Senvest Management, LLC: investment adviser

(Collectively, the Master Fund General Partner, the Cyprus General Partner and the Senvest Technology General Partner are referred to as the “Fund General Partners”). The Master Fund General Partner and the Senvest Technology General Partner are limited liability companies organized under the laws of the state of Delaware. The Cyprus General Partner is a Cayman Islands exempted company. The Fund General Partners are affiliates of the Adviser and serve or may serve as the general partner of Funds that are U.S. or non-U.S. partnerships. The Fund General Partners’ facilities and personnel are provided by the Adviser or Senvest Capital (as defined below). Mr. Mashaal is the majority owner of and controls the Master Fund General Partner and the Senvest Technology General Partner. Mr. Mashaal jointly owns the Cyprus General Partner with Senvest Capital and Mr. Gonick. Mr. Mashaal controls the Cyprus General Partner. Senvest is affiliated with Senvest Capital Inc. (“Senvest Capital”), a Canadian public company that trades on the Toronto Stock Exchange. Richard Mashaal serves as joint President and Chief Executive Officer of Senvest Capital, and George Malikotsis, Chief Financial Officer of the Adviser, serves as joint President and Chief Executive Officer. Both Richard Mashaal and George Malikotsis serve on the board of Senvest Capital. Senvest Capital is the largest investor in the Funds (as defined below) and acted as the seed investor for Senvest. Certain employees of Senvest Capital are supervised persons of Senvest and are compensated for such services by Senvest Capital. All Senvest Capital employees that provide services to Senvest are treated as access persons of Senvest and are subject to Senvest’s Code of Ethics. Senvest has its principal place of business in New York, with offices in California, Montana, Florida, and Québec. Senvest Capital is based in Montreal, Québec. Certain employees of Senvest Capital who are supervised persons of the Adviser are based in Montreal. Senvest Capital has no US operations. Senvest serves as the investment adviser, with discretionary trading authority, to several private pooled investment vehicles, the securities of which are offered to Investors (as defined below) on a private placement basis (each, a “Fund” or collectively the “Funds”). The Funds include:

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Senvest Partners, LP, a Delaware limited partnership;

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Senvest Partners, LTD, a Cayman Islands exempted company;

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Senvest Master Fund LP, a Cayman Islands exempted limited partnership, which serves as the master fund into which Senvest Partners, LP and Senvest Partners, LTD invest substantially all of their assets through a “master feeder” structure;

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Senvest Cyprus Recovery Investment Fund, LP, a Cayman Islands exempted limited partnership;

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Senvest Technology Partners, L.P., a Delaware limited partnership;

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Senvest Technology Partners, LTD, a Cayman Islands exempted company; and

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Senvest Technology Partners Master Fund, LP, a Cayman Islands exempted limited company, which serves as the master fund into which Senvest Technology Partners, L.P. and Senvest Technology Partners, LTD invest substantially all of their assets through a “master feeder” structure.

The Master Fund General Partner serves as the general partner to Senvest Master Fund LP and Senvest Partners, LP. The Senvest Technology General Partner serves as the general partner to Senvest Technology Partners, L.P. and Senvest Technology Partners Master Fund, LP. The Cyprus General Partner serves as the general partner to Senvest Cyprus Recovery Investment Fund, LP. In addition, the Adviser serves as an investment adviser with discretionary trading authority over, and also provides discretionary advisory services to, a separately managed account (the “Managed Account”). The Adviser reserves the right to advise additional Managed Accounts in the future. As used herein, the term “client” generally refers to each Fund and each beneficial owner of a Managed Account. Senvest formulates its investment advice for each Fund based on that Fund’s investment objectives, directs and manages each Fund’s investment portfolio on a discretionary basis in accordance with the terms of each Fund’s offering memorandum, limited partnership agreements and other governing documents applicable to each Fund (collectively, the “Governing Fund Documents”). Because it provides its advice directly to the Funds, Senvest does not tailor its advisory services individually for investors in the Funds (the “Investors”). Certain clients managed by Senvest have significant overlap in terms of investment objectives and securities holdings, but each client has differing risk tolerances and investment goals, which result in different exposures. Senvest formulates its investment advice for the Managed Account based on the investment objectives of the beneficial owner of the Managed Account. Senvest may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that it considers appropriate, subject to each client’s investment objectives and guidelines. The investment strategies Senvest pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved.

This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 (the “Securities Act”) and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds, including requirements that they be “accredited investors” as defined in Regulation D, “qualified purchasers” as defined in the Investment Company Act, or non-“U.S. Persons” as defined in Regulation S. Persons reviewing this Brochure should not construe this as an offer to sell or a solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. The Adviser does not participate in wrap fee programs. As of December 31, 2025, Senvest had approximately $ 4,115,033,177 in regulatory assets under management, all of which are managed on a discretionary basis.

Management Fee: With the exception of the Senvest Cyprus Recovery Investment Fund, LP, clients pay Senvest an annual asset-based investment management fee (the “Management Fee”) at a rate ranging from 1.5% to 4% (per annum) of the net assets of each client, the specific rate being specified in each client’s governing documents or investment management agreement, as applicable. The Funds’ Management Fee is payable monthly in arrears based upon the total market value of the assets (including net unrealized appreciation or depreciation of investments and cash, cash equivalents and accrued interest) on the last day of the month, and are deducted directly from the Fund(s)’ assets in accordance with the Governing Fund Documents pursuant to instructions provided to each Fund’s custodian, as applicable. Senvest and its affiliates reserve the right to waive or reduce Management Fees, and have waived or reduced Management Fees, for certain Investors, including current and former employees, relatives of employees, Senvest Capital, and any entities controlled by Senvest, Senvest Capital, or certain Senvest employees, as may be determined in Senvest’s sole discretion. The Management Fee for the Managed Account is calculated based on the net asset value of the Managed Account at a quarterly basis, in arrears, excluding cash and cash equivalents. Note that in the event of certain waivers of material size, as specified in the applicable Fund’s governing documents, Investors will have the ability to participate in any such waivers. Incentive Allocations: A portion of each Fund’s net investment profit, if any, generally is allocated to the capital account of its General Partner (or the General Partner’s delegate) as an “Incentive Allocation.” The manner of calculation of the Incentive Allocation is based on a percentage of capital gains on or capital appreciation of the assets. The specific percentage is disclosed in each Fund’s Governing Fund Documents, and varies by Fund. Generally, however, 15% to 20% of the investment profits of each Fund, subject to a loss carryforward provision, are allocated as an Incentive Allocation on the last business day of the Fund’s fiscal year, or at the time of withdrawal or redemption by an Investor, subject to certain conditions set forth within the Governing Fund Documents. The Incentive Allocation of one Fund is further subject to a compounded annualized 8% hurdle rate with a high watermark, and the Incentive Allocation of a sub-class of interests in another Fund is further subject to a non-compounding annualized 6% hurdle rate subject to a loss carry forward provision. As is the case with Management Fees, Senvest and its affiliates reserve the right to waive or reduce Incentive Allocations, and have waived or reduced Incentive Allocations, for certain Investors, including current and former employees, relatives of employees, Senvest Capital, and any entities

controlled by Senvest, Senvest Capital, or certain Senvest employees, as may be determined in Senvest’s sole discretion. Other Expenses Charged to the Funds: Each client bears its own expenses, including, without limitation, the Management Fee and Incentive Allocations. Clients will generally bear organizational expenses, legal, accounting, auditing, tax and other professional expenses (including expenses of consultants, investment bankers, attorneys, accountants and other experts), fees and expenses relating to software tools, programs or other technology utilized in managing the Funds (including third-party software licensing, implementation, data management and recovery services and custom development costs); administration expenses, investment expenses such as commissions, research and market data expenses (including the cost of accounting software packages, as well as, without limitation, any information technology hardware, software or other technology incorporated into the cost of obtaining such research and market data, and including fees and expenses related to obtaining, processing and analyzing research or market data that may be considered “big data” or “alternative data”, including fees and expenses related to performing due diligence on potential providers of any of such research or market data services (including, without limitation, “big data” or “alternative data” services)), interest on margin accounts and other indebtedness, borrowing charges on securities sold short, custodial fees, bank services fees, fees and expenses for third party administration (including middle and back office services provided by CSC f/k/a Intertrust Group), expenses attributable to regulatory filings which are made with respect to the Fund or the assets of the Fund (including Section 13, Section 16 and Form PF filings), costs of printing and mailing reports and notices, taxes, corporate licensing, organizational expenses, indemnification expenses, extraordinary expenses and any other reasonable expenses related to the purchase, sale, preservation or transmittal of Fund assets. Fund(s) may also invest in investment company securities (e.g., mutual funds, closed- or open-end funds and exchange traded funds), which charge expense ratios and possibly other charges and expenses. Such expenses are in addition to Management Fees and Incentive Allocations received by Senvest (or its affiliate), and Senvest and its affiliates do not receive any portion of these charges. In addition, each Fund will incur brokerage and other transaction costs. Please refer to Item 12, the Brokerage section of this Brochure for a discussion of the Adviser’s brokerage practices. In the case of Funds structured as master-feeder funds, the feeder fund Investors bear a pro rata share of the expenses associated with the related master fund. Overhead Expenses: Each Fund General Partner and the Adviser will pay all of their respective ordinary administrative and overhead expenses in managing Fund investments, including office rent, supplies, secretarial expenses, printing and stationery, charges for furniture and fixtures, employee insurance, payroll taxes, compensation of security analysts and other administrative personnel, and other reasonable overhead expenses of the Funds as determined by the General Partner in its sole discretion. Where applicable, the Fund General Partner also bears any fees payable to the Adviser. Common expenses frequently will be incurred on behalf of the multiple client accounts. Senvest seeks to allocate those common expenses among its clients in a manner that is fair and equitable. However, expense allocation decisions involve potential conflicts of interest (e.g., an incentive to favor accounts that pay higher incentive compensation, or conflicts relating to different expense

arrangements with certain clients). Under its current expense allocation practices, Senvest generally expects to allocate common expenses among the client accounts pro rata based on assets under management or in some other manner which Senvest determines is fair and equitable given the nature of the expenses and other relevant factors. Senvest may, however, use other methods to allocate expenses among its clients in certain circumstances when it deems another method more appropriate based on certain criteria, including but not limited to, the relative use of the product or service, the nature or source of the product or service or the relative benefits derived by each client from the product or service. Nonetheless, Investors should note that the portion of a common expense that Senvest allocates to each client for a particular product or service may not reflect the relative benefit derived by the client from that product or service in any particular instance. Certain of Senvest’s determinations with respect to whether specific expenses should be borne by Senvest or by clients require subjective judgments. Senvest has a conflict of interest when making such judgments because Senvest will generally bear the costs of any expenses not allocated to a client. Senvest seeks to allocate expenses in a manner that it deems to be fair and equitable. Senvest and its supervised persons do not accept compensation or commissions for the sale of securities or other investment products. Each client’s governing documents provide comprehensive details about the expenses for which that particular client is responsible. Please refer to such governing documents prior to making any investment decision.

Senvest has a fiduciary duty to allocate investment opportunities in a fair and equitable manner and has implemented policies and procedures designed to identify and mitigate conflicts of interest that arise in the investment allocation process. Senvest regularly reviews investment decisions and analyzes comparable client performance in order to monitor compliance with its investment allocation policies and procedures.

Senvest has not but may in the future enter into separate agreements, commonly referred to as “side letters”, or other similar agreements with a particular Investor in connection with such Investor’s admission to a Fund that have the effect of establishing rights under or supplementing the terms of the applicable Fund’s Partnership Agreement with respect to such Investor in a manner more favorable to such Investor than those applicable to other Investors. Other Investors are not parties to such side letters. The rights or terms contained in any such side letter or other similar agreement may include, without limitation: (i) excuse rights applicable to particular investments (which may increase the percentage interest of other Investors in, and contribution obligations of other Investors with respect to, such investments), (ii) reporting obligations, (iii) waiver of certain confidentiality obligations, (iv) consent to certain transfers by such Investor or (v) rights or terms requested or necessary in light of particular investment, legal, regulatory or public policy characteristics of an Investor.

Clients (and Investors in the case of the Funds) should review the governing documents and investment management agreements for their respective investment vehicles for more information regarding the methods of investment analysis used by Senvest in regard to each client. The descriptions set forth in this Brochure of specific advisory services that the Adviser offers to clients, and investment strategies pursued and investments made by the Adviser on behalf of its clients, should not be understood to limit in any way our investment activities. The Adviser may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that the Adviser considers appropriate, subject to each client’s investment objectives and guidelines. The investment strategies the Adviser pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by the Adviser. These risk factors include only those risks the Adviser believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. Market Risks. The profitability of a significant portion of a client’s investment program depends to a great extent upon the Adviser’s ability to correctly assess the future course of the price movements of securities and other investments. There can be no assurance that the Adviser will be able to accurately predict these price movements. Clients and Fund Investors should understand that all investments involve risk and a limited partner may lose some or all of its investment. There also can be no assurance that a client’s investment objective will be achieved. The value of a client’s portfolio may decrease as well as increase, due to a variety of factors, including general economic conditions, market factors and currency exchange rates. Additionally, investment decisions made by the Adviser may not always be profitable or prove to have been correct. Investment strategies, at any given time, may incur significant losses. Losses can occur for a number of reasons, including but not limited to an overall decline in the underlying market, a lack of liquidity in the underlying markets, excessive volatility in a particular market, government intervention or monetary and/or fiscal policies of a specific region or country. The Adviser’s investment strategy is speculative and involves substantial risk to clients due to, among other factors, the nature of a client’s investment strategy and the ongoing market environment. Clients must be fully able to bear the financial risks of such investment and be fully

able to sustain the possible loss of their entire investment. Investors in the Funds should consider an investment in a Fund as a long-term investment that is appropriate only for a limited portion of a limited partner’s overall portfolio. Options. Trading options is highly speculative and may entail risks that are greater than investing in other financial instruments. Prices of options are generally more volatile than prices of other financial instruments. In trading options, the Adviser speculates on market fluctuations of the underlying financial instrument (e.g., a security, an index, a commodity, exchange rate or other instrument), while only investing a small percentage of value relative to its client’s potential exposure. The price of any option is a function of direction (e.g., whether the option is a “put”—the right to sell—or a “call”—the right to buy), the time to expiry and the implied volatility of the underlying instrument. The Adviser may cause its clients to “sell” an option, which means such client receives a small payment, or premium, relative to a notional amount, or the Adviser may cause a client to “buy” an option, which means the client pays a premium to receive exposure to a larger notional amount. A “seller” of options is generally exposed to the entire notional amount of the option contract, and can be exposed to even more risk, it is selling a call option. A “buyer” of options risks losing all of its investment if the option expires “out of the money” (i.e., the trade goes against that option buyer). Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. Because option premiums paid or received by an investor will be small in relation to the market value of the investments underlying the options, buying and selling put and call options can result in large amounts of leverage. As a result, the leverage offered by trading in options could cause an investor’s asset value to be subject to more frequent and wider fluctuations than would be the case if the investor did not invest in options. Non-Diversification; Concentration; Volatility. Client portfolios may not be diversified among a wide range of issuers or industries. In addition, the Adviser may cause clients to take concentrated positions (e.g., 10% of the portfolio or more) in its high conviction ideas. However, the Adviser will not cause its clients to have exposure exceeding 10% of the client’s net assets in private investments (with new private investments valued at cost when acquired for the purposes of measuring this threshold). Accordingly, clients’ investment portfolios may be subject to more rapid change in value than would be the case if the Adviser were required to maintain a wide diversification in those portfolios among industries, areas, types of securities and issuers. Short Sales. Short selling, or the sale of securities not owned by clients, necessarily involves certain additional risks. Such transactions expose clients to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed by clients in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein the Adviser might be compelled, at the most disadvantageous time, to replace a client’s borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. In addition to entering into short sales for speculative purposes, as the Adviser may cause its clients to do from time to time, and depending

on market conditions, the Adviser may cause clients to engage in short selling in an effort to hedge its portfolio positions. Hedging activities may involve taking short positions related to particular portfolio positions as well as short positions intended to hedge a client’s broader exposures or particular identified risks at an overall portfolio level. Short Selling Legal Restrictions and Reporting-Related Risk. Certain jurisdictions have enacted restrictions on short selling (including wholesale bans, at times) as well as public disclosure requirements. If additional short selling restrictions and disclosure requirements are enacted, the prices of the instruments in which the clients invest may be materially affected and the ability of the Adviser to take advantage of opportunities for short selling may be significantly reduced. Leverage. While the use of margin and borrowed funds can substantially improve the return on invested capital, such use may also increase the adverse impact to which a client’s investment portfolio may be subject. Borrowings will usually be from securities brokers and dealers and will typically be secured by a client’s securities and other assets. Under certain circumstances, such a broker-dealer may demand an increase in the collateral that secures a client’s obligations and if the Adviser is unable to provide additional collateral for that client, the broker-dealer could liquidate assets held in the account to satisfy the client’s obligations to the broker-dealer. Liquidation in that manner could have extremely adverse consequences. In addition, the amount of the client’s borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on the profitability of the client’s portfolios. Depending on the conditions in the credit markets at any given time, the Adviser may find it difficult or impossible to obtain leverage for its clients on acceptable terms or at all. Since leveraging its assets is a part of certain clients’ investment strategies, in such event the Adviser could find it difficult to fully implement a client’s strategy. In addition, any leverage obtained, if terminated on short notice by the lender, could result in the Adviser being forced to unwind a client’s positions quickly and at prices below what the Adviser deems to be fair value for the positions. Small and Mid-Cap Stocks. At any given time, clients may have significant investments in smallerto-medium sized companies with market capitalizations of less than $2 billion. While smaller companies may have potential for rapid growth, they often involve higher risks because they lack the management experience, financial resources, product diversification, and competitive strengths of larger corporations. These factors make smaller companies far more likely than their larger counterparts to experience significant operating and financial setbacks that threaten their short-term and long-term viability. In addition, in many instances, the frequency and volume of their trading is substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations, and exiting investments in such securities at appropriate prices may be difficult, subject to substantial delay or impossible. When making large sales, clients may have to sell portfolio holdings at discounts from quoted prices or may have to make a series of small sales over an extended period of time due to the trading volume of smaller company securities. Non-U.S. Securities. Investing in securities of non-U.S. governments and companies domiciled or operating outside of the United States involves certain considerations comprising both risks and opportunities not typically associated with investing in securities of the United States Government or United States companies. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of foreign taxes, less

liquid markets and less available information than are generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. Technology Industry Related Risks. A significant portion of client assets may be invested in technology and technology-related markets. Certain technology and technology-related companies allocate, or may have allocated, greater than usual amounts to research and product development. The securities of such companies may experience above-average price movements associated with the perceived prospects of success of the research and development programs. In addition, companies in which the Adviser causes clients to invest could be adversely affected by lack of commercial acceptance of a new product or products or by technological change and obsolescence. Some of these companies may have limited operating histories. As a result, these companies may face undeveloped or limited markets, have limited products, have no proven profit-making history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses. Further, many companies with proprietary technology rely on a combination of patent, copyright, trademark and trade secret protection and non-disclosure agreements to establish and protect their proprietary rights, which may be essential to the growth and profitability of the company. There can be no assurance that a particular company will be able to protect these rights or will have the financial resources to do so, or that competitors will not develop or patent technologies that are substantially equivalent or superior to the technology of a company in which the Adviser causes a client to invest. Conversely, other companies may make infringement claims against a company in which the Adviser causes clients to invest, which could have a material adverse effect on such company. The markets in which many technology and technology-related companies operate are extremely competitive. New technologies and improved products and services are continually being developed, rendering older technologies, products and services obsolete. Moreover, competition can result in significant downward pressure on pricing. There can be no assurance that companies in which the Adviser causes clients to invest will successfully penetrate their markets or establish or maintain competitive advantages. Emerging Markets. Investing in emerging market debt or equity involves certain risks and special considerations not typically associated with investing in other more established economies or securities markets. Such risks may include (a) the risk of nationalization or expropriation of assets or confiscatory taxation; (b) social, economic and political uncertainty including war; (c) dependence on exports and the corresponding importance of international trade; (d) price fluctuations, less liquidity and smaller capitalization of securities markets; (e) currency exchange rate fluctuations; (f) rates of inflation; (g) controls on foreign investment and limitations on repatriation of invested capital and on the Adviser’s ability to exchange a client’s local currencies for U.S. dollars; (h) governmental involvement in and control over the economies; (i) that governments may decide not to continue to support economic reform programs generally and could impose centrally planned economies; (j) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers; (k) less extensive regulation of the securities markets; (l) longer settlement period for securities transactions; (m) less

developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors; and (n) certain considerations regarding the maintenance of client portfolio securities and cash with non-U.S. sub-custodians and securities depositories. Currency Risks. Client investments that are denominated in non-U.S. currencies are subject to the risk that the value of a particular currency will change in relation to one or more other currencies. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. The Adviser may try to hedge these risks by investing in foreign currencies and options thereon, forward foreign currency exchange contracts, or any combination thereof, but there can be no assurance that such strategies will be implemented or, if implemented, will be effective. High Growth Industry Related Risks. The Adviser may cause clients to have investments in the securities of high growth companies. These securities may be very volatile. In addition, these companies may face undeveloped or limited markets, have limited products, have no proven profitmaking history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses, have limited ability to protect their rights to certain patents, copyrights, trademarks and other trade secrets, or be otherwise adversely affected by the extremely competitive markets in which many of their competitors operate. High Yield Securities. The Adviser may cause clients to make significant investments in “high yield” bonds and preferred securities which are rated in the lower rating categories by the various credit rating agencies (or in comparable non-rated securities). Securities in the lower rating categories are subject to greater risk of loss of principal and interest than higher-rated securities and are generally considered to be predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal. They are also generally considered to be subject to greater risk than securities with higher ratings in the case of deterioration of general economic conditions. Because investors generally perceive that there are greater risks associated with lower-rated securities, the yields and prices of such securities may tend to fluctuate more than those for higher-rated securities. The market for lower-rated securities is thinner and less active than that for higher-rated securities, which can adversely affect the prices at which these securities can be sold. In addition, adverse publicity and investor perceptions about lower-rated securities, whether or not based on

fundamental analysis, may be a contributing factor in a decrease in the value and liquidity of such lower-rated securities. Special Situations. The Adviser may cause clients to invest in companies involved in (or the target of) acquisition attempts or tender offers or in companies or sovereign debt involved in work-outs, spin-offs, reorganizations, bankruptcies, liquidations, sovereign debt and similar transactions. In any investment opportunity involving any such type of special situation, there exists the risk that the contemplated transaction either will be unsuccessful, take considerable time or will result in a distribution of cash or a new security the value of which will be less than the purchase price to a client of the security or other financial instrument in respect of which such distribution is received. Similarly, if an anticipated transaction does not in fact occur, the Adviser may be required to sell a client’s investment at a loss. Because there is substantial uncertainty concerning the outcome of transactions involving financially troubled companies or countries in which the Adviser may cause clients to invest, there is a potential risk of loss by a client of its entire investment in such companies or countries. Shareholder Activism. The Adviser will generally cause its clients to make investments on a passive basis, however, there may be times when a client’s investment strategy may evolve and include activities intended to influence the management and operations of a particular portfolio company. There is a risk that any such activism will be unsuccessful. Further, in the event that a client’s investment strategy becomes active with respect to a particular portfolio company, a substantial period of time may elapse between the client’s purchase of the securities and the anticipated results. During this period, a portion of the client’s capital would be committed to the securities purchased. Additionally, if the anticipated results do not in fact occur, the client may be required to sell its investment at a loss. Moreover, there may be instances where one or more clients will be restricted in transacting in or redeeming a particular investment as a result of its activism with respect to an investment. Credit Default Swaps. The Adviser may cause its clients to utilize credit default swaps. The buyer of a credit default contract is obligated to pay the seller either a lump sum payment or a periodic stream of payments over the term of the contract in return for a contingent payment upon the occurrence of a credit event with respect to an underlying reference obligation or entity. Generally, a credit event means bankruptcy, failure to pay, cross default/acceleration, obligation acceleration, repudiation/moratorium, restructuring or rating decline. A client may be either the buyer or seller in a transaction. If the client is a buyer and no credit event occurs, the client will have made fixed payments and received nothing. However, if a credit event occurs, the client, as a buyer, typically will receive full notional value for a reference obligation that may have little or no value. As a seller, the client receives a fixed rate of income throughout the term of the contract, which typically is between one month and five years, provided that no credit event occurs. If a credit event occurs, the seller may pay the buyer the full notional value of the reference obligation which may have little or no value. In addition to general market risks, credit default swaps are subject to liquidity risk and credit risk. Swap contracts are not traded on exchanges and are not otherwise regulated, and as a consequence investors in such contracts do not benefit from regulatory protections. The selling of credit default swaps involves greater risks than if clients had invested in the reference obligation directly. If a credit event were to occur, the value of the reference obligation received by the seller, coupled with

the periodic payments previously received, may be less than the full notional value it pays to the buyer, resulting in a loss of value. The buyer of credit default swaps will incur a loss if the seller fails to perform on its obligation should a credit event occur. In certain circumstances, the buyer can receive the notional value of a credit default swap only by delivering a physical security to the seller, and is at risk if deliverable security is unavailable or illiquid. Fixed Income Securities. The Adviser may cause its clients to invest in fixed income securities and other debt securities. Certain of these securities may be unrated by a recognized credit-rating agency or below investment grade, which are subject to greater risk of loss of principal and interest than higher-rated debt securities. Accordingly, these securities tend to be more sensitive to economic conditions and tend to reflect individual corporate developments to a greater extent than do higher-rated securities, which primarily react to fluctuations in the general level of interest rates. Issuers of lower-rated debt securities are often highly-leveraged and may not have access to more traditional methods of financing. Furthermore, trading in these types of securities may be limited or disrupted by an economic recession, resulting in an adverse impact on the value of such securities. Moreover, it is likely that an economic downturn could affect the ability of the issuers to repay principal and pay interest thereon resulting in a high potential of default. Additionally, the Adviser may cause its clients to invest in debt securities that rank junior to other outstanding securities and obligations of the issuer, all or a significant portion of which may be secured on substantially all of that issuer’s assets. The Adviser may cause its clients to invest in debt securities that are not protected by financial covenants or limitations on additional indebtedness. Clients investing in such debt securities will therefore be subject to credit and liquidity risks. In addition, the market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. Investment in a debt instrument will normally involve the assumption of interest rate risk. Limited Liquidity. Client assets may, at any given time, include securities and other financial instruments or obligations which are restricted as to sale or which are very thinly traded. The sale of any such investments may be possible only at substantial discounts and such investments may be extremely difficult to value. Exposure to Material Non-Public Information. From time to time, the Adviser and/or its personnel may, in the course of its activities with respect to pursuing clients’ investment program (including in the course of its activities of serving as a board member, board observer, or in a similar capacity with respect to any portfolio company of any of the clients), receive material non-public information with respect to an issuer of publicly traded securities. In addition, during the course of the research process (or in the course of serving as a board member, board director, or in a similar capacity with respect to any portfolio company of any of the clients), the Adviser may share and receive information from other market participants, such as other investment managers, which could increase the likelihood that the Adviser will receive material non-public information and be required to restrict trading in an issuer’s securities. In such circumstances, the Adviser may restrict a client, or the Adviser (acting on behalf of its clients) may be prohibited, by law, policy or contract, for a period of time from (i) unwinding a position in such issuer, (ii) establishing an initial position or taking any greater position in such issuer, and (iii) pursuing other investment opportunities related

to such issuer. If these restrictions or prohibitions apply to securities in which the Adviser is considering causing a client to make an investment, such restrictions or limitations could prevent the Adviser from accessing a profitable investment opportunity for its clients. If such restrictions or limitations apply to securities in a client has an existing investment, then such restrictions or limitations could give rise to substantial investment losses, which losses, in the case of a security in which a client has a short position, are theoretically unlimited. Alternative Data. The Adviser expects to obtain and use alternative data in its investment process. Alternative data may consist of datasets that have been culled from a variety of sources, such as internet usage, payment records, financial transactions, weather and other physical phenomena sensors, applications and devices (such as smartphones) that generate location and mobility data, data gathered by satellites, and government and other public records databases (this data is sometimes referred to as “big data” or “alternative data”). The Adviser intends to apply this alternative data to better anticipate micro- and macro-economic trends and otherwise to develop or improve trading or investment themes. The analysis and interpretation of alternative data involves a high degree of uncertainty and may entail significant expense, including technological efforts that are expected to be borne— at least in part—by clients. No assurance can be given that the Adviser will be successful in utilizing alternative data in its investment process. Moreover, there has been increased scrutiny from a variety of regulators regarding the use of alternative data in this manner, and its use or misuse under current or future laws and regulations could create liability for the Adviser and clients in numerous jurisdictions. The Adviser cannot predict what, if any, regulatory or other actions may be asserted with regard to alternative data, but any adverse inquiries or formal actions could cause reputational, financial, or other harm to the Adviser or to its clients. Conversely, any future limitations on the use of alternative data could have a material adverse impact on the performance of client portfolios. Government Regulation of Investments. The Adviser may cause its clients to invest in instruments listed on both U.S. and non-U.S. securities and futures exchanges, as well as in “over-the-counter” instruments issued by broker-dealers and other financial counterparties. Instruments listed on exchanges are generally subject to restrictions and regulation by government and/or self-regulatory organizations in the country in which such instruments are traded. Over-the-counter transactions with broker-dealers and other financial counterparties generally will be entered into by the Adviser on behalf of its clients with counterparties regulated by government regulatory bodies and/or selfregulatory organizations in the countries in which such counterparties operate, but the specific instruments acquired pursuant to such transactions may not be registered or subject to specific regulation and therefore lack certain protections or regulatory oversight applicable to instruments which are registered or otherwise subject to specific regulation. It is also noted that changes in applicable regulations may adversely impact a client’s portfolio or manner of operation. Israeli Investment Risks. Certain clients invest significantly in companies that are located in Israel or have a substantial connection to Israel either through their conduct of business or the location of their assets, the investments of such clients may subject to legal, security, regulatory, political, economic and geographic risks specific to Israel. Israel’s relations with Palestinians and its neighboring countries have at times been strained due to territorial disputes. The Adviser cannot

predict whether or in what manner these factors may affect issuers of Israeli securities and Israeli markets and thus, certain clients’ investments. See also Israel-Hamas Conflict below. Digital Assets. Clients have previously made private investments in certain companies that provide services or products related to virtual currencies (also known as “cryptocurrencies” or “digital currencies”), or other digital assets that utilize blockchain technology (including tokens) (collectively, “Digital Assets”). While such investments have substantially been comprised of investments in the shares or other interests of such companies and not in actual Digital Assets, (i) clients have received certain small amounts of Digital Assets in connection with such investments and (ii) the success of such companies is generally expected to depend on, or otherwise be impacted by, the success of the Digital Asset industry in general. Clients may continue to make similar investments and other investments in Digital Assets in the future. Accordingly, clients are generally exposed to the risks of investments in Digital Assets. Digital Assets are relatively new, evolving products based upon new and evolving technologies. An investment in any Digital Asset is subject to a variety of risks, including technological, security and regulatory risks as well as associated uncertainties over the future existence, support and development of such Digital Asset. Digital Assets may also experience unusual volatility. Any such investment is highly speculative and subject to the risk that the entirety or a material portion of such investment or its value may be lost. Digital Assets are the subject of significant focus and action by governmental authorities – such assets may be the subject of legislation and/or regulation that could materially impact the ability to purchase, sell, or transfer such assets. In addition, certain trading venues pertaining to Digital Assets are the subject of legal and regulatory inquiries. Such considerations could affect the transferability, liquidity and value of Digital Assets. Notwithstanding the foregoing, it is currently expected that any investment by clients in Digital Assets is likely to constitute only a substantially small portion of clients’ portfolios. Digital Asset Exchanges, Intermediaries and Custodians. Digital Asset exchanges do not operate as typical futures or securities exchanges. They combine features of both traditional brokers and exchanges and all transactions executed through such facilities are executed and settled on a principal to principal basis. The Digital Asset exchanges, custodians and other intermediaries are relatively new, often do not have an extensive operating history and are largely unregulated. As an example, neither the NFA nor CFTC has general regulatory oversight authority over spot Digital Asset exchanges or markets. These entities generally are not subject to the same governmental oversight, and may have comparatively less well-developed or robust operational, risk and legal systems and procedures, when compared to market participants that are substantively regulated under either or both the U.S. futures or securities laws (or the equivalent or similar laws of any foreign jurisdiction). In addition, many of these entities may experience significant outages, downtime and transaction processing delays due to cyberattacks, internal failures or other reasons; may experience failure or be forced to cease operations due to theft, fraud, cyberattacks, liquidity or other business issues, regulatory proceedings or other reasons; may be particularly appealing targets from cyberattacks due to their substantial Digital Asset holdings; and/or may face substantial financial difficulties, including insolvency or bankruptcy for various reasons. These events have occurred in the past and may occur in the future and in many of these instances, the customers of

such Digital Asset exchanges were not compensated or made whole for the partial or complete losses of their Digital Assets held at such exchanges. There can be no assurance that any such entity will have in place any insurance to mitigate customer losses if any of the foregoing were to occur or that any insurance will be sufficient to fulfill the claims of all affected customers. In the event any that any one of the Funds’ financial intermediaries were subject to one or more of the foregoing adverse events, the Funds may be unable to recover their assets (whether fiat currency or Digital Asset) from the financial intermediary, and the Funds could suffer substantial losses. In addition, while certain of the Digital Asset exchanges with which the Funds may deal may have adopted policies and procedures to mitigate these risks, the Funds do not have access to sufficient information or the resources to assess the adequacy or effectiveness of those policies and procedures as the Digital Asset exchanges generally do not provide the public with significant information regarding their ownership structure, management teams, corporate practices or regulatory compliance. Non-U.S. Digital Asset exchanges pose additional risks. It is possible that non-U.S. Digital Asset exchanges may not be as developed, liquid, or efficient as those in the U.S. Digital Asset exchanges already are subject to minimal U.S. regulation compared to exchanges in traditional derivatives and equities markets, but non-U.S. Digital Asset exchanges may be subject to no regulation, or less stringent or different regulation, which could provide less legal protection to exchange investors. In addition, Digital Asset-related derivatives and other assets or claims held by the Funds at Digital Asset exchanges domiciled outside of the U.S. may be subject to a different and lower level of protection or no protection at all in the case of a non-U.S. Digital Asset exchange’s distress, including bankruptcy, insolvency, bank resolution and recovery measures, or similar events. The Funds may have difficulty in successfully pursuing claims in non-U.S. courts or enforcing in such courts a judgment obtained in another country. Counterparty Risk. To the extent the Adviser causes its clients to invest in non-U.S. securities, swaps, derivatives, or other over-the-counter transactions, in certain circumstances, such clients may take a credit risk and systemic risk with regard to parties with whom it trades and may also bear the risk of settlement default. These risks may differ materially from those entailed in exchange-traded transactions which generally are backed by clearing organization guarantees, daily marking-to-market and settlement, and segregation and minimum capital requirements applicable to intermediaries. Transactions entered directly between two counterparties generally do not benefit from such protections and expose the parties to the risk of counterparty default. Banking Relationships. The Adviser and the clients will hold cash and other assets in accounts with one or more banks, custodians or depository or credit institutions (collectively, “Banking Institutions”), which may include both U.S. and non-U.S. Banking Institutions from time to time. The clients may also enter into credit facilities and have other relationships with Banking Institutions as contemplated in Governing Fund Documents. The distress, impairment, or failure of, or a lack of investor or customer confidence in, any of such Banking Institutions may limit the ability of each of the Adviser clients to access, transfer or otherwise deal with its assets, draw upon a credit facility, or rely upon any of such other relationships, in a timely manner or at all, and may result in other market volatility and disruption, including by affecting other Banking Institutions.

All of the foregoing could have a negative impact on the clients. For example, in such a scenario, the clients could be forced to delay or forgo an investment or a distribution, including in connection with a withdrawal, or generate cash to fund such investment or distribution from other sources (including by disposing of other investments or making other borrowings) in a manner that it would not have otherwise considered desirable. Furthermore, in the event of the failure of a Banking Institution, access to a depository account with that institution could be restricted and U.S. Federal Deposit Insurance Corporation (“FDIC”) protection may not be available for balances in excess of amounts insured by the FDIC (and similar considerations may apply to Banking Institutions in other jurisdictions not subject to FDIC protection). In such a case, the Adviser or the clients, as applicable, may not recover all or a portion of such excess uninsured amounts and could instead have an unsecured or other type of impaired claim against the Banking Institution (alongside other unsecured or impaired creditors). The Adviser does not expect to be in a position to reliably identify in advance all potential solvency or stress concerns with respect to its, or the clients’ banking relationships, and there can be no assurance that the Adviser, or the clients, will be able to easily establish alternative relationships with and transfer assets to other Banking Institutions in the event a Banking Institution comes under stress or fails. Climate Change-Related Risks. The environmental effects of climate change, including rising temperatures, extreme weather, fires, flooding, erratic weather fluctuations, agricultural failures and displacement and destabilization of human populations, could have materially adverse effects on the securities held by the clients’ portfolios. The Adviser believes that such risks may increase over time, although the time period over which these consequences might unfold is difficult to predict. In addition to the physical, economic and geo-political risks associated with climate change, there are transition risks. The willingness of certain governments, industries and businesses, especially those that profit from, or have a reliance on, fossil fuels, to adapt to climate change or transition to sustainable practices may also adversely affect the clients’ portfolios. Regulatory changes and divestment movements tied to concerns about climate change could adversely affect the value of certain industries whose activities or products are seen as accelerating climate change, or ill-positioned in light of the economic and social demands imposed by climate change. In recent years, certain investors have incorporated the business risks of climate change and the adequacy of companies’ responses to climate change as part of their investment theses. These shifts in investing priorities may result in adverse effects on the trading price of securities if investors determine that the company has not made sufficient progress on climate change and environmental sustainability matters whether or not climate change proves to be as severe as predicted or preventable. The values of securities whose performance is linked to assets and revenue streams that are exposed to climate change risk, including futures and swaps that directly or indirectly reference fuel, energy, transportation and agricultural prices, real estate property values, mortgages, taxes, insurance rates and proceeds of tourism, may readily be affected by both long-term, systemic effects of climate change, as well as severe environmental events whose occurrence is inherently unpredictable. Assumption of Catastrophe Risks. Clients may be subject to the risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes

and other natural disasters (which may be caused, or enhanced in frequency and severity, by climate change factors); war, terrorism and other armed conflicts; social or political unrest; cyberterrorism; major or prolonged power outages or network interruptions; public health crises, including infectious disease outbreaks, epidemics and pandemics; and other unforeseeable and external events. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which the Adviser causes clients to invest (or has a material negative impact on the operations of the Adviser or the service providers of the Adviser or clients), the risks of loss can be substantial and could have a material adverse effect on client portfolios. Furthermore, any such event may also adversely impact one or more individual shareholders’ financial condition, which could result in substantial redemption requests by such shareholders as a result of their individual liquidity situations and irrespective of client portfolio performance. Conflict in Iran. The active armed conflict in Iran that commenced on February 28, 2026 has contributed, and may continue to contribute, to volatility and instability in global markets in an unpredictable fashion for an uncertain duration. This active armed conflict could negatively impact the business and financial condition of the clients in unpredictable ways. Actions taken in connection with armed conflicts are impossible to predict, and may have a negative impact on the Funds and their business strategy. Even if any existing conflict is resolved in the near-to-mid-term, the Middle East has historically been subject to unsettled political conditions, ethnic, religious and social conflict and regional hostilities. Any geopolitical concerns that arise due to continued tensions in the Middle East may impede business activity and adversely affect the environment for client investments. The threat of potential or actual warfare or escalating political tensions in the Middle East may continue to contribute to instability and volatility in global financial markets in the future. There can be no assurance that such continued tensions will not become a problem in the future and thus adversely affect client returns. Continued volatility in the financial markets and political systems in the Middle East may have adverse spill-over effects into the global financial markets generally (including the U.S.). The success of the clients will be dependent on general economic and market conditions and activity, including interest rates, availability of credit, inflation rates, commodity prices (including oil and gas prices), economic uncertainty, changes in laws, trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These and similar factors could have an adverse effect on the liquidity and value of the clients’ investments and on returns. Cybersecurity Risks. The Adviser, its clients and their respective service providers, including banks, broker-dealers, custodians and their affiliates, may be subject to operational and information security risks resulting from cyber-attacks. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, unauthorized asset transfers and various other forms of cybersecurity breaches. Cyber-attacks affecting the Fund, the General Partner, the Investment Manager or their service providers may adversely impact the Fund. For instance, cyberattacks may interfere with the processing or execution of Fund transactions, cause the release of confidential information, including private information about shareholders, subject the Adviser, its

clients or their Affiliates to regulatory fines or financial losses or cause reputational damage. Additionally, cyber-attacks or security breaches (e.g., hacking or the unlawful withdrawal or transfer of funds), affecting any of the Adviser’s or its clients’ key service providers, such as banks, broker-dealers, custodians or other counterparties holding assets of the Adviser or its clients, may cause significant harm to the Adviser or its clients, including the loss of capital. Similar types of cybersecurity risks are also present for issuers of securities in which the Adviser or its clients may invest. These risks could result in material adverse consequences for such issuers, and may cause the Adviser’s or its clients’ investments in such issuers to lose value. Artificial Intelligence Risks. Developments in generative artificial intelligence such as ChatGPT and similar large language models and chatbots (collectively, “Generative AI”) can pose risks to the Adviser, its clients and clients’ investments. The Adviser has begun using Generative AI in various processes, including, without limitation, to assist in certain investment research activities. The Adviser is also exposed to the risks of Generative AI through third parties (including, but not limited to, the Adviser’s or its clients’ service providers or counterparties) that use Generative AI, and the Adviser may not always be aware of such use. The Adviser cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Generative AI is highly reliant on the collection and analysis of large amounts of data, and in many instances, it may not be possible or practicable to incorporate all potentially relevant data into the data set that Generative AI utilizes or to fully evaluate the source and the reliability of the data being analyzed. Further, the outputs of Generative AI may be inaccurate or unreliable and are also susceptible to errors in their subsequent analysis. Generative AI that is based on a limited set of data is less likely to incorporate all potentially relevant information in producing outputs. This could limit the utility or reliability of such technologies used by the Adviser. Additionally, the use of Generative AI may involve (i) cybersecurity risks (including, but not limited to, the increased likelihood that the Firm, its clients or its clients’ investments become victims of cybercrime), (ii) threats to proprietary and confidential information, (iii) intellectual property violations, (iv) access to, or disclosure of, personal information in violation of applicable data protection laws, and (v) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats, and/or violations could have adverse impacts on the Adviser, its clients and its clients’ investments. Generative AI continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments. Due to the rapidly evolving nature of Generative AI and its widespread potential uses, the Adviser expects that its policies and procedures will continue to evolve to address the challenges of Generative AI in a manner reasonably designed to match the Adviser’s use of, and interaction with, such technologies.

The Adviser paid a civil money penalty of $6,500,000 in connection with the Order. As part of the settlement, the Adviser agreed to retain a compliance consultant to review certain aspects of its compliance program related to the use of unauthorized communication methods for business communications, including related policies, procedures, trainings, surveillance program, technological solutions, and other preventative measures. The Adviser was censured and ordered to cease-and-desist from committing or causing any violations and any future violations of Sections 204, 204A, and 206(4) of the Advisers Act and Rules 204-2, 204A-1, and 206(4)-7.

In particular, Richard Mashaal, Chief Executive Officer of the Adviser, serves as joint President and Chief Executive Officer of Senvest Capital, and George Malikotsis, Chief Financial Officer of the Adviser, serves as joint President and Chief Executive Officer. Both Richard Mashaal and George Malikotsis serve on the board of Senvest Capital. Richard Mashaal and George Malikotsis also serves roles with respect to various investments and entities controlled by Senvest Capital. All Senvest Capital employees who provide services to the Adviser are treated as access persons of the Adviser and are subject to the Adviser’s Code of Ethics. Certain employees of the Adviser, including Richard Mashaal, own shares of Senvest Capital. Adviser employees are permitted, subject to certain blackout periods and applicable policies, to purchase additional shares of Senvest Capital. Senvest Capital is the largest Investor in the Funds and acted as the seed investor for Senvest, although Senvest Capital does not have any ownership interest in the Adviser. Certain employees of Senvest Capital are supervised persons of Senvest and are compensated for such services by Senvest Capital. All Senvest Capital employees that provide services to Senvest are treated as access persons of Senvest and are subject to Senvest’s Code of Ethics. The Adviser does not recommend or select other investment advisers for its clients.

Individuals and entities designated in writing by the Chief Compliance Officer as being subject to all or a portion of the compliance procedures or policies adopted by the Adviser (collectively, the “Covered Persons”) are subject to the Code. The Adviser requires its Supervised Persons to act in accordance with Senvest’s fiduciary duties to its clients and abide by all applicable laws and regulations. The Code also sets forth procedures and controls to prevent the misuse of material nonpublic information, and requires prompt internal reporting of Code violations; the pre-clearance of all transactions in equities, initial public offerings, and limited offerings; and periodic reporting of Covered Persons’ personal securities transactions and all holdings. The Chief Compliance Officer has responsibility for the day-to-day administration of the Code and is responsible for reviewing the reports provided by Covered Persons under the Code. Supervised Persons are required to immediately report any violation of the Code, as well as any Federal securities laws, to the Chief Compliance Officer. The restrictions of the Code do not preclude purchases of interests in the Funds. Certain Covered Persons are Investors in the Funds, and some or all of the key personnel of the Adviser and its affiliates have significant interests in one or more of the Funds as Investors. Clients may request to review the Code by contacting Senvest at the address or telephone number listed on the first page of this document. Cross Transactions Senvest may effect cross transactions between its clients, except as otherwise noted below. Cross transactions enable the Adviser to affect a trade between two clients for the same security at a set price. The Adviser may determine that it would be in the best interests to cause certain clients to engage in a cross transaction for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of the clients, or to reduce transaction costs that may arise in an open market transaction. If the Adviser decides to engage in a cross transaction, the Adviser will determine that the trade is in the best interests of each client involved in it and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those clients. The Adviser will generally execute cross transactions with the assistance of a broker-dealer who executes and books the transaction at the close of the market on the day of the transaction.

Alternatively, a cross transaction between two clients may occur as an “internal cross”, where the Adviser instructs the custodian for the clients to book the transaction at the price determined in accordance with the Adviser’s valuation policy. If the Adviser effects an internal cross, the Adviser will not receive any fee in connection with the completion of the transaction. To the extent that cross transactions are viewed as principal transactions due to the ownership interest in a client by the Adviser or its personnel, the Adviser will comply with the requirements of Section 206(3) of the Advisers Act, including that any such transactions will be considered on behalf of Investors in such a client and approved or disapproved by (i) an advisory board comprised of representatives of such Investors or (ii) a committee consisting of one or more persons selected by the Adviser (or its affiliate), and any valuation approved by such a committee will be determined by an independent third party that has appropriate experience in providing such valuations. In addition, cross transactions are not permitted for benefit plan or other similar accounts that are subject to ERISA, unless they have over $100 million in assets. Trade Errors If it appears that a trade error has occurred, Senvest will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors and breaches of investment guidelines and restrictions occur, the Adviser’s error correction procedure is designed to identify and mitigate any problems that occur. The Adviser has discretion to resolve a particular error in any appropriate manner that is consistent with the above stated policy. In the event that a client account incurs a trade error as a result of actions that breach the applicable client’s standard of care (as specified in the applicable client’s governing documents), trade errors will be corrected by the Adviser as soon as practicable, in a manner such that the client incurs no loss. Trade errors that result other than by breach of the standard of care above are generally borne by the applicable client. Senvest has a conflict of interest when determining whether losses resulting from a trading error will be borne by a client because otherwise Senvest would generally be required to reimburse such losses. From time to time, the Adviser or its affiliates may elect to voluntarily reimburse clients for losses suffered as a result of certain trade errors identified by the Adviser or its affiliates or otherwise. However, notwithstanding the previous sentence, clients and Investors should not carry the expectation that a reimbursement will ever take place, and, in evaluating Senvest, no decisions should be made in reliance on it making any reimbursements to a client for losses suffered as a result of such trade errors. Any decision to reimburse is not precedential and should not create the expectation of any reimbursement in the future. Investing in Securities that the Adviser or a Related Person Recommends to Clients The Code places restrictions on personal trades by employees, including that they disclose their personal securities holdings and transactions to the Adviser on a periodic basis, and requires that employees pre-clear certain types of personal securities transactions. Generally, and subject to certain exceptions, employees are restricted from trading options or short selling in their personal accounts. The Adviser, its affiliates and its employees at times invest on behalf of themselves in

securities and other instruments that would be appropriate for, are held by, or fall within the investment guidelines of clients, at the time of such employees’ personal investments. However, all equity transactions are subject to mandatory pre-clearance. Further, employees are generally restricted from personal trading in client-held securities, excluding securities above a certain market capitalization threshold when a client is not trading in such securities on the same day. The Adviser may deny permission to engage in any equity transactions for any reason or no reason. The Adviser, its affiliates and its employees may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for clients. These activities may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more clients. Potential conflicts also may arise due to the fact that the Adviser and its personnel have investments in some Funds but not in others or have different levels of investments in the various Funds. The Adviser has established policies and procedures to monitor and resolve conflicts with respect to investment opportunities in a fair and equitable manner, as determined in the Adviser’s sole discretion, including the restrictions placed on personal trading in the Code, as described above, and regular monitoring of employee transactions and trading patterns for conflicts of interest, including those conflicts that may arise as a result of personal trades in the same or similar securities made at or about the same time as client trades. Conflicts of Interest Created by Contemporaneous Trading The Adviser manages investments on behalf of a number of clients. Certain clients have investment programs that are similar to or overlap and, therefore, participate with each other in certain investments from time to time. It is the policy of the Adviser to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. The Adviser will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any client solely because the Adviser purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any client if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client. The Adviser generally allocates investments on a pro rata basis for clients with similar investment strategies. Senvest has allocated investments on a non-pro rata basis in certain circumstances for various reasons, including but not limited to: varying investment strategies and restrictions between different clients, regulatory restrictions, differing risk management strategies among clients, hedging preferences specific to certain clients, position size, asset levels, cash flow considerations, portfolio liquidity and concentration, timing and size of capital contributions and redemptions, market conditions, whether certain clients would receive nominal or de minimis allocation amounts, and participation in prior investments in the same issuer. Even client accounts that are typically managed on a pari passu basis may from time to time receive differing allocations under certain circumstances, such as (but not limited to) variances in the total assets of each account eligible to invest in the applicable investment type.

The Adviser at times causes clients to acquire a substantial position in the securities of a company, and secures the appointment of persons selected or recommended by the Adviser to the company’s management team or board of directors. In so doing, the Adviser may acquire fiduciary duties to the company and to its other shareholders. These fiduciary duties may compel the Adviser to take actions that, while in the best interest of the company and/or its shareholders, may not be in the best interests of clients. Accordingly, the Adviser may have a conflict of interest between the fiduciary duties (if any) that it or its personnel owe to such companies and their shareholders, on the one hand, and those that it owes to its clients, on the other. Service on boards of directors can increase the likelihood that the Adviser will receive material, nonpublic information with respect to the company itself or other companies that are affiliated with such company, or that directly compete with or are in the same sector as such company. In such situations, the Adviser could potentially face restrictions on its ability to make certain investments on behalf of clients. This can include situations where the Adviser has selected or recommended board members for a company in which one client has invested, but where such board membership results in investment restrictions for clients that have not invested in the applicable company. Information received in connection with service on a company’s board of directors may, at times, constitute material nonpublic information with respect to securities issued by another company (e.g., market participant, key supplier, material competitor). Receipt of such information in connection with board memberships could result in investment restrictions for clients.

While the Adviser engages in transactions with certain broker-dealers on an “execution only” basis, the Funds will generally be paying for research, brokerage or other services provided by a broker-dealer, which are included in the commission rate. The Adviser has adopted policies and procedures intended to seek best execution on an ongoing basis for securities transactions, based upon the aforementioned factors. Senvest has discretionary investment authority pursuant to the investment management agreements or other governing documents applicable to each client. The Adviser has discretion to select the executing broker or dealer for any single transaction and the commission rates and commission equivalents charged for the transactions. Soft Dollar Benefits Senvest receives research or other products or services other than execution from a broker-dealer and/or a third party in connection with client securities transactions. This is known as a “soft dollar” relationship. From time to time, the Adviser causes its clients to pay broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transaction) for effecting Fund and/or Managed Account transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. The Adviser will effect such transactions, and receive such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934 (“Section 28(e)”), as amended, and subject to prevailing guidance provided by the SEC regarding Section 28(e). When the Adviser uses client brokerage commissions (or markups or markdowns) to obtain research or other products or services, the Adviser receives a benefit because it does not have to produce or pay for such products or services. The Adviser has an incentive to select or recommend a brokerdealer based on the Adviser’s interest in receiving research or other products or services, rather than on its clients’ interest in receiving most favorable execution. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by one or more Funds or Managed Accounts are used by the Adviser to service one or more other clients, including clients that may not have paid for the soft dollar benefits. The Adviser does not seek to allocate soft dollar benefits to client accounts in proportion to the soft dollar credits the client accounts generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to the Adviser (i.e., a “mixed use” item), the Adviser will make

a good faith allocation of the cost which may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest exists by reason of the Adviser’s allocation of the costs of such benefits and services between those that primarily benefit the Adviser and those that primarily benefit the Funds and/or Managed Accounts. During the Adviser’s last fiscal year, as a result of client brokerage commissions, Senvest and/or its affiliates acquired research and brokerage services, including: • Market data services, including real-time exchange data, company financials, and economic reports • Third-party investment research, including sector and industry analysis • Trading and execution services • Quantitative and technical research tools • Expert network services providing industry and sector-specific insights • Share recall services related to securities lending and borrowing activities • Alternative data services, including the acquisition and analysis of non-traditional datasets to support investment decision-making The Adviser participates in “client commission arrangements” pursuant to which Senvest would execute transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to the Adviser. The Adviser only receives products or research under these arrangements to the extent that such research or products are eligible under Section 28(e) and applicable regulatory interpretations. The proportion of the product or service attributable to assisting the Adviser in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by the Adviser from its own resources. Investment transactions for clients and the use of such commissions by the Adviser may be outside the safe harbor provided by Section 28(e) and applicable regulatory interpretations for one or more of the following reasons: the type of investment, the market mechanism or the market intermediary compensation involved in the transaction or the types of services obtained with the commissions paid for the transaction. Even when investment transactions for clients are outside the Section 28(e) safe harbor, the commissions paid will be used for the acquisition of research and brokerage services that fall within the guidance regarding Section 28(e). At least annually, the Adviser considers the amount and nature of research and 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 its Funds and Managed Accounts on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation, but can (and often does) exceed the suggested level, because total brokerage is allocated on the basis of all of the considerations described above. In no case will the Adviser make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if

any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. Brokerage for Client Referrals Neither the Adviser nor any related person receives client referrals from any broker-dealer or third party. However, as discussed above, subject to best execution, the Adviser utilizes, among other things, capital introduction and marketing assistance with respect to Investors in the Funds from broker-dealers. In no event will Senvest select a broker-dealer as a means of remuneration for recommending the Adviser or any Fund or other product managed by the Adviser (or an affiliate) or affording the Adviser with the opportunity to participate in capital introduction programs. As such, client referrals are not considered when making brokerage decisions. The Adviser does not recommend, request or require that a client direct the Adviser to execute transactions through a specified broker-dealer. Order Aggregation The Adviser often purchases or sells the same security for clients, including accounts for affiliates managed by Senvest, contemporaneously and at or near the same time and using the same executing broker. It is the Adviser’s practice, where possible, to aggregate orders for the purchase or sale of the same security submitted at or near the same time for execution using the same executing broker. Such aggregation is intended to enable the Adviser to obtain for clients a more favorable price or a better commission rate based upon the volume of a particular transaction. In cases where trading or investment restrictions are placed on a Fund’s account, the Adviser may be precluded from aggregating that Fund’s transaction with others. In such a case, the Fund may pay a higher commission rate and/or receive less favorable prices than Funds who are able to participate in an aggregated order. When an aggregated order is completely filled, the Adviser generally allocates the securities purchased or proceeds of sale pro rata among the participating accounts, based on the purchase or sale order. The pro rata calculation will be affected by the relative size of the accounts. Adjustments or changes may be made under certain circumstances, including but not limited to efforts to avoid odd lots or excessively small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. If an aggregated order is only partially filled, the Adviser’s procedures provide that the securities or proceeds are to be allocated in a manner deemed fair and equitable to each client participating in the transaction. Depending on the investment strategy pursued and the type of security, this may result in a non-pro rata allocation to all participating clients. The Adviser or its Covered Persons may also participate in an aggregated order. Sometimes the Adviser places trades on an individual basis and does not attempt to group orders for multiple Funds

for the same security and type of trade in a single, combined order. Because in these situations the Adviser does not engage in the practice of aggregating orders, its clients generally would not receive the potential benefits of aggregation, such as lower commission rates and uniform pricing. As a result, some opportunities for reduced transaction costs and economies of scale generally would not be achieved.

In addition, Senvest provides periodic information updates to Investors regarding fund performance and significant investments from time to time. Investors may also reach out to Senvest with any questions on their account.

Please see Item 12 for further information on the Adviser’s “soft dollar” practices, including the Adviser’s procedures for addressing conflicts of interest that arise from such practices. Senvest has not engaged any third party placement agents (i.e., solicitors) to introduce prospective Investors to the Funds, but it may in the future. The fees and expenses of any third-party placement agents will be paid by the Funds, but will be reimbursed by Senvest by offsetting its Management Fees. At the present time, Senvest has not engaged any third party placement agents.

Specifically, several clients have invested in Senvest Cyprus Recovery Investment Fund. Prior to assuming discretion in managing a prospective client’s assets, Senvest enters into an Agreement that sets forth the scope of its discretion. Senvest adheres to all such requirements and has established policies and procedures designed to ensure that Senvest’s investments are in line with the scope of Senvest’s discretion and the investment mandate of each client. As noted in Item 12 above, Senvest has the ability to effect cross transactions between different client accounts, except where prohibited by an agreement or applicable law.

Both Senvest’s analysts and trader will be provided with voting service’s recommendation for each proxy vote. Unless a determination is made to vote against the recommendation, the securities will be voted in accordance with the proxy service’s recommendation. The CEO and/or a portfolio manager will have final approval of any instances when the Adviser determines that it will vote against the recommendations of the proxy voting service. The Adviser conducts due diligence on an annual basis to confirm that the proxy voting service is performing its work in a manner consistent with the Adviser’s policies and procedures. If Senvest detects a material conflict of interest in connection with a proxy solicitation, the Adviser will abide by the recommendation of the proxy voting service. Senvest conducts appropriate due diligence on the third-party proxy voting service on a periodic basis. In certain instances, Senvest has pledged to restrict its voting rights or otherwise forfeited its right to vote certain securities in order to avoid triggering certain regulatory thresholds or limit its ability to trade securities. In addition, Senvest may not vote proxies or may delegate proxy voting authority to an independent third party where the cost of doing so would exceed the expected benefits to the clients. All proxies that Senvest receives will be treated in accordance with these policies and procedures. A copy of Senvest’s written proxy voting policies and procedures, as well as a record of how Senvest has voted in the past, will be maintained and available for review upon request.