertible bond and common stock against each other as one instrument becomes overvalued or undervalued relative to the other.

Opportunistic Strategies

To implement the opportunistic strategy, Lighthouse focuses on Portfolio Managers that attempt to take advantage of investment opportunities in the medium term (i.e., three to seven years) liquidity market that Lighthouse believes presents an attractive risk/return profile. Portfolio Managers that Lighthouse selects for the opportunistic strategy may implement event-driven, credit, or any other investment strategy. Lighthouse has found investment opportunities with Portfolio Managers who focus on asset-backed securities, collateralized loan obligations, collateralized debt obligations, long/short credit, bank loans, distressed debt, secondary loans, whole mortgages, and other products with exposure to the credit markets both in the U.S. and internationally. For the opportunistic portfolio, Lighthouse may also invest assets in non-credit focused opportunities, including, but not limited to, investments in distressed hedge fund interests trading at a discount in the secondary market and co-investment opportunities in individual securities alongside the Funds. Certain Funds implementing opportunistic strategies can have exposure to publicly and privately traded securities. Generally, our Portfolio Managers are neither limited in the markets (either by location or type, such as large capitalization, small capitalization, or non-U.S. markets) in which they invest nor the investment discipline that they may employ (such as value or growth or bottom-up or top-down analysis). The investment guidelines are set forth in the Subadvisory Agreements, each of which specify restrictions and investment strategies of the applicable Fund. However, the offering documents of Unaffiliated Funds may not subject the Portfolio Managers to any formal limitations as to the investments permitted or strategies in effect.

Risk of Loss Investing in securities involves a substantial risk of loss that investors in our Funds should be prepared to bear. Further, past performance of a Fund is not indicative of future performance. There are material risks associated with the structures of our Funds and with the investment strategies employed directly or through Portfolio Managers and Unaffiliated Funds, as summarized below. This summary does not attempt to describe all of the risks associated with an investment in our Funds or all the risks associated with the strategies employed by our Funds. Although no summary can fully describe all of the risks associated with an investment in our Funds, investors should also review the risk factors stated in the offering documents or relevant constitutional document for each of our Funds, which are tailored to the specific strategies and investment structures employed, and consult with their own financial advisors prior to making an investment.

17 | P a g e

The risks described below may arise from investments made directly by Lighthouse, through Portfolio Managers, or through investments in other pooled investment vehicles, as applicable. Not every risk described below applies to every Fund or investment strategy.

Investment Management and Strategy Risks Investment Strategies and Risk Generally

The success of our Funds depends on Lighthouse’s and the applicable Portfolio Managers’ ability to identify and select investments, interpret market information and otherwise successfully implement the applicable investment strategies. For multi-Portfolio Manager strategies, success also depends on Lighthouse’s ability to select Portfolio Managers and allocate and reallocate capital among them. Portfolio Managers may deviate from expected investment strategies or guidelines, whether intentionally or inadvertently, and may engage in excessive concentration, directional investing, leverage or other activities that result in losses, or engage in fraud or other misconduct. There can be no assurance that Lighthouse or any Portfolio Manager will successfully implement an investment strategy or that a Fund will be able to obtain or maintain desired investments or exposures.

Multiple Portfolio Managers

For Funds that use multiple Portfolio Managers, each Portfolio Manager generally trades independently of the others. As a result, losses generated by certain Portfolio Managers may offset profits generated by others. Portfolio Managers may also compete for the same investment opportunities, potentially affecting the availability or value of positions in a manner adverse to a Fund. Conversely, Portfolio Managers may establish economically offsetting positions, causing a Fund to incur expenses without achieving a corresponding net investment exposure. Portfolio Managers may also establish similar or overlapping positions, resulting in greater concentration or correlation than intended.

Other Clients of Portfolio Managers

The Portfolio Managers may also manage other accounts (including other funds and accounts in which the Portfolio Managers have an interest) that may employ different or similar trading strategies and that, together with accounts already being managed, could increase the level of competition for the same trades our Funds might otherwise make, including the priorities of order entry. This could make it difficult or impossible to take or liquidate a position in a particular security or futures contract at a price or on the terms sought by a Portfolio Manager.

Portfolio Managers with Limited or No Performance Track Record

Certain Portfolio Managers may be newly formed businesses or otherwise have limited operating histories or performance track records. Such Portfolio Managers may still be developing their operational processes and refining their approaches to portfolio construction and risk management and may have fewer personnel or other resources than more established Portfolio Managers. Although Lighthouse may seek to evaluate the prior performance and experience of key personnel at previous firms, such information may be limited or unavailable and may not be indicative of the Portfolio Manager's future performance. These factors may increase the investment and operational risks associated with allocating capital to such Portfolio Managers.

Portfolio Managers Consisting of a Single Principal

Certain Portfolio Managers may consist of only one principal or otherwise depend substantially on a single individual. The death, incapacity, departure or other unavailability of such individual could adversely affect the implementation of the applicable investment strategy and result in losses to a Fund.

Regulatory Hosting Platforms

Lighthouse or an affiliate may provide regulatory hosting arrangements to certain Portfolio Managers, including arrangements under which a Portfolio Manager becomes affiliated with Lighthouse or an affiliate for purposes of obtaining regulatory authorization necessary to trade on behalf of a Fund. Lighthouse may also use third parties to provide such arrangements. Regulatory requirements and the availability or 18 | P a g e

permissibility of regulatory hosting arrangements vary by jurisdiction and may change. Changes in applicable requirements or regulatory practices could delay the onboarding of Portfolio Managers, interrupt or restrict the activities of existing Portfolio Managers, or require alternative regulatory arrangements, which could adversely affect a Fund or Lighthouse’s ability to source, attract and onboard Portfolio Managers.

Reliance on Management and Key Employees

The success of our Funds depends substantially on the services and skills of Lighthouse and its personnel and, depending on the applicable strategy, Portfolio Managers and their key personnel. The loss or unavailability of one or more key individuals, or an inability to attract and retain qualified investment and other personnel, could adversely affect the implementation of a Fund’s investment strategy and its performance.

Assets May Not Be Diversified

Our Funds are not necessarily required to diversify their investments and may have significant exposure to a limited number of positions, issuers, industries, sectors, geographic regions, asset classes, investment strategies or Portfolio Managers. In Funds that allocate capital among multiple Portfolio Managers, Portfolio Managers make investment decisions independently and may establish similar or overlapping positions, resulting in greater concentration or correlation than intended. Concentrated exposures may increase a Fund’s risk of loss because adverse developments affecting one or a limited number of investments or exposures could have a material adverse effect on the Fund.

Sector Risks

Certain Funds or investment strategies may have significant exposure to particular industries, sectors or market segments. Such concentrations may cause a Fund to be more significantly affected by economic, regulatory, technological or other developments affecting the applicable industry, sector or market segment and may result in greater volatility or losses than would occur in a more diversified portfolio.

Increased Competition for Investment Opportunities

The investment management industry is highly competitive, and increased numbers of market participants or increased capital pursuing similar investment strategies may reduce the availability or attractiveness of investment opportunities. Increased competition may result in higher asset prices, narrower spreads, reduced liquidity, increased transaction costs or lower prospective returns and may make it more difficult for a Fund to establish or exit positions on favorable terms.

Transaction Costs

Certain Funds or investment strategies may engage in a high level of trading activity, which may result in significant transaction costs, including brokerage commissions, bid-ask spreads, exchange and clearing fees and other trading expenses. Such costs reduce a Fund's investment returns and may be increased by the use of leverage or frequent trading. Lighthouse or a Portfolio Manager may select or limit the use of brokers, counterparties, clearing firms or other service providers based on factors other than the lowest available cost, including financial condition, execution capabilities, operational considerations and other factors considered relevant. As a result, a Fund may incur higher transaction or other costs than it would if such providers were selected solely on the basis of price.

Hedge Strategies

A Fund may use short positions, futures, options, swaps and other instruments or strategies to hedge or otherwise manage investment exposures. Hedging may be incomplete, ineffective or unavailable and may result in losses or reduce gains that otherwise would have been realized. There can be no assurance that any hedging strategy will achieve its intended purpose, and a Fund may determine not to hedge certain risks or exposures.

19 | P a g e

Relative Value Strategies

Relative value, market-neutral and arbitrage strategies seek to profit from perceived pricing discrepancies or relationships among investments and are not without substantial risk. A perceived mispricing may be incorrectly identified, may persist for an extended period or may widen rather than converge. Historical or expected relationships among investments may change, particularly during periods of market stress. Illiquidity, default or other adverse developments affecting one component of a position may also result in losses on the overall position or cause an intended relative value or hedged position to become directional.

Event-Driven Strategies

Event-driven strategies seek to identify investment opportunities arising from mergers, acquisitions, restructurings, tender offers, exchange offers and other corporate events or special situations. The success of these strategies may depend on correctly assessing whether, when and on what terms an anticipated event or transaction will occur. A transaction may be delayed, modified or terminated as a result of regulatory, financing, market, shareholder, litigation or other developments. If an anticipated event does not occur as expected, securities or other positions related to the event may experience significant changes in value and result in losses to a Fund. Positions related to such events may not be fully hedged against market or other risks.

Opportunistic Strategies and Other Illiquid Fund Investments

Investments in Unaffiliated Funds pursuing opportunistic or other illiquid strategies may not be redeemable at the option of a Fund and may not make distributions for extended periods. Such investments may also require additional capital contributions. Lighthouse must manage a Fund’s liquidity to meet capital calls, the timing and amount of which may be uncertain. A Fund’s failure to satisfy a capital call could result in adverse consequences under the applicable investment terms.

Activist Investing

A Fund may pursue, directly or indirectly through an Unaffiliated Fund, activist or similar investment strategies that seek to influence the management, governance, strategy or operations of an issuer. Such activities may require significant time and resources and may result in opposition from an issuer, its management, other shareholders or other parties. Activist investing may also result in litigation, regulatory inquiries or investigations, additional disclosure or filing obligations, and other legal or regulatory requirements. A Fund may incur substantial expenses in connection with such activities, and there can be no assurance that an activist strategy will achieve its intended objective or result in a profitable investment.

Tracking Error in Benchmark Replication

When certain investment strategies seek to replicate one or more applicable indices, a variety of factors could result in divergences between the performance of the investment strategy index exposure and the applicable index. As tracking an index involves replicating or approximating the performance of a specified market or sector index, there may be differences between the return of a Fund’s index exposure and the underlying index itself, which may arise from factors such as expenses, transaction costs, sampling, rebalancing, market conditions, liquidity or divergence of the holdings of the index exposure from the underlying index’s constituents. Further, the underlying index may be subject to changes in the composition, methodology or calculation of such index, which may affect the ability of a Fund’s index exposure to track the index accurately or efficiently. For instance, constituents may be added, deleted or reweighted or the rules or criteria for selecting or excluding such constituents may be modified based on various factors, such as market capitalization, liquidity, dividends or environmental, social, and governance criteria. As a result, investors should be aware that a Fund’s index exposure may not accurately replicate the applicable index at all times.

20 | P a g e

Quantitative and Systematic Model Risks

Lighthouse and certain Portfolio Managers employ quantitative models in connection with certain investment strategies. Such models and related technology may be developed or provided by third parties that are not affiliated with Lighthouse, in which case Lighthouse may have limited visibility into their design, data or modification and may be unable to independently validate their outputs. The termination, modification or degradation of a third-party arrangement, or the departure of key personnel at a provider, could require a strategy to be modified, suspended or terminated. Quantitative strategies may use statistical, economic, financial, mathematical or other models, algorithms and techniques to analyze data, identify investment opportunities, construct portfolios and/or generate investment or trading decisions, in some cases with limited human intervention. The research, development and implementation of quantitative models can be complex, and there can be no assurance that any model will be effective or that Lighthouse or a Portfolio Manager will successfully develop, maintain or update models as market conditions and other factors change. Models may be based on assumptions that prove incorrect or may fail to adequately reflect the complexity of financial markets. Modifications or enhancements to a model may also produce unintended results. Quantitative models may depend on substantial amounts of proprietary or externally sourced data. Data or other inputs may be inaccurate, stale, misleading, incomplete or otherwise unsuitable, and errors may occur in the collection, processing or use of such data. Even where data inputs are accurate, modelgenerated valuations or other outputs may differ materially from market prices or actual results. Reliance on faulty models, data or assumptions may result in inappropriate investment, valuation, hedging or trading decisions or missed investment opportunities. Quantitative strategies also depend on computer systems, software, telecommunications and other technologies. Programming or coding errors, input failures, system failures and other implementation errors may occur and may be difficult to detect or correct. Such errors may remain undetected for extended periods, and their effects may compound before they are identified. In addition, reduced market liquidity or other market conditions may impair the implementation or effectiveness of a quantitative strategy. Transaction costs associated with quantitative strategies may be significant, and differences between the expected price of a trade and the price at which it is executed, or “slippage,” may adversely affect performance. Quantitative models may incorporate or be used in conjunction with AI Technologies (as defined below), which are subject to the additional risks described below under “Use of AI Technologies.”

Use of Systematic Execution Strategies

Certain Lighthouse strategies place significant reliance on order routing, internal netting, and systematic execution strategies developed and implemented by Lighthouse personnel and technologists. The objective of these internal systematic trade execution strategies is to minimize market impact and reduce the overall transaction costs for the Funds. Consequently, Lighthouse at times will internally transact with independently managed strategies within a Fund to internalize the risk. Subsequent to internalization, Lighthouse will typically transact in the market at the most optimal time determined by Lighthouse consistent with our obligation to seek best execution.

Use of AI Technologies

Recent technological advances in AI, including generative AI, machine learning and related technologies (collectively, “AI Technologies”) pose risks to Lighthouse, the Funds, the Portfolio Managers, and the companies in which the Funds invest. Lighthouse, the Funds, the Portfolio Managers, and the companies in which the Funds invest could be further exposed to the risks of AI Technologies if third-party service providers or any counterparties, whether or not known to Lighthouse, also use AI Technologies in their business activities. Lighthouse will not be in a position to control the operations of third-party service providers or counterparties, the manner in which third-party products are developed or maintained or the 21 | P a g e

manner in which third-party services are provided. When relying on AI Technologies, there are certain risks involved, including data quality, copyright and trade secret violations, confidentiality breaches, unauthorized access or malware risks, insider trading, breach of contract, cybersecurity, and privacy law violations. In addition, AI Technologies are relatively recent developments and may be subject to one or more undetected errors, defects or security vulnerabilities, which may be discovered only after the technology has been introduced to and/or has had substantial operations in the marketplace. Lighthouse and certain Portfolio Managers may use AI Technologies as part of investment research, portfolio construction, risk management and investment decision-making, and certain investment strategies may rely materially on such technology, including through automated or autonomous processes. The effectiveness of these strategies may depend on the design and implementation of models and algorithms and the quality, relevance and availability of underlying data. Models may contain errors, rely on assumptions that prove incorrect, experience degradation or drift as data or market relationships change, fail to identify changing market relationships or perform differently in actual or changing market conditions than in historical or simulated environments. The speed or autonomy of certain AI Technologies may amplify the effects of such errors or limit the ability to intervene before losses occur. These and other limitations may result in investment decisions or trading activity that cause losses to a Fund. Lighthouse’s use of AI Technologies and the use by any of the parties described in the previous paragraph could include the input of confidential information (including material non-public information) — either by third parties in contravention of non-disclosure agreements (or similar undertakings or obligations of confidentiality) or by personnel of Lighthouse in contravention of Lighthouse’s policies, into AI Technologies, potentially resulting in such confidential information becoming accessible to third parties or other users. AI Technologies are generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that AI Technologies utilize to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error — potentially materially so — and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of AI Technologies. To the extent that Lighthouse, the Funds, the Portfolio Managers, and the companies in which the Funds invest are exposed to the risks of AI Technologies, any such inaccuracies or errors could have adverse impacts on Lighthouse, the Funds, the Portfolio Managers, and the Funds’ investments. AI Technologies and their applications, including in the private investment and financial sectors, continue to develop rapidly, and it is impossible to predict the future risks that may arise from such developments. Changes in laws, regulations or regulatory expectations regarding AI Technologies could also restrict or otherwise affect their use in investment management activities.

Alternative Data

Lighthouse and Portfolio Managers may use alternative data and other non-traditional sources of information in connection with investment research and decision-making. Such data may be obtained from third-party vendors or other sources and may be inaccurate, incomplete, outdated or otherwise unreliable. The collection, acquisition or use of alternative data may also raise legal, regulatory, contractual, privacy, intellectual-property or confidentiality issues, including questions regarding whether a provider had the right to collect, use or provide the data. If data is obtained or used improperly, Lighthouse, a Portfolio Manager or a Fund could become subject to investigations, litigation, restrictions on the use of the data, reputational harm or other adverse consequences. A Fund may also incur losses as a result of investment decisions based on inaccurate or unreliable data. Alternative data may include information collected through automated data collection or web scraping, which may present additional risks relating to website terms of use, intellectual property rights, privacy, unauthorized access and other legal or contractual restrictions.

Expert Networks

Lighthouse and Portfolio Managers may use expert networks, consultants and other third parties as part of their investment research. Such persons may possess or disclose material nonpublic information or other confidential information that they are prohibited from disclosing. Receipt of such information could 22 | P a g e

restrict a Fund's ability to trade in affected securities or other investments and could result in regulatory investigations, litigation, reputational harm or other adverse consequences. There can be no assurance that policies and procedures designed to prevent the improper receipt or use of such information will be effective in all circumstances.

Fund Structure, Investor and Liquidity Risks Investments by Affiliated Funds

Lighthouse-managed Funds may invest in other Lighthouse-managed Funds and are permitted to withdraw from their respective capital accounts more frequently and on less notice than other investors, which in certain circumstances could disadvantage other investors by forcing asset sales or liquidations at inappropriate times. Such Lighthouse-managed Funds may enter into letter agreements with their own investors that grant them less restrictive rights than those enjoyed by investors in the investee Funds. Not all investors will be able to obtain such additional rights. Notwithstanding Lighthouse’s authority to enter into such letter agreements, Lighthouse will not take any action or agree to any terms that would, in its reasonable judgment, be materially detrimental to investors in the investee Funds.

Liquidity

Interests in the Funds are not freely transferable and there is no market for these interests. Investors may liquidate their investments in our Funds only at certain withdrawal periods, with prior written notice to Lighthouse and/or its administrator based on an agreed upon notice period. Such terms are subject to a waiver or reduction at our discretion. There are significant restrictions on redemptions, as well as on “holdbacks” on redemptions pending the completion of a Fund’s annual audit. Consequently, investors may not be able to liquidate their investment readily in the event of an emergency or for any other reason. Certain Funds may also impose fund-level or investor-level “gates.” In general, investors cannot transfer, assign, or pledge shares and interests in the Funds without Lighthouse’s prior written consent. No market for the Funds’ shares and interests will exist at any time. Also, Portfolio Managers of Unaffiliated Funds in which our Funds may invest could subject our Funds to similar restrictions on liquidity, such as withdrawal gates and “lockups” (where investors are prohibited from redeeming their capital for a specified period following investment in such Unaffiliated Funds), which in turn will limit the liquidity of interests held by investors in our Funds. Some Portfolio Managers can limit redemptions with respect to “side pocket” investments, where a particular investment is classified as “illiquid” or “designated” and investors generally cannot receive their allocable share until that investment is liquidated or otherwise realized. Portfolio Managers to the Funds can contractually limit termination rights under the applicable Subadvisory Agreement and trade in illiquid securities.

Effect of Redemptions

If significant redemptions are requested, it may not be possible to liquidate a Fund’s investments at the time such redemptions are requested, or a Fund may be able to do so only at unfavorable prices or on unfavorable terms, which could adversely affect the Fund and its remaining investors. In addition, although it is expected that on termination of the Fund, the Fund will liquidate all of its investments and distribute only cash to the investors, there can be no assurance that this objective will be attained.

No Current Income and Potential for In-Kind Distributions

An investment in our Funds will not be suitable for investors seeking current income for financial or tax planning purposes. Although we reserve the right to declare and pay special dividends or distributions, we do not anticipate such dividends or distributions being paid except in unusual circumstances. Upon an investor’s redemption, distributions may be made partly in cash and partly in-kind. An in-kind distribution may consist of securities that are not readily marketable and may be subject to restrictions on resale. An in-kind distribution may also consist of an interest in a liquidation vehicle formed to hold certain Fund interests on behalf of redeeming investors.

23 | P a g e

Lack of Control

Substantially all decisions with respect to the management of our Funds are made by Lighthouse, the applicable Portfolio Managers and/or the governing body of the applicable Fund, subject to the Fund’s governing documents. Investors generally have no right or power to participate in the management of a Fund. In the event of the withdrawal or bankruptcy of Lighthouse, certain Funds may be liquidated or otherwise affected in accordance with their governing documents.

Side Letters; Different Business Terms

Subject to applicable law and the governing documents of the Funds, Lighthouse and the Funds may from time to time negotiate and enter into letter agreements or other similar agreements (collectively, “Side Letters”) permitting certain investors to acquire interests or shares in our Funds with additional and/or different rights than other investors. Such rights may include, but are not limited to, more favorable terms with respect to fees, expenses, liquidity, reporting and redemption rights based on the size or scope of their investment. Except as required by applicable law, Lighthouse and the Funds will not be required, and generally do not intend, to notify any or all of the other investors of any such Side Letters or any of the rights and/or terms or provisions thereof, and Lighthouse and the Funds will not be required to offer such additional and/or different rights and/or terms to any or all of the other investors. Notwithstanding the foregoing, the Fund will not enter into any Side Letter that Lighthouse believes materially adversely affects the other investors. Lighthouse may also create and offer other classes of interests or shares that are subject to different terms in respect of, without limitation, fees and allocations, voting rights, withdrawal privileges and allocation of costs and expenses, but only if Lighthouse determines that the issuance of such other classes or interests would not have a material adverse effect on existing investors.

Disparate Information Rights

Lighthouse may provide certain investors with information regarding a Fund not generally available to other investors, including but not limited to, information about Funds, Unaffiliated Funds, or Portfolio Managers. Such information is typically provided in connection with a Side Letter. Because the Funds generally permit voluntary redemptions, an investor with that information may redeem from a Fund based on that information and avoid losses when other investors would not have that information to rely upon in assessing whether they should redeem.

Sanctioned Investors

If an investor or beneficial owner becomes subject to applicable sanctions or is included on a list of prohibited or restricted persons maintained by a relevant governmental or regulatory authority, a Fund may be required to restrict or cease dealings with such investor, including by freezing or restricting subscriptions, redemptions, distributions or other transactions, and may be required to make reports to applicable authorities. Such restrictions may remain in place until the applicable sanctions are lifted, appropriate governmental authorization is obtained or other action is permitted or required by applicable law. The imposition of such restrictions or other actions by governmental authorities could adversely affect the applicable Fund and its investors.

Passive Currency Hedging

With regard to certain share classes of our Funds denominated in foreign currencies (“Foreign Currency Share Classes”), the Fund enters into forward currency contracts and spot FX transactions as part of currency hedging transactions (“Hedging Transactions”), intended to manage (not eliminate) the currency exchange rate fluctuation risk between the applicable foreign currencies and the U.S. Dollar. There is no assurance that the Hedging Transactions with regard to Foreign Currency Share Classes will be successful. Fluctuations in exchange rates are unpredictable and can have a significant impact on the return on investment to Foreign Currency Share Classes. As a result of the costs of the Hedging Transactions with regard to the Foreign Currency Share Classes, investors in such share classes may receive a lower return than the U.S. Dollar denominated Classes. Hedging involves special risks, including the possible default by the counterparty to the transaction and the risk of error in establishing a 24 | P a g e

Hedging Transaction. The costs and liabilities associated with the hedging will be borne by a Fund and allocated to the Foreign Currency Share Classes. With regard to the risk of failure or default by the counterparty to a Hedging Transaction, the Fund has contractual remedies pursuant to the agreements related to the transaction (which may or may not be meaningful depending on the financial position of the defaulting counterparty). We will seek to minimize the Fund’s counterparty risk through the selection of financial institutions and types of Hedging Transactions employed.

Cross-Class and Cross-Fund Liability Risk

Certain Funds may issue multiple classes and/or invest through other Funds. Each such Fund is a single legal entity, while the classes of a Fund are not separate legal entities. Creditors of a Fund that issues multiple classes may, absent contrary contractual provisions, enforce claims against all assets of that Fund, even if the creditors’ claims relate to a single class of that Fund. Similarly, creditors of a “Master Fund” may, absent contrary contractual provisions, enforce claims against all assets of that Master Fund. Therefore, in the unlikely event of a deficit in one class of shares in a Fund, assets of another class of the relevant Fund will be available to cover the deficit. That risk also applies to a Fund’s currency hedging activities with respect to any non-U.S. dollar denominated class and to a Fund’s allocation to opportunistic strategies. As a result, if non-U.S. dollar denominated shares of a Fund experience losses that deplete the assets of the relevant class, those losses may be offset against U.S. dollar shares or other non-U.S. dollar denominated shares (as applicable) of that Fund. Also, if a Master Fund defaults on a credit facility, including circumstances due to increased borrowing amounts from currency hedging activities or the need to meet capital calls for opportunity strategy classes, a Fund’s investments in that Master Fund may be reduced (or lost) in paying off that facility, even if that Fund or any particular class was not otherwise benefiting from the borrowing from that facility.

Fund Legal Structures Untested

Certain of Lighthouse’s Funds are Cayman Islands segregated portfolio companies (“SPCs”) and an Irish unit trust (“Unit Trust”) or similar structures. As an SPC and Unit Trust, the Funds can operate segregated portfolios and sub-trusts with the benefit of statutory segregation under Cayman Islands law or Irish law of assets and liabilities between each segregated portfolio or each sub-trust, respectively. Although not judicially tested, the principal advantage of an SPC or Unit Trust is that it protects the assets of one segregated portfolio or sub-trust, as the case may be, from the liabilities of the other segregated portfolios and sub-trusts. However, it is uncertain whether such segregation of assets and liabilities would be enforced in jurisdictions outside of the Cayman Islands or Ireland. If the assets of the other segregated portfolios in the SPC, or other sub-trusts in the case of the Unit Trust, could be accessed for the purpose of covering the deficit of one segregated portfolio or sub-trust, this could result in losses for our Funds invested therein. Certain Funds may be further sub-divided into Sub-Accounts, each of which is sub-advised by a Portfolio Manager. The assets and liabilities of the Sub-Accounts of such a Fund will not be considered segregated from one another. Rather, the assets and liabilities of all Sub-Accounts of such Fund will be considered on an aggregate basis. As a result, liabilities of one Sub-Account of a Fund may be enforced against another Sub-Account of the same Fund.

Possible Indemnification Obligations

The Funds have agreed or may agree to indemnify, among others, the administrator, Lighthouse (in its capacity as general partner, member or investment manager of the Funds), the prime brokers of the Funds, other parties and each of their respective agents, principals, officers, employees and affiliates under certain circumstances.

Valuations in Unaffiliated Funds

To determine net profits and losses, the securities and other positions held by our Funds in Unaffiliated Funds must be valued. In valuing a Fund’s assets in Unaffiliated Funds, Lighthouse will generally rely on the valuations provided by the various third-party Portfolio Managers and/or the administrators of such Unaffiliated Funds. Although Lighthouse will review the valuation procedures used by the third-party Portfolio Managers, Lighthouse will have little or no means of independently verifying valuations provided 25 | P a g e

by such third-party Portfolio Managers. In calculating net asset values, although our Funds will review other relevant factors, Lighthouse will rely significantly on values reported by the third-party Portfolio Managers for such Unaffiliated Funds and/or their administrator. These valuations will typically be estimates only and will be subject to revision based on the annual audit for each Unaffiliated Fund. Revisions to a Fund’s gain and loss calculations will be an ongoing process, and no appreciation or depreciation figure can be considered final until the annual audits of the Unaffiliated Funds are completed. Should these valuations prove to be incorrect, such Funds may experience losses.

Investment, Trading and Financing Risks Borrowing and Leverage

A Fund may employ leverage directly or indirectly through borrowings, margin transactions, derivatives, short sales and other investments or financing arrangements. The amount and form of leverage employed may vary significantly among Funds, investment strategies and over time. Leverage can magnify both gains and losses, and a Fund that employs leverage may experience greater losses than it would have experienced without leverage. Interest, financing and other costs associated with leverage will reduce returns and may exceed gains generated by the assets or exposures financed. A Fund may be required to pledge assets or post margin or other collateral in connection with its use of leverage. Changes in market conditions, asset values, collateral requirements or the availability or terms of financing may require a Fund to post additional collateral on short notice or reduce its leverage. A Fund may therefore be required to liquidate investments or unwind positions at unfavorable times or prices, potentially resulting in substantial losses.

Credit Facilities

Certain Funds may use credit facilities or other financing arrangements to provide liquidity for investments, meet redemption requests or capital calls, settle transactions or for other purposes. Such arrangements may result in interest, commitment fees and other expenses and may be subject to borrowing limits, collateral requirements, financial covenants and other conditions. A lender may reduce, terminate or decline to renew a credit facility, or financing may otherwise become unavailable or more expensive, including during periods of market stress. A reduction in or loss of available financing could impair a Fund's ability to meet liquidity needs, make investments or satisfy other obligations and could require the Fund to liquidate investments at unfavorable times or prices.

Financial Institution Risk; Distress Events

A Fund is subject to the risk that a bank, broker, counterparty, clearinghouse, exchange, lender, custodian or other financial institution through which it conducts business or at which assets are maintained (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, seizure, receivership or other financial distress or difficulty (a “Distress Event”). A Distress Event may prevent or delay a Fund from accessing deposits, assets, financing arrangements or other services and may result in losses or disruptions to a Fund's investment or other activities. Deposit or other protection schemes, where available, may be subject to limits and may not protect all assets or exposures of a Fund. Governmental or regulatory authorities may take actions in response to a Distress Event, but there can be no assurance as to the nature, timing or effectiveness of any such action. A Distress Event may adversely affect a Fund and Lighthouse's ability to manage or operate the Fund. Assets held by a Financial Institution may also be subject to risks arising from the Financial Institution's custody or control of such assets, including potential delays or limitations on a Fund's ability to recover or access assets in the event of insolvency or other financial distress. Depending on the applicable custody and financing arrangements and insolvency law, assets posted as margin or collateral to a prime broker or other counterparty may be available to that party's creditors, and a Fund may experience delays in recovering such assets or may recover only as an unsecured creditor.

26 | P a g e

Short Selling

A Fund may engage in short selling as part of its investment strategy or for hedging purposes. Short selling generally involves selling a security that the Fund does not own and borrowing the security for delivery to the purchaser, with an obligation to replace the borrowed security at a later date. If the price of a security sold short increases, the Fund will incur a loss when it purchases the security to close the position. Because the price of a security sold short can increase without limit, losses on a short position may be theoretically unlimited. A Fund may also incur borrowing costs and may be required to post additional collateral as the value of a short position changes. Securities may become difficult or expensive to borrow, and a lender may require the return of borrowed securities at a time when doing so is disadvantageous to the Fund. Short selling may therefore result in substantial losses. Regulators and exchanges in the United States and other jurisdictions have from time to time imposed restrictions or prohibitions on short selling, and future restrictions could impair a Fund's ability to implement its strategy or require the closing of positions at unfavorable prices.

Use of Derivatives

A Fund may invest in or obtain exposure through derivative instruments, including swaps, options, futures, forwards and other instruments whose value is derived from or related to an underlying security, asset, rate, index or other reference. Derivatives may be used to obtain long or short exposure, implement investment strategies, hedge risks or manage portfolio exposures. The use of derivatives involves risks that may be different from, or greater than, those associated with investing directly in the underlying investments. Derivatives may involve leverage, which can magnify gains and losses, and may expose a Fund to losses exceeding the amount initially invested or committed. Derivative instruments may also be subject to liquidity, valuation, documentation, operational, settlement and counterparty risks. A Fund may be required to post collateral or margin and may be required to provide additional collateral on short notice as a result of market movements or other events. If a counterparty defaults or experiences financial difficulties, a Fund may suffer losses, experience delays in recovering collateral or other assets, or be unable to enter into, terminate or replace transactions on favorable terms. A Fund may have significant exposure to a limited number of counterparties, which may increase these risks.

Options

A Fund may purchase or write put and call options on securities, indices and other instruments for investment, hedging or other purposes. The purchaser of an option may lose the entire premium paid if the option expires without being exercised or otherwise offset. The writer of an option may incur substantial losses if the value of the underlying instrument moves adversely, and the potential loss from writing an uncovered call option is theoretically unlimited. The value of an option may also be affected by changes in the value and volatility of the underlying instrument, the passage of time, liquidity and other market conditions. Options may involve leverage and may result in losses disproportionate to the amount initially invested or received.

Futures and Commodity Contracts

A Fund may invest in futures and other commodity interests. Futures and commodity markets can be highly volatile, and prices may be affected by changing supply and demand relationships, weather, governmental actions and policies, political and economic events, interest rates, inflation, currency movements and other market factors. Because futures contracts generally require the posting of margin representing only a portion of the contract's value, futures trading may involve substantial leverage, and relatively small price movements may result in significant gains or losses. A Fund may also be required to post additional margin on short notice as a result of adverse market movements. Futures and commodity markets may be subject to trading limits, suspensions, position limits, reduced liquidity and other exchange or regulatory restrictions that could prevent or delay a Fund from establishing or liquidating positions at desired prices. A Fund is also subject to risks associated with the exchanges, clearinghouses, futures commission merchants and other intermediaries through which such transactions are effected. These risks could result in substantial losses to a Fund. 27 | P a g e

Structured Investments

A Fund may invest in structured notes and other structured instruments whose returns are linked to one or more securities, funds, indices, loans, credit instruments or other reference assets. Structured investments are subject to the risks associated with the applicable reference asset and may also involve leverage, liquidity, valuation, documentation and counterparty risks. The return on a structured investment may differ from the return that would have been realized through a direct investment in the reference asset, and a Fund may lose some or all of its investment.

Equity Securities

Funds may invest in long and short positions in common stocks, including new issues and secondary offerings, preferred stocks and other equity or equity-linked securities of U.S. and non-U.S. issuers. Funds may also invest in depositary receipts relating to non-U.S. securities. Equity securities may fluctuate significantly in value in response to factors affecting individual issuers, industries or sectors and general market, economic, political and regulatory conditions. Such changes may result in losses to a Fund.

Convertible Securities

Convertible securities have characteristics of both debt and equity securities and may therefore be subject to risks associated with each. Their value may be affected by changes in interest rates, the creditworthiness of the issuer and changes in the value of the underlying equity security. A convertible security may also be subject to redemption by the issuer under its terms, which may require a Fund to convert the security, permit its redemption or sell it at a time or on terms that are unfavorable. These factors may adversely affect the value of a Fund's investment.

Fixed Income Securities

A Fund may invest in fixed income securities and other debt instruments, the values of which may be affected by changes in interest rates, credit conditions and the actual or perceived creditworthiness of the issuer or other obligor. Generally, the value of fixed-rate debt securities tends to decline when prevailing interest rates rise and increase when prevailing interest rates fall, although the sensitivity of particular instruments may vary. A deterioration in the financial condition or creditworthiness of an issuer or obligor may reduce the value or liquidity of an investment and may result in delayed or missed payments of principal or interest or other losses. Certain fixed income instruments, including mortgage-backed and other asset-backed securities, may also be affected by changes in expected cash flows, prepayments, defaults and other characteristics of the underlying assets.

Securitized Credit Products

A Fund may invest in securitized credit products, including asset-backed securities, mortgage-backed securities, collateralized loan obligations and other instruments backed by or providing exposure to pools of loans, receivables or other financial assets. Such investments may be subject to credit, default, prepayment, extension, interest-rate, liquidity, valuation, structural and legal risks. Their performance may depend on the credit performance of the underlying assets, the timing and amount of principal and interest payments, prepayments, defaults and recoveries, the adequacy of collateral and the priority of the applicable instrument within the securitization structure. Certain securitized products may be divided into tranches with different priorities, credit characteristics and exposures to losses, and relatively small changes in the performance of the underlying assets may have a disproportionate effect on more subordinated or leveraged tranches.

Consumer Credit Investments

Certain Funds may invest in consumer loans, receivables and other instruments or arrangements that provide exposure to consumer credit. Such investments are subject to the creditworthiness and payment performance of individual borrowers and may experience increased delinquencies, defaults and losses as a result of unemployment, inflation, changes in interest rates or other economic or borrower-specific conditions. Underwriting and investment decisions may rely on information provided by borrowers, credit 28 | P a g e

reporting agencies, lending platforms and other third parties that may be inaccurate, incomplete or outdated, and consumer credit investments may also be affected by borrower fraud. Consumer credit investments may depend on lending platforms, originators, servicers and other third parties for the origination, administration, servicing and collection of underlying obligations. Failures or disruptions involving such parties may adversely affect collections, enforcement or the value of a Fund's investments. Consumer lending is also subject to extensive federal and state laws and regulations governing the origination, servicing, collection and enforcement of consumer obligations, and changes in or violations of such requirements may adversely affect the enforceability, value or performance of a Fund's investments. Consumer credit investments may also be illiquid, difficult to value and subject to concentration and other risks.

Lower-Quality and Distressed Credit

A Fund may invest in debt or other obligations of issuers or borrowers experiencing financial distress, deterioration in credit quality, default, bankruptcy or restructuring, as well as other lower-rated or unrated credit instruments. Such investments may involve a substantial risk of loss and may be highly speculative, illiquid and difficult to value. An issuer or borrower may be unable to make scheduled payments of principal or interest, and the value of collateral or other assets available to satisfy an obligation may be insufficient. In a restructuring, bankruptcy or other workout, a Fund may incur significant expenses, experience substantial delays in receiving payments or recoveries, receive cash or securities with a value below the amount invested, or lose all or a substantial portion of its investment.

Insurance-Linked Securities

Certain Funds or Fund Accounts invest in insurance-linked securities and reinsurance-related instruments, including catastrophe bonds, collateralized reinsurance, industry loss warranties and similar instruments, the returns of which depend on the occurrence and severity of natural catastrophes or other insured events. A single event or series of events may cause a total loss of principal on affected positions. Such investments rely on catastrophe models, loss estimates, indices and other information concerning the frequency, severity and impact of insured events that may prove inaccurate, including as weather and climate patterns change, and losses may not be determinable for extended periods following an event, during which collateral may be held in trust or otherwise unavailable to the Fund. Insurancelinked instruments may be illiquid, difficult to value and concentrated by peril, region or season, and are subject to the credit risk of ceding insurers, reinsurers, collateral arrangements and related service providers.

Exchange-Traded Funds

A Fund may invest in exchange-traded funds (“ETFs”), which may provide exposure to securities, indices, sectors, commodities or other assets or investment strategies. An ETF is subject to the risks associated with its underlying investments or exposures and may trade at a premium or discount to its net asset value. An ETF may also fail to track its underlying index or other benchmark as intended and may be subject to liquidity and other market risks. A Fund investing in an ETF will indirectly bear its proportionate share of the ETF's fees and expenses in addition to expenses otherwise borne by the Fund.

Special Purpose Acquisition Companies

A Fund may invest in special purpose acquisition companies (“SPACs”), including before a SPAC has identified or entered into an agreement with a prospective acquisition target. SPAC investments are speculative and may involve risks different from investments in operating companies. A SPAC may be unable to identify or complete a suitable business combination within the required period, in which case it may be required to liquidate. A SPAC may have limited operations and may concentrate its assets in a single business following a business combination. The interests of a SPAC's sponsors or management may differ from those of its investors, including because their compensation or investment may depend on completing a business combination. SPAC investments may also be subject to dilution, redemption, liquidity, valuation, regulatory and other risks, and the value of a SPAC or the resulting combined

29 | P a g e

company may decline substantially following a business combination. A Fund may lose some or all of its investment in a SPAC.

Private Investments in Public Equity

A Fund may invest in private investments in public equity (“PIPEs”), which generally involve the private issuance of equity or equity-linked securities by a publicly traded company. Securities acquired in a PIPE transaction may be subject to contractual or legal restrictions on resale and may be illiquid or difficult to value. A Fund may bear the risk of adverse price movements between the time it commits to a PIPE investment and the time the transaction closes and during any period in which the securities cannot be freely sold. The liquidity of a PIPE investment may depend on the issuer satisfying registration or other contractual obligations, and there can be no assurance that such obligations will be satisfied or that registration or other resale rights will result in a liquid market. A Fund may therefore be unable to dispose of a PIPE investment at a desired time or price and may lose some or all of its investment.

Digital Assets and Related Investments

A Fund may obtain exposure to digital assets and virtual currencies through derivatives, investment vehicles or other instruments or arrangements that provide exposure to such assets. Digital assets and related markets may experience significant price volatility, limited liquidity and rapid changes in market conditions. Such exposure may be affected by valuation difficulties, technological developments, cybersecurity incidents, theft or loss of underlying digital assets or access credentials, disruptions or failures involving trading venues, custodians or other service providers, and changes in market acceptance or use. Digital assets and related activities are subject to an evolving legal and regulatory environment in the United States and other jurisdictions. Changes in laws, regulations, regulatory interpretations or enforcement practices may restrict or otherwise affect the issuance, trading, custody, transfer or use of digital assets or the availability of related investment products and markets. Instruments or investment vehicles providing digital-asset exposure may also involve leverage, liquidity, valuation, margin, settlement, counterparty or tracking risks and may not perform in the same manner as the underlying digital asset or market. These and other risks may result in substantial or complete losses to a Fund.

Investments in Non-U.S. Markets

A Fund may invest in securities and other instruments of non-U.S. issuers or in non-U.S. markets. Such investments may involve risks not generally associated with investments in the United States, including differences in accounting, auditing, financial reporting and disclosure standards; less developed or liquid markets; different settlement, custody and market practices; governmental or regulatory restrictions; political, economic or social instability; expropriation or nationalization; capital or currency controls; and difficulties in enforcing contractual or other legal rights. Publicly available information concerning non-U.S. issuers may be more limited than information concerning U.S. issuers, and regulatory oversight and investor protections may differ materially from those in the United States. These risks may be greater in emerging or developing markets.

Currency Risk

A Fund may have exposure to currencies other than its base currency as a result of its investments or trading activities. Changes in currency exchange rates may adversely affect the value of a Fund's investments, income or returns. Certain currencies may be subject to governmental controls, fixed or managed exchange rates, convertibility restrictions or limited liquidity, which may impair a Fund's ability to convert or transfer currency or otherwise manage its currency exposure. Currency hedging, if used, may be incomplete or unsuccessful and may reduce gains or result in additional losses or expenses.

30 | P a g e

Market, Operational, Legal and Regulatory Risks General Economic Conditions

Changes in economic, market, political, regulatory and other conditions, including changes in interest rates, inflation, employment conditions, competition, technological developments, political and diplomatic events and tax laws, can substantially and adversely affect our Funds and their investments. These conditions are outside Lighthouse’s control, and there can be no assurance that Lighthouse or a Portfolio Manager will anticipate such developments or their effects.

Market Risk

The value of a Fund’s investments may increase or decrease as a result of changes in financial markets and other factors affecting particular investments, asset classes or markets. The success of certain investment strategies depends on correctly assessing price movements, market conditions or relationships among investments, and there can be no assurance that Lighthouse or a Portfolio Manager will make such assessments correctly. Market movements may result in substantial losses to a Fund.

Market Disruptions

Financial markets may experience periods of significant disruption, volatility or illiquidity during which historical or expected pricing relationships become materially distorted. During such periods, a Fund may be unable to establish, adjust or liquidate positions at desired prices or may be unable to do so at all. Financing and liquidity available from banks, dealers and other counterparties may also be reduced or become more expensive. Market disruptions may result in substantial losses and may cause investment strategies that historically exhibited lower volatility or risk to perform in unexpected ways.

Inflation Risk

Inflation may adversely affect the value and performance of a Fund's investments. Inflation may reduce the real value of investment returns, adversely affect the value of fixed income securities and increase the operating, financing and other costs of issuers and borrowers. Governmental or central bank actions taken in response to inflation, including changes in interest rates or other monetary or fiscal policies, may also adversely affect financial markets and a Fund's investments. The effects of inflation may vary significantly among different investments, industries and asset classes.

Political and Geopolitical Risk

Political and geopolitical events and developments, including elections, changes in government, armed conflicts, terrorism, trade disputes, tariffs, changes in international relations and governmental or regulatory actions, may create uncertainty or disruption in financial markets or business operations. Such events may affect economic conditions, market prices, liquidity, currencies, interest rates and the ability of Lighthouse, Portfolio Managers, service providers, issuers and other market participants to conduct operations in affected locations, and may adversely affect a Fund's investments.

Public Health Emergencies

Epidemics, pandemics and other public health emergencies may disrupt local, national and global economies and financial markets and adversely affect issuers, counterparties, service providers and other market participants. Such events, and governmental or private-sector responses to them, may result in market volatility or illiquidity, supply-chain and business disruptions, restrictions on travel or other activities and operational disruptions. These effects may adversely affect a Fund's investments or Lighthouse's ability, or the ability of Portfolio Managers and service providers, to conduct Fund activities.

Suspensions of Trading

Securities, futures and other markets or exchanges may suspend or limit trading in particular instruments or more broadly as a result of market conditions, regulatory actions, exchange rules or other events. Such restrictions may prevent or delay a Fund from establishing, liquidating or adjusting positions and may result in a Fund being unable to limit losses, realize gains or otherwise implement its investment strategy at desired times or prices. 31 | P a g e

Sanctions Risks

The Funds and their investment activities are subject to economic and trade sanctions and other restrictions imposed by the United States and other applicable jurisdictions. Such sanctions may prohibit or restrict investments in or transactions involving particular countries, regions, entities, individuals, securities or other assets, and the scope or application of sanctions may change, sometimes with limited notice. If an existing investment becomes subject to applicable sanctions, a Fund may be required to divest or freeze the investment, cease further dealings, or take other actions required by applicable law. A Fund may also be unable to dispose of or otherwise transact in a sanctioned investment for an extended period. These restrictions may adversely affect the value or liquidity of an investment, prevent a Fund from pursuing an investment opportunity or require a Fund to liquidate an investment at an unfavorable time or price.

Outbound Investment Rule

U.S. regulations concerning outbound investments prohibit or require notification of certain transactions by U.S. persons involving persons or entities associated with China, including Hong Kong and Macau, that engage in specified activities relating to semiconductors and microelectronics, quantum information technologies and artificial intelligence. These restrictions may also apply in certain circumstances to investments involving non-U.S. investment vehicles. Certain prospective investments by a Fund may therefore be prohibited, subject to notification requirements or otherwise restricted. Lighthouse may decline, limit, restructure or dispose of an investment, or take other actions it considers necessary or appropriate to comply with applicable outbound investment requirements. These requirements may limit investment opportunities available to a Fund and may change over time.

Misuse of Confidential Information

Lighthouse, Portfolio Managers and other persons involved in a Fund's investment activities may from time to time receive material nonpublic or other confidential information. Possession of such information may restrict a Fund's ability to purchase, sell or otherwise transact in certain investments. The misuse of such information could also result in regulatory investigations, litigation, penalties, reputational harm or other adverse consequences to Lighthouse, a Portfolio Manager or a Fund.

Litigation Risk

Lighthouse and the Funds may from time to time become involved in litigation, regulatory proceedings or other disputes arising from their operations or investment activities. Such matters may result in legal expenses, damages, settlements, penalties, restrictions or other adverse consequences and may divert the time and attention of Lighthouse personnel. There can be no assurance that any such matter will be resolved favorably or without adversely affecting Lighthouse or a Fund.

Systems and Operational Risks

Lighthouse, the Funds, Portfolio Managers and their service providers rely on information technology, communications, trading, accounting and other operational systems to conduct their activities. These systems may experience failures, disruptions, errors, capacity constraints or other problems as a result of technological failures, human error, third-party failures, natural disasters or other events. Such events may impair the ability to execute or settle transactions, value investments, maintain records, communicate with counterparties or investors, or otherwise conduct Fund activities and may result in financial losses, regulatory consequences or other adverse effects. Lighthouse and other relevant parties maintain business continuity and other measures designed to address certain operational risks, but such measures may not prevent or mitigate all failures or disruptions.

Cyber Security Breaches and Identity Theft

Cybersecurity incidents and cyber-attacks are an ongoing and evolving risk to Lighthouse, the Funds, Portfolio Managers, service providers and other parties on which they rely. The information and technology systems of Lighthouse, the Funds, Portfolio Managers, service providers and their respective investments may be vulnerable to cyber-attacks, unauthorized access or use, malware, system or 32 | P a g e

network failures, telecommunications failures, human error, power outages, natural disasters and other events. Although Lighthouse maintains policies, procedures and other measures designed to manage cybersecurity and information-security risks, no such measures can eliminate these risks. If information or technology systems are compromised, become unavailable or cease to function properly, Lighthouse, the Funds and/or their investments may incur costs to respond to or remediate the incident and may experience significant operational disruptions. Such events may also result in the unauthorized access to or use of confidential or sensitive information, including personal information relating to investors or their beneficial owners, and could result in financial losses, legal or regulatory consequences, reputational harm or other adverse effects on Lighthouse or a Fund.

Combination of Risk Factors

The risks described above are not mutually exclusive and may occur simultaneously or interact with one another. The combination of multiple risk factors may increase the likelihood or magnitude of losses to a Fund, and the effect of such risks may be greater than would be expected from any individual risk considered separately. See each Fund’s offering document or relevant constitutional document for additional Fund-specific risk factors.

Lighthouse has entered into and may from time to time enter into co-advisory arrangements with unaffiliated investment advisers to jointly manage certain Funds or to provide limited scope advisory services. In some cases, these arrangements involve shared responsibility for investment management and related services; in others, Lighthouse’s role may be to primarily provide Platform Services. These relationships create potential conflicts of interest, including allocation of investment opportunities, resources, and expenses between the co-advisers’ respective clients. There is no guarantee that such arrangements will be successful or that the roles of the co-advisers will result in achieving the Fund’s investment objectives. Additional risks include: • •

Resource Allocation Risk: Each co-adviser may be unable to devote sufficient time and resources to the Fund. Delegation Risk: Investment and trading responsibilities may be delegated to an Investment Committee or other body, which may not successfully execute the overall strategy. 33 | P a g e

•

Termination Risk: If the co-advisers terminate their arrangement, the Fund may experience significant operational and strategic consequences, including potential cessation of operations, which could result in material losses to investors.

Lighthouse employees may constitute significant investors in certain Funds. Additionally, certain Funds are majority or wholly owned by Lighthouse and Lighthouse employees. Lighthouse may be viewed as having an incentive to favor those Funds in which Lighthouse employees invest. Lighthouse has adopted procedures and controls that are intended to ensure that no investors or Funds are favored over others. Lighthouse and its subsidiaries serve as the general partner or manager of the U.S.-domiciled Funds. Lighthouse and its subsidiaries serve as investment manager of the non-U.S. Funds. We do not receive any compensation from Portfolio Managers in connection with our Funds’ investments, and in the event we engage in any seeding transactions, the proceeds of any such transaction shall inure solely to the benefit of the Lighthouse Funds (i.e., Lighthouse Funds may receive a profit allocation from a Portfolio Manager’s investment management business). Certain personnel of Lighthouse serve as directors of Funds. These personnel do not receive compensation for their service as directors. Certain personnel of Lighthouse also serve as directors to MSW Director Services Limited, a wholly owned subsidiary of Lighthouse and a Cayman Islands exempted company that serves as corporate director to certain Funds. These personnel do not receive compensation for their services as directors of MSW. NGI, OWL or their affiliates own passive minority ownership stakes in certain alternative asset managers. Lighthouse may cause our Funds to invest with managers or their funds that are sponsored by NGI, OWL or their affiliates. In such case, the Funds will bear the fees and expenses incurred by investing with such managers, including asset- and/or performance-based compensation payable to NGI and/or OWL or their affiliates. Lighthouse will be subject to a conflict of interest in causing the Funds to make such investments given its affiliation with OWL and NGI. Longreach Alternatives Ltd. (“LRA”) is an Australia-based alternative asset management firm that is an affiliate of Lighthouse as a result of NGI being a greater than 25% shareholder of LRA. LRA maintains an Australian financial services license and provides investor distribution and client servicing support to Lighthouse. Lighthouse may compensate LRA in the future by paying an ongoing fee that comprises a portion of Lighthouse’s Management and/or Performance Fees. Lighthouse’s compensation to LRA would not increase the compensation earned by Lighthouse in respect of any investor solicited by LRA. Prospective investors introduced by LRA are informed of the affiliation between Lighthouse and LRA. LRA may sponsor and/or serve as a distributor to unaffiliated investment vehicles established by LRA or third parties for Australian and New Zealand investors to access certain of our Funds. Lighthouse is also affiliated with Ashmere Limited; LH PAMLI Partners GP LLC; and LH PAMLI Partners GP Ltd. These entities serve as general partners to Funds structured as Cayman Islands and Delaware limited partnerships. Lighthouse has two wholly owned affiliates which provide investment management or research services directly to Lighthouse: Lighthouse Partners UK, LLC, headquartered in London, and Lighthouse Partners HK Limited, headquartered in Hong Kong. Lighthouse’s Relying Advisers are listed below, together with any applicable foreign licenses or registrations:

North Rock, a Delaware limited liability company that manages a multi-portfolio manager long/short equity focused strategy.

34 | P a g e

North Rock Capital Management (UK) LLP (“NR UK”), a United Kingdom limited liability partnership that serves as a sub-investment manager of the North Rock strategy. NR UK is authorized by the United Kingdom Financial Conduct Authority as a MiFIDPRU investment firm. North Rock Capital Management (HK) Limited (“NR HK”), a Hong Kong limited company that serves as a sub-investment manager of the North Rock strategy. NR HK is licensed by the Hong Kong Securities and Futures Commission to conduct regulated activities in Dealing in Securities and Asset Management. North Rock Capital Management (SG) Pte. Ltd (“NR SG”), a Singapore private limited company that serves as a sub-investment manager of the North Rock strategy. NR SG is licensed by the Monetary Authority of Singapore as a Capital Markets Services Licensee for Fund Management. North Rock Capital Management (DIFC) Limited (“NR DIFC”) is a private limited company incorporated in the Dubai International Financial Centre that serves as a sub-investment manager of the North Rock strategy. NR DIFC is authorized by the Dubai Financial Services Authority as a Category 3C Firm. Mission Crest, a Delaware limited liability company that manages a multi-portfolio manager global macro-focused strategy. Pier61 Partners, LLC, a Delaware limited liability company that manages a multi-portfolio manager strategy focused on opportunities influenced by climate, energy, and global public policy. LHP Ireland Fund Management Limited (“LHP Ireland”), an Irish private limited company that manages the assets of certain Ireland-domiciled Funds. LHP Ireland is authorized by the Central Bank of Ireland as an alternative investment fund manager. Lighthouse Partners (DIFC) Limited (“Lighthouse Dubai”) is a private limited company incorporated in the Dubai International Financial Centre. Lighthouse Dubai is authorized by the Dubai Financial Services Authority as a Category 4 Firm. Penglai Peak Capital Management, LLC, a Delaware limited liability company that manages a multiportfolio manager long/short strategy focused on Japan. LH Penglai Peak Ltd. (“Penglai Peak Japan”), a Japanese company registered with the Kanto Local Finance Bureau as an Investment Management Business Operator under the Financial Instruments and Exchange Act of Japan. Penglai Peak Japan serves as a sub-investment manager of the Penglai Peak strategy. LH Credit Partners LLC (“LH Credit”), a Delaware limited liability company that operates a consumer credit focused strategy. See LH Credit below. LH PAMLI Partners LLC, a Delaware limited liability company that manages a credit convexity focused strategy. Lighthouse Omphalos Partners, LLC (“LH Omphalos”), a Delaware limited liability company that manages an AI-powered long/short strategy. See LH Omphalos below.

LH Credit operates as a Relying Adviser under Lighthouse and manages a strategy focused on consumer-credit through dedicated Funds. The strategy is intended to concentrate on consumer receivables generated through lending platforms that have bank partner arrangements with DR Bank, a state-chartered non-member bank regulated by the State of Connecticut Department of Banking and the Federal Deposit Insurance Corporation, but may diversify its holdings across lending platforms over time. While Lighthouse and DR Bank are not affiliated, certain personnel involved in the management of the strategy have outside relationships with DR Bank. In particular, certain personnel employed or affiliated with DR Bank, including the Chairman of the Board of DR Bank and the largest shareholder of DR Bank’s holding company, have been seconded to LH Credit and have day-to-day portfolio management responsibilities. The portfolio management personnel will devote such reasonable time and efforts to the business, purposes and activities of LH Credit as determined to be necessary for the dedicated Funds to achieve their business objectives. However, such personnel currently conduct, and may in the future conduct, other business, including any business within the asset management and/or consumer lending industry, including, but not limited to, continuing to provide services to DR Bank, in an employment, board member and/or advisory capacity and, in such capacities, will have ongoing responsibilities and obligations (including fiduciary obligations) to DR Bank. Further, certain personnel of Lighthouse, including Lighthouse’s Founder and Chief Executive Officer, are shareholders in DR Bank and its affiliates. These relationships and ownership interests could influence the decision-making process of 35 | P a g e

such personnel, including decisions related to investments, counterparties, allocation of certain costs incurred by DR Bank in connection with the issuance of consumer receivables purchased by the dedicated Funds, or other transactions involving DR Bank. Lighthouse believes that the conflicts relating to existing and future DR Bank relationships are mitigated, in part, by the incentive compensation structure of the dedicated Funds which can serve to align the interest of LH Credit personnel with the overall performance of the dedicated Funds, rather than with any specific external entity. LH Omphalos operates as a Relying Adviser under Lighthouse and manages the Omphalos Funds. LH Omphalos is jointly owned by Lighthouse, which holds a majority interest; an unaffiliated technology provider that provides AI-related services to LH Omphalos; and a vehicle owned by certain Lighthouse executive officers and other management personnel. These ownership interests present conflicts because certain Lighthouse personnel may benefit economically from the activities of LH Omphalos and the technology provider is both an owner of and service provider to LH Omphalos. Lighthouse addresses these conflicts under the policies described in Items 6 and 11.

Through regular reporting and/or obtaining pre-approval from the Lighthouse Chief Compliance Officer (“CCO”), employees are subject to various policies that govern, among other things, employee securities transactions, gifts, and entertainment, outside business activities, confidentiality of information, and charitable and political contributions. The Code strictly prohibits the misuse of material non-public information. At the beginning of employment and annually thereafter, each Lighthouse employee must acknowledge the terms of the Code and receive training on the various obligations under it. Any employee who violates the Code will be subject to disciplinary action up to and including termination. All employees are obligated to report any violations of the Code to the CCO. The CCO and compliance staff conduct testing and monitoring of various procedures under the Code and provide an annual report to Lighthouse’s senior management on the effectiveness of these policies and procedures.

Participation or Interest in Client Transactions Lighthouse and Lighthouse-qualified employees (subject to pre-approval requirements) may invest in certain Funds and in certain underlying securities in which investors also invest indirectly through the Funds, and certain Lighthouse employees hold ownership interests in Lighthouse affiliates, as described in Item 10. In addition, Lighthouse serves as the general partner and manager of the U.S. Funds. The investments and interests of Lighthouse employees and Lighthouse's status as the general partner and manager of the U.S. Funds could be viewed as creating a conflict of interest because Lighthouse and its employees may have an incentive to act in its interest or their own self-interest as opposed to that of the applicable Fund. However, the Code, as described above, and various other compliance policies and procedures, such as our allocation policy, are intended to ensure the mitigation of the risk that any Fund is favored over another.

36 | P a g e

Lighthouse may cause a Fund to purchase, sell, or transfer interests in a Fund or Unaffiliated Funds from or to another Fund when Lighthouse believes that those transactions are appropriate and in the best interest of those Funds. Any such purchase, sale, or transfer will take place at the stated net asset value of the interests being purchased, sold, or transferred. In addition, Lighthouse may recommend that a Fund purchase or sell an investment that is being sold or purchased, respectively, at the same time by Lighthouse, Lighthouse’s affiliates, officers, employees, or another advisory client. In addition, under certain circumstances, employees may hold personal investments in the same portfolio securities that Lighthouse clients hold. These personal investments could be in the same security or in different parts or issues of the same issuer’s capital structure. Lighthouse, as a fiduciary, endeavors to always make decisions in the best interest of clients if a conflict of interest arises. If any such investment(s) poses a conflict of interest, Lighthouse will seek to act in a way that favors the interest of clients. There could also be various reasons such as investment or risk guidelines, trading restrictions, entry point, investment time horizon, estate planning, or tax consequences that may cause Lighthouse personnel to transact contrary to Lighthouse clients in common investments. In relation to cross trades and those simultaneous purchases and sales, Lighthouse may have a conflict of interest between acting in the best interest of that Fund and assisting another Fund by selling or purchasing a particular Fund investment or Unaffiliated Fund interest. Lighthouse does not typically engage in principal transactions with our Funds; however, on occasions when such transactions occur, Lighthouse obtains any required client consents in accordance with applicable law. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker‐dealer, buys from or sells any security to any advisory client. A principal transaction also may be deemed to occur if Lighthouse and Lighthouse subsidiaries own a substantial portion of a Fund, and that Fund participates in a purchase or sale transaction with another Fund. Any principal or cross trade will be effected in accordance with applicable law and Lighthouse's policies and procedures, including applicable approval, pricing and consent requirements. Lighthouse also has adopted compliance policies and procedures designed to ensure that, over time, all our Funds are treated fairly in allocation and redemption opportunities (see Item 6). Certain officers of Lighthouse serve as directors of the non-U.S. Funds, and these officers are not compensated for their service as directors. Under certain circumstances, we may determine that Lighthouse or one of our employees or certain affiliates has obtained, or may have obtained, material non-public information. Lighthouse maintains a “restricted list” that is designed to prevent our clients, officers, and employees from engaging in insider trading. Lighthouse and its affiliates’ use of a restricted list and caution in connection with potential exposure to material non-public information may limit clients’ investment opportunities. Lighthouse employees may benefit from educational events sponsored by industry service providers such as prime brokers, administrators, law firms, audit firms, and such other professional service firms.

and difficulty of execution; speed of execution, expertise with difficult securities, the financial strength, integrity and stability of the broker-dealer; the quality, comprehensiveness, and frequency of related services considered to be of value; the competitiveness of commission rates in comparison with other broker-dealers satisfying our selection criteria, responsiveness, and frequency of errors. Accordingly, if we determine that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the brokerage and products or services provided by such broker-dealer, the Fund may pay commissions to such broker-dealer in an amount greater than the amount another broker-dealer 37 | P a g e

might charge for effecting the same transaction. We may benefit indirectly from payments made by a client (including payments by way of “soft dollars”) as described further below. With respect to our North Rock Platform Hedge Fund, we receive research, brokerage, or other products or services other than executions from a broker-dealer and/or a third party in connection with securities transactions. This is known as a soft dollar relationship. We have also established commission sharing arrangements (“CSAs”) with various broker-dealers and use a commission management service to assist in administering soft dollar payments to third-party research providers that are paid with soft dollars. We have entered into such arrangements where we believe that it is administratively or operationally expedient to do so or where such an arrangement is more favorable to the client than an arrangement under which the client pays for the products or services in question with hard dollars. However, such arrangements may present conflicts in allocating expenses and make it more difficult for investors to evaluate the cost structure of a client because the costs of such products or services are not broken out separately. Lighthouse limits the use of soft dollars to obtain services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended. Research and brokerage services Lighthouse receives include but are not limited to research reports on particular industries and companies, economic and industry surveys and analyses, recommendations as to specific securities, certain financial newsletters and trade journals, software providing analysis of securities portfolios, attendance at certain seminars and conferences, discussions with research analysts, meetings with corporate executives, data services (including services providing market and alternative data, news data, company financial data, and certain valuation, pricing, and economic data), consulting services regarding products, technologies, issuers, or industries, market risk data, advice on portfolio strategy, financial database software and services, advice from brokers on order execution, as well as other products and services that provide assistance in the performance of investment and trading decision-making responsibilities, services related to trade execution, including effecting securities transactions, messaging and connectivity services used to transmit orders, commission management services, including trade recordkeeping and reporting, and clearing and settlement of securities and functions incidental thereto. Where a product or service provided has both “eligible” uses under Section 28(e) (i.e., uses related to Lighthouse’s investment decision-making process) but also has other uses, Lighthouse will make a reasonable allocation between the eligible and “non-eligible” uses and will use soft dollars only for the eligible portion. Lighthouse and Portfolio Managers also receive products or services that may have multiple uses or that benefit more than one Sub-Account, and in some instances all or a portion of the products or services received are eligible under the Section 28(e) safe harbor. Lighthouse allocates the cost of any mixed-use products or services between hard dollars and soft dollars and among Sub-Accounts in good faith. In making good faith allocations of costs between non-eligible administrative benefits and eligible research and brokerage services, a conflict of interest exists by reason of Lighthouse’s allocation of the costs of such benefits and services between those that primarily benefit Lighthouse and those that primarily benefit the client. Our use of soft dollars presents a potential conflict of interest because Lighthouse is effectively using client assets to pay for research that we might be able to generate internally or would otherwise have to purchase. Soft dollar arrangements also provide an incentive to select or recommend a broker-dealer based on an interest in receiving research or other products or services, rather than on receiving the most favorable execution. Soft dollar arrangements may cause the Fund to pay commissions (markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as “paying-up”). As previously mentioned, Lighthouse considers the amount and nature of research services provided by broker-dealers, as well as the extent to which such services are relied upon and attempts to allocate a portion of the brokerage business of clients on the basis of that consideration. In addition, broker-dealers sometimes may suggest a level of business that they would like to receive in return for the various services provided. Actual brokerage business received by any broker-dealer may be less than the suggested allocations but can (and often does) exceed the suggestions because total brokerage is allocated on the basis of all the considerations described above. A broker-dealer is not excluded from receiving business because it has not been identified as providing research services. Periodically, we consider the amount and nature of research and brokerage services provided by broker-dealers, as well as the extent to which such services are relied upon, and we attempt to allocate a portion of the brokerage business of the clients on the basis of that consideration. Research and brokerage services 38 | P a g e

obtained by the use of commissions arising from a client’s portfolio transactions may be used by Lighthouse in its other investment activities. Research and brokerage services obtained by the use of commissions arising from a client’s portfolio transactions generally benefit the respective client though they typically benefit Lighthouse and certain third-party Portfolio Managers as well. In some cases, such as at the end of a calendar year or when an account closes, certain brokers may provide a cash refund of unused soft dollar credits. In such case, Lighthouse intends to credit the refund to the corresponding client. Lighthouse maintains policies and procedures to review the quality of executions, including periodic reviews by our trading and investment professionals of our brokerage and counterparty relationships. A “trade error” is generally considered to include an error that (i) prevents portfolio trading instructions given by a Portfolio Manager on behalf of a client from being substantially effectuated in the manner intended by the Portfolio Manager; (ii) results in the execution of a trade on behalf of a client that was not intended for that client; or (iii) causes a violation of any applicable investment guideline or restriction. Depending on the relevant facts and circumstances, other events might also be considered trade errors. Lighthouse seeks to detect trade errors prior to settlement and to correct and/or mitigate them in an expeditious manner. Generally, gains and losses attributable to trade errors will be borne by clients. However, if the error was caused by Lighthouse’s willful misconduct, recklessness, or gross negligence, then Lighthouse will bear the costs of the error. Lighthouse has a conflict of interest in determining whether an error has occurred or was caused as a result of willful misconduct, recklessness, or gross negligence. To the extent an error is caused by a third party, such as a broker, Lighthouse will seek to recover any losses associated with the error from that third party. However, there is no guarantee that Lighthouse will be able to do so. Lighthouse will not use soft dollars or commitments of future brokerage business to compensate any broker-dealer for absorbing the cost of a trade error. Lighthouse or our subsidiaries may receive introductions to Fund investors through broker-dealers that are prime brokers or who execute trades on behalf of Lighthouse. Lighthouse does not believe that it pays any additional fees or higher commissions as a result of these introductions. Lighthouse seeks the best execution on all transactions. However, Lighthouse may have an incentive to select or use an executing or prime broker based on Lighthouse or an affiliate receiving Fund investor referrals from that counterparty. Lighthouse does not consider client or Fund investor referrals from broker-dealers when making brokerage allocation decisions. Where a Relying Adviser manages more than one Fund or account pursuing the same or a similar investment strategy, Lighthouse may aggregate orders and determine an allocation method for the aggregated orders, subject to treating the participating Funds and accounts fairly. Lighthouse is not obligated to aggregate orders, and where orders are not aggregated, participating Funds and accounts may receive different prices for the same security and bear higher transaction costs than if orders had been combined. As it relates to our Platform Hedge Funds, third-party Portfolio Managers generally do engage in brokerage activities (e.g., direct brokerage transactions or have soft dollar arrangements). As part of the Lighthouse due diligence process on Portfolio Managers, Lighthouse reviews the brokerage practices and soft dollar arrangements of the third-party Portfolio Managers. Lighthouse selects the prime brokers and swap counterparties of our Funds in consultation with the Portfolio Manager, based on such factors as the prime broker or counterparty’s overall performance, pricing, operational capabilities, and financial stability. Lighthouse negotiates the terms of the fees and commissions each Fund will pay to each applicable prime broker. Under the terms of each Subadvisory Agreement between a third-party Portfolio Manager and a Fund, each Portfolio Manager is responsible for arranging for the execution of all orders for the purchase and sale of securities and other investments with respect to the applicable Fund. The Portfolio Manager is required to seek the best execution for that Fund. The Portfolio Manager, to the extent permitted by applicable laws and regulations, may aggregate the investments to be purchased or sold on behalf of its clients to attempt to obtain a more favorable price, lower brokerage commissions, or most efficient execution. Portfolio Managers may engage in soft dollar practices whether or not such practices fall within the soft dollar safe harbor established by Section 28(e) of the Securities Exchange Act of 1934, as 39 | P a g e

amended. For instance, a Portfolio Manager could receive “brokerage and related services” covered by such safe harbor as well as office space, overhead expense reimbursement, and similar benefits not covered by such safe harbor. Lighthouse conducts hedging in relation to certain of our Fund share classes that are denominated in a foreign currency. Lighthouse may also deem it advisable for a Fund to take a direct position in a security, currency, over-the-counter derivative, or futures product for hedging or portfolio reallocation purposes. If Lighthouse terminates a Portfolio Manager’s investment authority over a Fund, Lighthouse may cause such Fund to trade securities, futures, or other financial instruments it holds, typically by liquidating them as promptly as Lighthouse deems advisable under the circumstances or by hiring a third party to do so. Finally, Funds may buy or sell interests in Unaffiliated Funds through secondary market transactions. Lighthouse does not request, require, or recommend an investor to direct brokerage transactions to specific brokers or dealers. Lighthouse does not select or recommend brokers or dealers based on whether they refer investors to Funds.

Reports to Investors Each investor in a Fund receives monthly account statements, depending on the terms specific to that Fund, which provide beginning and ending balances as well as a description of account activity. Statements are either delivered by mail or as elected by an investor, by an email notification that the statements are available on the administrator’s website. In limited circumstances where onshore investors have opted to receive their statements in hardcopy format via mail, statements are distributed monthly. Certain investors or their advisors receive performance estimates and monthly risk reports of various Funds via email monthly. Similarly, Lighthouse also distributes weekly performance estimates for certain Funds via email. On a monthly and/or quarterly basis, Lighthouse also prepares commentary on overall investment performance that is sent to various investors or their advisors. On a quarterly basis, senior investment staff conduct conference calls providing investment commentary on certain of our products and hedge fund strategies, providing general investment commentary to various investors and their advisors. The reporting that is in addition to the monthly account statements described above is also made available to investors or their advisors upon request. Each investor in a Fund also receives audited financial statements on an annual basis. In the case of Funds that are organized as partnerships for U.S. tax purposes, as soon as reasonably practicable after the end of each calendar year, Lighthouse delivers to each person who was an investor in the Fund at any time during such calendar year such tax information and schedules relating to the Fund as are necessary for the preparation by the investor of its federal income tax returns. However, Lighthouse does not assume responsibility for tax reporting errors or delays on the part of the Unaffiliated Funds. Further, a Fund that is organized as a partnership for U.S. tax purposes may not be able to complete and file its partnership income tax return for any year or deliver a Schedule K-1 for such year to each of its investors until the Fund has received tax information for that year from the Unaffiliated Funds in which it invests. Because certain Unaffiliated Funds in which a Fund may invest are calendar-year taxpayers, and due to the time needed for the preparation of income tax returns, Lighthouse is ordinarily not able to send a Schedule K-1 to each investor in time to file the investor’s income tax returns by the original due date. In such cases, Lighthouse can provide investors with tax estimates prior to issuing a 40 | P a g e

Schedule K-1, and it is usually necessary for each investor to obtain an extension of the filing date for its return for such year.

Lighthouse may pay a retrocession fee in an amount equal to all or part of the management fee and/or performance‐based compensation to third-party placement agents for assisting in the placement of interests in a Fund. The payment of the retrocession fee by Lighthouse to a third-party placement agent does not increase the compensation earned by Lighthouse in respect of any investor solicited by a third-party placement agent. However, in certain circumstances, placement agents have an agreement with an investor to be compensated by receiving an upfront selling commission from the investor’s subscription amount. Any solicitation agreement with placement agents is in writing and in compliance with applicable securities laws. The payment of retrocessions may cause a placement agent to recommend one Fund over another adviser that does not pay such compensation. In any case in which a placement agent receives payment from Lighthouse, the placement agent will have a conflict in advising investors with respect to subscriptions and withdrawals. Further, placement agents may receive different amounts of compensation with respect to different Funds and therefore could have incentives to favor one or more products over others. The Funds also use placement agents some of which may be affiliated with Fund investors or brokerdealers or prime brokers that service the Funds. Placement agents receive compensation from Lighthouse in connection with investors referred by them. Placement agents that solicit or refer potential investors to Funds are subject to a conflict of interest because they will be compensated in connection with their solicitation activities. Investor referrals or an investment from an entity or affiliate that serves as an executing or prime broker may also create a conflict of interest in that such may create an incentive for Lighthouse to direct additional brokerage to these entities or an affiliate. As mentioned in the Brokerage Practices section above, Lighthouse does not consider client or investor referrals when selecting trading counterparties. Lighthouse also has policies and procedures designed to seek the best execution on all transactions and periodically monitors and evaluates service providers.

Other Compensation Lighthouse does not permit Lighthouse employees to receive any form of compensation, including cash, sales awards, or other prizes, from non-clients for providing advisory services to our Funds. Lighthouse maintains written policies and procedures with respect to the giving and receipt of gifts and entertainment and the giving of donations and contributions, which are reasonably designed to comply with applicable law, including pay-to-play restrictions. Those policies and procedures may prohibit giving or receiving gifts, entertainment, donations, and contributions under certain circumstances (e.g., lavish or excessive). Lighthouse also receives investor referrals from unaffiliated consultants and wealth advisers that are retained by investors. Lighthouse does not compensate these parties for such referrals but may enter into

41 | P a g e

agreements with them to reduce management and performance fees paid by their clients based on their clients’ aggregate investments in our Funds.

generally accepted accounting principles; and (ii) audited by an independent public accountant that is registered with and subject to regular inspection by the Public Company Accounting Oversight Board.

For the majority of such assets, however, Lighthouse maintains authority to terminate a Portfolio Manager’s investment authority on behalf of the Fund. With respect to a portion of the assets of a Custom Fund and certain Funds managed under Lighthouse Platform Services offerings, Lighthouse does not have the authority to terminate a Portfolio Manager's investment authority without requisite approval, or acts subject to the direction of the Fund's unaffiliated investment manager, and therefore treats such arrangements as non-discretionary for this purpose. For Fund Accounts, Lighthouse maintains discretionary authority but delegates the day-to-day investment activity to Portfolio Managers who are subject to investment guidelines set forth in the respective Subadvisory Agreement.

With respect to circumstances where Lighthouse trades equities directly, Lighthouse would vote in a manner that it believes reasonably furthers the best interest of the Funds and is consistent with the investment objectives as set forth in the relevant investment management documents. Lighthouse may abstain from voting if it deems that abstaining is in a Fund’s best interest. For example, Lighthouse may abstain from voting proxies where (i) clients no longer hold the securities at the time of the vote (whether or not they held them on the record date of the vote), (ii) Lighthouse, on behalf of clients, has a net short position in such issuer, or (iii) the proxy involves “share blocking,” or similar measures that could limit Lighthouse’s ability to sell the affected security during a blocking period. There may also be times when 42 | P a g e

refraining from voting is in the best interest of clients, such as when analysis of a proxy reveals that the cost of voting the proxy may exceed the expected benefit to clients. For example, Lighthouse may elect not to vote all proxies or acknowledge a Portfolio Manager’s policy of not voting all proxies, for certain portfolios when it determines that the success of the portfolios’ investment strategy is not dependent on the outcome of proxy contests, such as with certain quantitative strategies with short-term holding periods. Because Lighthouse does not feel it is in our clients’ best economic interest, Lighthouse also does not anticipate attempting to recall shares that have been lent or rehypothecated in order to participate in proxy voting. We will reasonably try to assess whether Lighthouse is subject to any material conflict of interest in connection with proxies. If it is determined that a conflict of interest is material, one or more methods may be used to resolve the conflict. These include disclosing the conflict to the relevant client and obtaining its consent before voting; suggesting to the relevant client that it engages another party to vote the proxy on its behalf; consulting with an unaffiliated third party (e.g., a proxy voting service) to recommend a vote with respect to the proxy, based on application of the policies set forth herein; or such other method as is deemed appropriate by Lighthouse under the circumstances given the nature of the conflict. Portfolio Managers typically have authority to vote proxies in the best interest of their Sub-Account; therefore, at times, a Lighthouse client may vote the same proxy differently when multiple Portfolio Managers vote the respective proxy. For certain Platform Hedge Funds, Lighthouse has engaged a third-party proxy voting service to assist in the administration of its proxy voting responsibilities and provide proxy voting recommendations. A review and agreement of general voting guidelines and policies has been established between Lighthouse and the proxy voting service provider. Lighthouse also periodically reviews the proxy voting service provider’s voting guidelines and processes. The proxy voting firm pre-populates each client’s votes with the proxy voting service’s recommendations and automatically submits the Fund’s votes. Pre-population and automated voting generally occur prior to the submission deadline for proxies to be voted on at the shareholder meetings and Lighthouse relies on the proxy voting service to ensure soliciting materials that are received close to the submission deadline are incorporated into voting recommendations and Lighthouse’s votes. Lighthouse will generally vote in line with the recommendations of the proxy voting service in accordance with their voting guidelines and recommendations. Should a situation arise where Lighthouse or a Portfolio Manager believes voting in a manner other than agreed upon in the guidelines, or abstaining from a vote, is in the best interest of its clients, Lighthouse will exercise its discretion to vote or abstain accordingly. With respect to voting regarding Unaffiliated Funds, in evaluating these proxies, Lighthouse considers numerous factors relating to each investment and makes an independent determination whether to support or oppose a proposal from a third-party Portfolio Manager. Lighthouse also has procedures to ensure a proxy is voted in our Funds’ best interest in the event a proxy vote creates a material conflict between the interests of Lighthouse and our Funds. Third-party Portfolio Managers of our Funds are required to have a proxy voting policy and vote proxies pursuant to the applicable Subadvisory Agreement. Lighthouse has also adopted procedures and retained the services of a third-party service provider to facilitate the submission of claims in class actions involving securities held by Lighthouse clients. When Lighthouse participates in a class action lawsuit and later receives any recovery amounts, those amounts will generally be credited to the participating clients at the time the recovery amounts are received. A copy of the Lighthouse proxy voting policies and procedures is available to investors upon request.

43 | P a g e