CVC Credit Partners, LLC: investment adviser

4. Advisory Business CVC Credit Partners, LLC, a Delaware limited liability company, which was originally formed on January 12, 2005, is a wholly owned subsidiary (through certain intermediate subsidiaries) of CVC Credit Partners Group Holding Foundation, a foundation incorporated under the laws of Jersey, Channel Islands (“CVC Credit Holding Foundation”). CVC Capital Partners plc wholly owns the sole beneficiary of CVC Credit Holding Foundation (i.e., CVC Management Holdings II Limited) and is a company incorporated in Jersey and listed on Euronext Amsterdam (the regulated market operated by Euronext Amsterdam N.V.) trading under the ticker symbol “CVC”. CVC Nominees Limited holds shares (legal title) in CVC Capital Partners plc both directly and indirectly (through CVC Capital Partners SICAV-FIS S.A. and Vision 2013 PCC). CVC Credit Partners, LLC’s global platform includes two relying advisers: CVC Credit Partners European Investment Fund Manager Limited, which is regulated by the Jersey Financial Services Commission, and CVC Credit Partners Investment Management Limited (“CVC Credit UK”), a separately-organized U.K. investment adviser regulated by the U.K. Financial Conduct Authority. CVC Credit Partners, LLC and its relying advisers are collectively referred to herein as (“CVC Credit Partners”). CVC Credit Partners is also under common ultimate control with the following other investment advisers (as described in more detail in Item 10 below):

CVC Credit Partners U.S. CLO Management LLC, which is regulated by the Securities and Exchange Commission, and CVC Credit Partners European CLO Management, LLP, which is regulated by the U.K. Financial Conduct Authority (collectively referred to herein as “CVC Credit CLO Management”). CVC Credit CLO Management focuses on the management of collateralized loan obligation vehicles. Both advisers are held under a separate ownership structure and are wholly-owned subsidiaries of CVC Credit Partners Global CLO Management Limited, a closed ended private limited liability company incorporated in Jersey. All the investment advisers constituting CVC Credit Partners and CVC Credit CLO Management are collectively referred to herein as (“CVC Credit”).

CVC Advisors (U.S.), Inc. is an SEC-registered investment adviser and is wholly-owned by CVC Advisers (Luxembourg) Sàrl, which is principally held, through various intermediate subsidiaries, by CVC Capital Partners Advisory Group Holding Foundation, a foundation incorporated under the laws of Jersey, Channel Islands. CVC Advisers Jersey Limited1 is a limited company incorporated in Jersey, Channel Islands. CVC Advisers Jersey acts as investment adviser to certain CVC private equity funds (each, a “CVC Capital Fund” or “CVC Fund”). Local CVC-affiliated sub-advisers organized in Europe, Asia and the Americas (including CVC US) make investment recommendations to CVC Advisers Jersey investment committees and cost approval committees. The investment advisers constituting CVC Capital Partners are collectively referred to herein as (“CVC Capital” or “CVC Capital Partners”). As used in this brochure, these terms do not include portfolio companies of the investment funds advised by CVC Capital. CVC Credit and CVC Capital are under common control of CVC Nominees Limited.

CVC Secondary Partners (U.S.), LLC and CVC Secondary Partners, LLP, a private markets firm focused on discretionary investments in the secondary market globally (collectively “CVC Secondary Partners”). CVC Credit and CVC Secondary Partners are under common control of CVC Nominees Limited.

In July 2024, CVC Advisers Luxembourg (as defined below) acquired a majority shareholding in DIF Capital Partners (which was rebranded “CVC DIF” in July 2024). The first tranche of the transaction closed in July 2024, following which CVC owns 60% of the shares in CVC DIF. The remaining 40% will be acquired by CVC in December 2026 (20%) and December 2028 (20%).

As of July 1, 2026, all voting interests in CVC Marathon, formerly Marathon Asset Management, L.P., were acquired by CVC Capital Partners plc through various subsidiaries. CVC Marathon

CVC Advisers Jersey has filed with the SEC as an exempt reporting adviser. Form ADV 2A | Page 4 of 80

implements a variety of strategies in the global public and private credit markets, including direct lending, asset-based lending, and opportunistic credit, along with multi-asset public credit that includes broadly syndicated loans, CLOs, high yield, emerging markets, and structured credit. CVC Credit, CVC Capital, CVC Secondary Partners, CVC Marathon and CVC DIF collectively are referred to herein as “CVC”. CVC Credit provides investment advisory and sub-advisory services to investment vehicles, including collateralized loan obligations and collateral debt obligations (collectively, “CLOs”), other co-investment funds and collective investment vehicles (“Managed Funds”), and separately managed accounts for institutional investors on a discretionary and non-discretionary basis (“Managed Accounts”), together CVC Credit’s (“Clients”). CVC Credit’s Clients pursue primarily (i) U.S. and European Liquid Credit strategies (such as broadly syndicated bank loans, secured and leveraged loans, floating rate loans, second lien loans, corporate and high yield bonds, convertible bonds) (“Liquid Credit”), and (ii) Private Credit strategies focusing on direct lending (privately negotiated loans to mid-market companies) and capital solutions/special situations (primary junior capital) (“Private Credit”). In the pursuit of these strategies, CVC Credit will also utilize currency forwards and other derivative instruments on behalf of its Clients. CVC Credit generally provides investment advisory services under the terms of specific offering documents and other analogous governing documents (i) a collateral management agreement and indenture in the case of CLOs; (ii) a limited partnership agreement or an investment management agreement in the case of Managed Funds; and (iii) an investment management agreement or similar written agreement(s) in the case of Managed Accounts (together, “Client Agreements”). CVC Credit negotiates these documents, which set forth the specific services that will be provided by CVC Credit, with Clients before the commencement of the relevant advisory relationship. CVC Credit may also negotiate side letters with individual Managed Fund investors to accommodate specific reporting, regulatory, and similar requirements. Each of the CLOs, Managed Funds and Managed Accounts for which CVC Credit provides investment advisory services may impose investment guidelines and limitations on the types of securities and other instruments in which each portfolio may invest. In particular, each CLO for which CVC Credit provides investment advisory services is governed by an indenture that places significant restrictions on the types of securities and other instruments that may be purchased on behalf of the CLO. CVC Credit does not participate in wrap fee programs. As of December 31, 2025, CVC Credit Partners had approximately $61,600,000,000 billion of assets under management. Of the total assets under management, approximately $60,400,000,000 billion is managed on a discretionary basis, with the remainder managed on a non-discretionary basis. Certain Managed Accounts, pursuant to the terms of their investment management agreements, require CVC Credit Partners to provide notice of any proposed investments. In such cases, the Managed Account Client has the right to reject any investment proposed by CVC Credit Partners.

5. Fees and Compensation As a general matter the Client Agreements for each Client detail the fees payable by such Client. These fees are typically negotiated, will vary from Client to Client, and typically include a management fee and incentive fees, which are at the rates and under the terms described in the relevant governing documents. The discussion below summarizes representative fee arrangements for each type of Client. All fees are negotiated with CLOs, Managed Funds and Managed Accounts before the advisory relationship commences. The governing documents of each CLO, Managed Fund and Managed Account include detailed information regarding fees and expenses paid by the Client. Clients and investors should review the provisions related to fees and expenses in the relevant governing documents and offering materials for further information regarding the nature and total amount of fees and expenses they will incur. All Clients, including Managed Accounts, will incur

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expenses that are allocated among multiple Clients or among Clients and CVC Credit, in the manner described below. Investors in Managed Funds and CLOs will indirectly bear fees and expenses of the Managed Fund or CLO, including a pro rata share of the fees and expenses described below, for the time period they are invested in the Managed Fund or CLO. The amount and nature of fees and expenses incurred by Managed Funds and CLOs, and indirectly borne by investors, can vary significantly. Fees CLOs With respect to its CVC Credit-managed CLOs (“CVC Credit CLOs”):

CVC Credit receives a senior management fee that is typically up to 20 basis points, calculated as a percentage of assets under management of such CVC Credit CLO.

CVC Credit receives a subordinated management fee that is typically up to 35 basis points and is calculated as a percentage of assets under management of such CVC Credit CLO.

CVC Credit also charges the CVC Credit CLOs an incentive fee, which is generally 20% of distributions which would otherwise be payable to the equity class of securities for each CVC Credit CLO when such class of securities has achieved a specified internal rate of return on investment.

Managed Funds With respect to its Managed Funds:

CVC Credit Partners receives a management fee, typically up to 150 basis points of assets under management or net invested capital.

CVC Credit Partners also charges certain Managed Funds performance fees or carried interest, of up to 20% of the overall profits of the account. Performance fees typically are payable subject to such Managed Fund’s investments exceeding a specified internal rate of return on investment.

Managed Accounts With respect to its Managed Accounts:

CVC Credit Partners receives a management fee that is typically up to 75 basis points of assets under management or net invested capital.

CVC Credit Partners also charges certain Managed Accounts performance fees or carried interest, of up to 15% of the overall profits of the account. Performance fees typically are payable subject to such Managed Account’s investments exceeding a specified internal rate of return on investment.

All fees attributable to CVC Credit CLOs are paid quarterly to CVC Credit by independent trustees for the CLOs in accordance with the terms of the applicable indenture. The management fee attributable to each CLO is calculated by the trustee and confirmed by CVC Credit. Base management fees and incentive fees attributable to Managed Funds and Managed Accounts are paid quarterly (with respect to the management fees) and annually (with respect to incentive fees) to CVC Credit Partners by the Client or an independent third-party custodian. Certain Managed Funds are required to pay base management fees quarterly in advance of the calendar quarter. If an investor in a Managed Fund redeems that interest during the quarter (as opposed to the end of the quarter), the investor is entitled to a pro-rata share of unearned management fees.

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CVC Credit Subscription and Servicing Fees In respect of certain Clients, certain distributors or other financial intermediaries through which an investor acquires an interest in such vehicle may charge such investor upfront selling commissions, placement fees, subscription fees, administrative fees or similar fees (“Subscription and Servicing Fees”). In certain circumstances, the Subscription and Servicing Fees may be paid to CVC Credit or a Client and reallocated, in whole or in part, to the distributor or other financial intermediary through which an investor acquires an interest in such vehicle. Further details with respect to Subscription and Servicing Fees for a specific Clients are included in such vehicle’s governing and/or offering documents. Types of Expenses Charged to CVC Credit Clients CVC Credit’s advisory fees are not inclusive of all the fees and expenses that Clients (and, indirectly, investors) may pay. The fees and/or expenses that Clients may possibly pay will typically fall into three general categories: (1) organizational expenses, (2) operational expenses, and (3) investment-related expenses. A summary of these expenses, which is not intended to be exhaustive, is provided below. The relevant Client Agreement may set forth specific expenses that will (or will not) be borne by a Client, and the provisions of Client Agreements will supersede this brochure to the extent of any direct conflict. Organizational Expenses Organizational expenses typically include fees, costs and expenses in connection with establishing and organizing a Client. This expense category generally includes the following:

Legal, accounting, and filing fees, costs and expenses incurred in connection with the formation, organization and establishment of, or sale of interests in, the Client and its general partner (if any);

Expenses incurred in connection with any amendments, restatements or other modifications to, or the monitoring of compliance with, Client Agreements, side letters and other constituent or related documents of the Client and the general partner (if any) and other comparable compliance and compliance monitoring-related activities, including compliance with any applicable environmental, social and governance and climate change related requirements;

Fees, costs and expenses incurred in connection with the marketing and offering of interests in the Client (including legal, accounting, filing, access to, and use of, databases, client relationship management systems (“CRM”) or data rooms for posting the Client documents and due diligence materials, travel and travel-related expenses (which may include expenses for the use of first-class (or private aircraft where equivalent in price) or business class travel or the equivalent on domestic or short-haul flights (e.g., U.S. domestic or European regional flights) and equivalent ground transportation), accommodations, closing dinners, meals, and entertainment expenses incidental to roadshows and printing); and

Any CVC Services (as defined below) that would be organizational expenses pursuant to any of the foregoing. Please refer to the sub-heading “Services by CVC and/or CVC Personnel” below for further details on such in-house services.

In addition, CVC Credit is subject to regulatory requirements that include provisions that can be vague or ambiguous and that permit more than one reasonable interpretation. CVC Credit’s determination of how to interpret such provisions as they relate to a Client could be expected to impact the amount of regulatory compliance or other costs that are allocated to that Client. While CVC Credit will interpret such provisions in good faith and in a manner consistent with its legal obligations (and, when appropriate, in consultation with external legal counsel), the interpretations CVC Credit adopts will not necessarily be, and need not be, the interpretations that lead to the least compliance costs being allocated to the Clients or their investors. Operational Expenses Operational expenses generally include ongoing fees, costs, expenses and liabilities (together with any applicable value-added tax (“VAT”)) incurred directly or indirectly in connection with operating a Client Form ADV 2A | Page 7 of 80

portfolio, including those that are transactional and regulatory in nature. generally includes the following, to the extent permitted by applicable law:

This expense category

Legal, accounting (including third-party accounting services and systems), bookkeeping, consulting, rating agency, asset assignment and settlement, tax preparation and filing (including Schedules K-1), independent appraisal, audit, other professional fees;

Costs, expenses and liabilities of a Client in respect of administration, reporting (including the use of CRM), custody, management, systems used for monitoring of investment guidelines, operation, termination, liquidation, winding up and dissolution, including the costs and expenses of legal and tax advisers, administrators, auditors and consultants incurred in connection therewith;

Costs and expenses incurred in connection with tax, legal and regulatory compliance relating to the Client’s activities (including, without limitation, regulatory filings of the general partner (if any), CVC Credit and their affiliates relating to the Client’s activities), information, and communication;

With respect to Managed Funds, the salary and benefits of personnel reasonably necessary for the maintenance of such entities, or other personnel and overhead costs or expenses in connection therewith including third-party directors’ fees and expenses;

Costs and expenses associated with reports, disclosures, and filings prepared in accordance with applicable US (SEC, CFTC and IRS) and non-US (FCA, CSSF, ESMA) regulations, including but not limited to Form PF, the Alternative Investment Fund Managers Directive (“AIFMD”), the Markets in Financial Instruments Directive II (“MiFID II”), or any other regulatory requirement (including, without limitation, regulatory and “blue sky” filings), and any costs associated with outsourcing the completion of such reports;

Costs and expenses of any litigation and other extraordinary expenses relating to the Client or an entity in which investments are made by the Client;

Costs and expenses attributed to holding any meetings (including annual investor conferences) of the Client, including the Client’s investors and the Client’s board of directors or advisory committee (including expenses related to transportation, accommodations, meals, events, and entertainment);

Insurance premiums and fees (including directors’ and officers’ liability and errors and omissions liability);

Interest on and fees, costs and expenses associated with certain strategies involving the use of leverage and borrowings (including interest on principal, fees and other costs), guarantees or other indebtedness incurred by the Client (or a financing subsidiary thereof);

Costs and expenses incurred in connection with the usage of data service providers such as Bloomberg terminal fees, Markit/WSO fees and other expenses incurred in connection with data services providing price feeds, news feeds, securities and company information, company fundamental data, and S&P Index Alerts;

Fees and expenses in connection with the settlement of loans, trade executions and other trade related documentation (including expenses incurred in connection with legal counsel, expert review of loan documents, and any vendors or service providers);

Fees and expenses of directorship services provided to Clients, their general partners, and any special purpose vehicles;

Information technology system expenses (including the costs of acquiring, developing, implementing and maintaining specialty and custom computer software and hardware and

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other technological systems for the benefit of a Managed Fund, its investors, or a portfolio investment or potential investment);

Employees, delegates, independent agents, lawyers, accountants, appraisers, nominees, consultants, intermediaries, valuers, lenders, banks, administrators, custodians, depositaries, auditors, investment professionals, financial advisers and/or other financial institutions, data providers, expert network firms and other professional service providers or advisors, including finders, investment bankers, tax advisers and brokers (including legal fees and regulatory compliance costs incurred in connection with the engagement of any such professionals for a Client), who, in each case, may be CVC entities and/or CVC personnel provided that such CVC entities and/or CVC personnel are engaged on arm’s length terms;

Any administrators, custodians and depositaries (who, in each case, may be CVC entities and/or CVC personnel, provided that such CVC entities and/or CVC personnel are engaged on arm’s length terms) in relation to the safeguarding, administering and/or holding (or similar) of the assets of a Client and/or the performance of any functions of a custodian and/or depositary contemplated by the Directive 2011/61/EU of the European Parliament and of the Council on Alternative Investment Fund Managers and its implementing measures or any national private placement regime in any jurisdiction (the “AIFM Directive”); and

Any CVC Services (as defined below) that would be operational expenses pursuant to any of the foregoing.

Investment-Related Expenses Investment-related expenses generally include costs and expenses in connection with the pursuit or sourcing of particular investments and ongoing investment costs. This expense category generally includes the following, to the extent permitted by applicable law:

Costs and expenses of identifying, investigating (including, without limitation, conducting diligence) evaluating, researching (including research-related travel), structuring and negotiating potential investments for a strategy (fees and expenses of any legal (including services of personnel insourced from external providers), financial, accounting, consulting or other advisors or lenders, investment banks and other financing sources and any deposits or down payments that are forfeited in connection with, or amounts paid as a penalty for, unconsummated transactions (i.e., “broken-deals”));

Costs and expenses relating to the holding, settlement, administering, monitoring, financing, refinancing, managing, disposing and hedging of investments (including proposed but unconsummated investments), brokerage commissions, sourcing agent fees, clearing and settlement charges, syndication fees, arranger fees, pricing and valuation fees (including appraisal fees), underwriting commissions and discounts, interest and investment fees, transaction fees, breakup fees, investment banking fees, advisory fees, bank charges, other investment costs and expenses related to closing, execution and transaction costs, custodial, trustee, transfer agent, recordkeeping and other administrative fees, origination fees, commitment fees, rating agency fees, collateral management fees, facility fees, float fees or similar fees;

Fees, costs and expenses of attending conferences or similar meetings in connection with the sourcing and evaluation of potential investments on behalf of Clients, even if such expenses are not related to a specific transaction and irrespective of whether any such investment is ultimately consummated;

Any travel-related expenses related to or arising from the discovery, evaluation, investigation, development, acquisition or consummation, ownership, maintenance, monitoring, hedging, or disposition of investments, including potential investments (which includes ground transportation, meals, accommodation, and travel expenses for the use of business class travel);

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Fees, costs and expenses for other third-party research, specialty data subscription and license-based services and risk analysis software, industry information, analytics and expert networks/research resources incurred in connection with the sourcing or evaluation of investments for Clients, including any research or other service that may be deemed to be bundled for the benefit of a Client;

Fees, costs and expenses of consultants, including senior advisors and industry advisors, and other technical consultants; where a consultant charges a retainer fee and, in addition, a sourcing or a success fee which is paid in respect of specific investments or potential investments, the retainer fee will typically be borne by CVC Credit Partners, and the sourcing or success fee will typically be borne by the Clients participating (or potentially participating in) the relevant investment opportunity;

The costs and expenses associated with attendance at meetings, such as board meetings or steering committee meetings in connection with borrower investments made on behalf of Clients;

Investment-related expenses incurred in connection with sourcing or due diligence for transactions that are not consummated;

Travel and accommodation expenses for CVC Credit personnel and third-party providers incurred in connection with a broken deal;

Any reverse breakup fees

Any CVC Services (as defined below) that would be investment-related expenses pursuant to any of the foregoing.

Expense Allocation and Attribution Certain expenses are incurred on behalf of multiple Clients, and on occasion, an expense will be incurred on behalf of CVC Credit or an affiliate of CVC Credit as well as one or more Clients. To address the potential conflicts of interest associated with the allocation of such expenses, CVC Credit has adopted an Expense Allocation Policy that generally provides that CVC Credit will seek to allocate expenses and fees equitably across all relevant Clients in accordance with CVC Credit’s contractual and fiduciary obligations. Consistent with this policy, CVC Credit will exercise good faith discretion in determining the proper allocation of expenses between CVC Credit and the relevant Client or between two or more Clients in a manner that is fair and reasonable under the circumstances (which may involve lending more weight to one guideline or factor contained in the policy than to others), based on its good faith consideration of relevant factors and in accordance with its contractual and fiduciary obligations. Under the policy, the allocation of expenses will generally be determined by CVC Credit based on the following factors:

the extent of each Client’s utilization of the services associated with such expense;

the relative benefit to each Client that is derived from such expense (or that is expected to be derived from such expense);

with respect to transactions and broken deals, the size or expected size of each Client’s participation in the transaction; and

the relationship of such expense to the legal, contractual or other obligations of each of the Clients.

In applying these factors, CVC Credit will generally allocate expenses according to the following standards, subject to the relevant Client Agreement.

Services by CVC: CVC Credit or an affiliate of CVC Credit will, in some cases, incur, charge, attribute, or allocate fees costs and expenses to Clients for services performed by a supervised Form ADV 2A | Page 10 of 80

person of CVC, which may be organizational expenses, operational expenses, or investmentrelated expenses (“CVC Services"). CVC Services include fees, costs and expenses associated with the provision of in-house services (including any related costs incurred in connection therewith) including, without limitation, fund administration, reporting, legal services, regulatory services, accounting services, sustainability-related services (including transactionrelated expenses, expenses in connection with the collection and benchmarking of data and preparation of filings, reports, disclosures and notices prepared in connection with the SFDR and any other similar legislation or regulation, and portfolio monitoring expenses), tax services (e.g., tax compliance, tax oversight, tax structuring and tax reporting), information technology, data science services, core tech stack and infrastructure services, cybersecurity, artificial intelligence, digitalization services, hedging, currency and treasury management, transfer pricing, and other similar services performed for the benefit of a Managed Fund, Managed Account, or CLO and/or portfolio investment, in each case to the extent permitted by the applicable Client Agreement. The allocation of CVC Services to Clients creates a conflict of interest as CVC Credit may effectively recoup a portion of its employee compensation costs through this practice. To mitigate this conflict, CVC Services may be allocated by CVC Credit to one or more Clients only to the extent that any such CVC Services to be borne by the Client are no less favorable to the Client than could be obtained in arm’s length negotiation with unrelated third parties for similar services, as determined by CVC Credit pursuant to its Expense Allocation Policy. CVC Credit will determine the value of CVC Services using a methodology it considers fair and reasonable, consistent with its Expense Allocation Policy. Such “arm’s length”, “market” or similar rates or terms referred to herein will be determined by CVC Credit in good faith, having regard to any rates or terms that it has determined in its good faith discretion to be reflective of the range of rates in the applicable or related markets and, consequently, CVC Credit is not required to undertake any minimum amount of benchmarking. CVC Credit takes into account a variety of considerations when determining the extent to which fees, costs and expenses are to be allocated to a Client (and the extent to which fees, costs and expenses may be allocated to any other Client or CVC Fund), and uses methods that it believes are fair and reasonable. CVC Credit’s in-house expense calculation and allocation processes are expected to rely on certain judgments and assessments that in turn are based on information and estimates from various inputs, and the calculations and allocations that result may not be exact. In addition, relevant comparisons may not be available (or obtaining them may otherwise not be feasible) for a number of reasons, including as a result of a lack of a substantial market of providers or users of such services or the confidential or bespoke nature of such services. Any methodology, or choice among methodologies, involves potential conflicts of interest which will not necessarily be resolved in a Client’s favor, and the use of any particular methodology may lead a Client to bear relatively more costs in certain instances and relatively less costs in other instances compared to what the Client would have borne if a different methodology had been used. In the future, CVC Credit may use additional or different methodologies to allocate fees, costs and expenses in a manner that it determines to be fair and reasonable. CVC Credit or an affiliate thereof and/or such CVC Credit personnel or the personnel of such affiliate may receive an arm’s length fee from a Managed Fund, Managed Account, or CLO and/or portfolio investment (as applicable) in return for providing the services described in the preceding paragraph and CVC Credit or an affiliate thereof and/or its or their personnel will not be required to account to such Managed Fund, Managed Account, or CLO and/or portfolio investment (as applicable) for any such fees.

Expenses that are obligations of CVC Credit and not obligations of any Client are allocated solely to CVC Credit. These include payroll and employee benefits, office expenses, and other expenses incurred in connection with the operations of CVC Credit (except to the extent such expenses are paid indirectly as a result of the allocation of CVC Services to a Managed Fund, Managed Account, or CLO).

Organizational, operational, and investment-related expenses incurred solely by, or on behalf of, a single Client are allocated, in whole, to that Client.

Expenses that are attributable to more than one Client are allocated between and among such Clients in a manner that is fair and equitable based on the factors described above. Barring unusual circumstances, broken-deal expenses will be allocated according to the Client’s Form ADV 2A | Page 11 of 80

expected allocation to the transaction. Feeder funds generally will bear their own expenses, as well as a pro rata share of all master fund expenses based upon their relative percentage of ownership of such master fund. Expenses that benefit all Clients in a particular CVC Credit investment strategy (including, for example, research subscriptions, publications, and other third-party vendors contracted to provide company and industry level research) are typically allocated to all Clients within that strategy in a manner that is fair and equitable over time on the nature of the expenses and the benefit derived therefrom.

Where co-investors have been permitted to participate in investments, expenses associated with such investments will typically be allocated to such co-investors and among Clients according to the factors set forth above or as prescribed in the Client Agreements. CVC Credit or the GP of a Managed Fund will determine whether potential co-investors that may have participated in in an investment will be allocated deal-related expenses, including but not limited to break-up fees, incurred with respect to such investment. In making this determination, CVC Credit (or the GP of the Managed Fund) will consider, among other matters, whether the potential co-investor committed to participate in the investment, and whether the potential coinvestor agreed to bear (or to not bear) a portion of any ongoing deal related expenses. The foregoing will in some circumstances result in Clients bearing more than a pro rata share of such expenses.

Expenses attributable to CVC Credit and one or more Clients will generally be allocated in the same manner as expenses allocated among Clients, except that the scope of benefit to CVC Credit shall also be considered when making the allocation. In addition, when CVC Credit engages consultants and vendors for deal sourcing purposes, CVC Credit will typically pay any retainer fee, and the applicable Client(s) who participate in the investment will typically pay the deal sourcing fee.

In circumstances where an expense is allocated amongst various Clients and/or a portion of an expense is allocated to CVC Credit, the Expense Allocation Policy requires a review of each allocation by CVC Credit’s compliance department. The allocation methodology used for recurring expenses is reviewed on a periodic basis by the Finance and Compliance departments. CVC Credit’s Expense Allocation Policy also provides for the periodic testing and review of expense allocations to assess the appropriateness of CVC Credit’s expense allocation practices.

6. Performance Based Fees and Side-by-Side Management CVC Credit may charge both management fees based on the value of assets under management and performance-based fees (meaning, fees based on a share of capital gains on or capital appreciation of assets, “Incentive Fees”) to certain of its Clients. Certain investors in Managed Funds do not pay fees, and others incur lower or no Incentive Fees. The Incentive Fees often differ from one Client to another, as well as among investors in the same Managed Funds. The payment by some, but not all, Client of Incentive Fees or payment of Incentive Fees at varying rates creates an incentive for CVC Credit to disproportionately allocate time, services or functions to Clients paying Incentive Fees or Clients paying Incentive Fees at a higher rate, or allocate investment opportunities to such Clients. Please see Item 10 for additional information on allocation and how conflicts of interest are generally addressed by CVC Credit. Opportunities may arise for individual investors, or other third parties, to co-invest in parallel with a Managed Fund on terms to be agreed, which are expected to provide for lower or no management fees and/or carried interest than those paid by Managed Funds. There is no guarantee that any Managed Fund investor will be granted co-investment opportunities.

7. Types of Clients CVC Credit provides investment advice to CLOs, Managed Funds and Managed Accounts. Managed Account Clients and investors in CLOs and Managed Funds include high net worth individuals, banks, thrift institutions, pension and profit-sharing plans, sovereign wealth funds, trusts, estates, charitable organizations, university endowments, corporations, limited partnerships and limited liability companies or other business entities. Investments in CLOs and Managed Funds are generally only available to institutional investors, professional investors, wholesale investors and certain high-net worth investors Form ADV 2A | Page 12 of 80

who are qualified purchasers or can be opted up to professional investor status. Acceptance of nonUS investors into CVC Credit Partners’ Managed Funds also generally requires qualification as an institutional investor under local regulatory requirements of the jurisdiction in which they are based. CVC Credit Partners’ Managed Funds generally have a specific minimum investment amount, which is set forth in their Investment Agreements. Certain Clients are not registered or required to be registered under the Investment Company Act, and their securities are not registered or required to be registered under the Securities Act and their securities will be privately placed to qualified investors in the United States and elsewhere. Certain of the Clients have a specified minimum initial investment as set forth in their offering documentation; such minimums range from $25,000 to $10,000,000. Details concerning applicable investor suitability criteria are set forth in the relevant Client’s offering documents.

8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Portfolio Management CVC Credit manages its Clients in accordance with their investment strategy, applicable Client Agreements, and other governing documents. Certain strategies and agreements may place more significant restrictions on CVC Credit’s ability to make certain investments. In analyzing investments, CVC Credit employs fundamental credit research with respect to each of the loans, bonds, and securities held in (or considered for) the CLOs, Managed Funds and Managed Accounts for which CVC Credit provides investment advisory services (the issuers or borrowers of such instruments are generally referred to as “borrowers” in this Item 8). CVC Credit operates a rigorous, multi-stage, bottom-up, investment process which is bifurcated between the Private Credit and Liquid Credit investment teams, with separate investment committees for each platform of the business. The investment team seeks to maintain a highly selective and systematic investment approach. The investment process concentrates on fundamental credit and technical market analysis to evaluate the portfolio suitability of each potential investment, in order to seek to identify, mitigate and manage risks. Critical to the assessment of each investment opportunity is the work done on the fundamental credit worthiness of the borrower, focusing on business risk, financial risk, and structural risk. This is evaluated through extensive analysis and due diligence on the borrower which underpins the entire investment process. CVC Credit utilizes multiple sources of information in analyzing investments, including but not limited to: 1) management presentations, annual reports, detailed cash flows underwriting & analysis, legal due diligence, third-party due diligence, prospectuses and credit agreements, regulatory filings filed with U.S. and foreign regulators and company press releases; 2) newswires, research material prepared by broker-dealers and third-party research providers, and corporate rating services; 3) third-party consultants, expert networks, lawyers, accountants, commercial and investment banks, financial intermediaries, other investment and advisory institutions and its direct and indirect contacts through its association with CVC. CVC Credit personnel may participate in on-site visits, borrower management meetings, sponsor lead roadshows, creditors’ committees, industry groups, or steering committees or may sit on the boards of directors of Client held investments. CVC Credit will seek to leverage CVC’s network of relationships and capital resources across Europe and the United States to identify and participate in investment opportunities. In connection with the evaluation of potential investment opportunities, CVC Credit may engage with individuals retained by certain expert networks. To mitigate and manage the risk of receiving non-public information from these sources, CVC Credit has implemented policies and procedures designed to avoid inadvertently obtaining proprietary and/or confidential information from its interactions with all information sources, including CVC, industry contacts, as well as expert network consultants. Credit monitoring is actively performed on an ongoing basis with both formal and informal updates provided typically several times a week at various investment committee meetings. CVC Credit believes that effective investment management requires a consistent, disciplined and proactive approach to collecting the necessary details regarding: (i) borrower financial and operational performance; (ii) macroeconomic factors that affect and drive the borrower’s operating environment; and (iii) the competitive landscape. The ability to monitor performance at a very granular level in an accurate and Form ADV 2A | Page 13 of 80

timely manner is critical, and reliant upon access to high quality data in order to reduce risks and highlight opportunities. CVC Credit, where possible, seeks to establish and build strong relationships with management teams and sponsors to increase the investment team’s understanding of the issuer and industry dynamics. In addition to a detailed assessment of the operational performance of an investment, this monitoring process includes an evaluation of macroeconomic, credit specific and eventdriven factors for each investment, the results of which the investment team will utilize to make decisions on the appropriate action for each respective investment. In all situations, relative value analysis and focus on acceptable risks and returns are considered when determining whether a position should remain in a portfolio. To the extent consistent with its fiduciary responsibilities, CVC Credit may integrate sustainability considerations into its investment analysis when reviewing an investment opportunity and during the lifecycle of an investment. CVC Credit’s evaluation of sustainability considerations will vary as a result of certain factors bespoke to each investment, including, among others, the level of control and influence, investment approach, and engagement activities related to an investment that CVC Credit is able to undertake. Notwithstanding the foregoing, CVC Credit does not intend to invest exclusively in issuers that actively pursue sustainability-related goals, unless expressly stated as the investment objective of the Client account and expects to make investments in cases where it has limited or no ability to evaluate or manage sustainability considerations. Investment Strategies The investment strategies employed by CVC Credit in the management of its CLOs, Managed Funds, and Managed Accounts are more fully set forth in the Client Agreements. General Risks Risk of Loss Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. While CVC Credit seeks to mitigate risks so that they are appropriate to the potential return for the Client or strategy, it is usually not possible or desirable to fully mitigate risks. Prospective investors or Clients should carefully consider the following risks, along with those risk factors described in the applicable governing documents. There can be no assurance that investment strategies will be carried out successfully. Investors of Clients should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. The governing documents of each investment program, including the offering memoranda for the Managed Funds and CLOs, more fully explain the material risks associated with the Credit strategies managed by CVC Credit. Investors in Managed Funds and CLOs should review these documents in addition to the risk summaries below. Strategy Risk Strategy risk is associated with the failure or deterioration of an investment strategy such that most or all investment managers employing that strategy suffer losses. Strategy specific losses may result from excessive concentration by multiple market participants in the same investment or general economic or other events that adversely affect particular strategies (for example, the disruption of historical pricing relationships). An investment strategy may fail, and it may be difficult for CVC Credit to amend an investment strategy quickly or at all should certain market factors appear, which may have a material adverse effect on the Client. Credit Risk Performance and investor yield on the interests may be affected by the default or perceived credit impairment of debt investments. Credit risks associated with such investments include among others: (i) the possibility that earnings of the obligor may be insufficient to meet its debt service obligations; (ii) the obligor’s assets declining in value; and (iii) the declining creditworthiness, default and potential for insolvency of the obligor during periods of rising interest rates and economic downturn. Any such investment may become defaulted for a variety of reasons, including non-payment of principal or interest, as well as breaches of contractual covenants. A defaulted investment may become subject to Form ADV 2A | Page 14 of 80

workout negotiations or may be restructured by, for example, reducing the interest rate, a write-down of the principal, and/or changes to its terms and conditions. Any such process may be extensive and protracted over time, and therefore may result in substantial uncertainty with respect to the ultimate recovery on the defaulted investment. In addition, significant costs might be imposed on the lender, further affecting the value of an investment. The liquidity in such defaulted investments may also be limited and, where a defaulted investment is sold, it is unlikely that the proceeds from such sale will be equal to the amount of unpaid principal and interest owed on that investment. This would have a material adverse effect on the value of the Client portfolio. In the case of secured loans, restructuring can be an expensive and lengthy process which could have a material negative effect on the anticipated return on the restructured loan. Financial Market Fluctuations General fluctuations in interest rates and the market prices of investments may adversely affect the value of the Client’s investments. Instability and volatility in interest rates and the debt, equity and other relevant markets may also increase the risks inherent in a Client’s investments. The ability of an underlying issuer to refinance debt may depend on the ability to sell new debt and equity in the market, to borrow from banks or do otherwise, which may not be achievable on favorable terms or at all. A deterioration of the global debt markets (particularly the E.U. and U.S. debt markets), any possible future failures of financial services companies or a significant rise in market perception of counterparty default risk will likely significantly reduce investor demand and liquidity for investment grade, high-yield and senior bank debt, which in turn is likely to lead some banks and other lenders to be unwilling or significantly less willing to finance new investments or to only offer financing for investments on less favorable terms than had been prevailing in the past. In recent years, U.S. and global financial markets and the broader current financial environment have been, and continue to be, characterized by uncertainty, volatility and instability. These financial market fluctuations have the tendency to reduce the availability of attractive investment opportunities for Clients and may affect the Clients’ ability to make investments and the value of the investments held by the Clients. Instability in the securities markets and economic conditions generally may also increase the risks inherent in the Clients’ investments. The public securities markets have seen increased volatility and the ability of companies to obtain financing for ongoing operations or expansions may be severely hampered by the tightening of the credit markets and the ongoing financial turmoil. It is unclear what the repercussions of this market turmoil may be. Moreover, it remains unknown whether governmental measures undertaken in response to such turmoil (whether regulatory or financial in nature) will have a positive or negative effect on market conditions. There can be no assurance that the market will, in the future, become more liquid than it is at present, and it may well continue to be volatile for the foreseeable future. The ability to realize investments depends not only on borrowers and their historical results and prospects, but also on political, market and economic conditions at the time of such realizations. In the past, many private equity funds have looked to the public securities markets as a potential exit strategy and there can be no assurance, particularly given the recent volatility in the financial markets and a potential lack of investor appetite for new issues in the public securities markets, that private equity funds will be able to exit from their investments in borrowers by listing their shares on securities exchanges, which could have an impact on the value of positions in Client accounts. The trading market, if any, for the securities of any borrower may not be sufficiently liquid to enable the borrower to raise capital or refinance positions without adversely affecting the value of positions in client accounts. Continued or renewed volatility in the financial sector may have an adverse material effect on the ability of the Clients to buy, sell and partially dispose of their investments. Clients may be adversely affected to the extent that they seek to dispose of any of their investments into an illiquid or volatile market, and a Client may find itself unable to dispose of investments at prices that CVC Credit believes reflect the fair value of such investments. The duration and ultimate effect of current market conditions and whether such conditions may worsen cannot be predicted and there can be no assurances that conditions in the financial markets will not worsen or adversely affect one or more of a Client’s borrowers. The ability of borrowers to refinance debt securities depends on their ability to sell new securities in the public high yield debt market or otherwise. Conditions in the credit markets, in particular, may have a significant impact on the business of CVC Credit. For example, the credit markets in the United States have experienced a variety of difficulties and changed economic conditions in recent years that have adversely affected the performance and Form ADV 2A | Page 15 of 80

market value of many securities and financial instruments. There can be no assurance that Clients will not suffer material adverse effects from broad and rapid changes in market conditions in the future. Although the continued unfolding of the credit cycle may result in attractive investment opportunities, CVC Credit may not be able to time its investments correctly, which could result in depreciation in values. Furthermore, market conditions could deteriorate further, and CVC Credit may be limited in its ability to realize investments already made due to difficulties in buyers’ ability to obtain financing on favorable terms, or to secure financing at all. Carried Interest The fact that CVC Credit, its affiliates and certain personnel receive carried interest based on the performance of a Managed Fund or other type of Client creates an incentive for CVC Credit to make investments that are more speculative than would otherwise be the case. Cybersecurity Risk Cyber security incidents and cyber-attacks have been occurring globally at a more frequent and severe level and will likely continue to increase in frequency in the future. CVC Credit’s, Clients’, the borrowers’ and our service providers’ information and technology systems may be vulnerable to damage or interruption from cyber security breaches, computer viruses or other malicious code, network failures, computer and telecommunication failures, infiltration by unauthorized persons and other security breaches, usage errors by their respective professionals or service providers, power, communications or other service outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. If unauthorized parties gain access to such information and technology systems, they may be able to steal, publish, delete, modify or prevent CVC Credit from accessing private and sensitive information, including non-public personal information related to investors (and their beneficial owners) and material non-public information. Although CVC Credit has implemented, and borrowers and service providers may implement or already have implemented, various measures to manage risks relating to these types of events, such systems could prove to be inadequate and, if compromised, could become inoperable for extended periods of time, cease to function properly or fail to adequately secure private information. CVC Credit does not control the cyber security plans and systems put in place by third-party service providers, and such third-party service providers may have limited indemnification obligations to CVC Credit and to borrowers, each of which could be negatively impacted as a result. Breaches such as those involving covertly introduced malware, impersonation of authorized users and industrial or other espionage may not be identified even with sophisticated prevention and detection systems, potentially resulting in further harm and preventing it from being addressed appropriately. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in CVC Credit’s, Clients’ and/or a borrower’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to investors (and their beneficial owners), material non-public information and the intellectual property and trade secrets of CVC Credit and/or borrowers and other sensitive information in the possession of CVC Credit and borrowers. CVC Credit, Clients and/or a borrower could be required to make a significant investment to remedy the effects of any such failures, harm their reputations, subject them and their respective affiliates to legal claims and adverse publicity and otherwise affect their business, financial performance and, indirectly, the performance of Client investments. Such incidents could cause Clients, CVC Credit or their service providers to incur regulatory penalties, reputational damage, additional compliance costs or financial loss. In addition, Clients and/or CVC Credit may incur substantial costs related to investigation of the origin and scope of a cybersecurity incident, increasing and upgrading cybersecurity protections including its administrative, technical, organizational and physical controls, acts of identity theft, unauthorized use or loss of proprietary information, adverse investor reaction, increased insurance premiums or difficulties obtaining insurance coverage, or litigation, regulatory actions or other legal risks.

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Similar types of operational and technology risks are also present for the companies in which Clients invest, which could have material adverse consequences for such companies, and may cause Clients' investments to lose value. CVC has established procedures and systems that we believe are reasonably designed to seek to reduce the risks associated with cybersecurity incidents. These efforts include encryption and next generation endpoint protection, IDS\IPS, bi-annual penetration and phishing testing, advanced two factor authentication and identify management systems, robust diligence as part of the vendor onboarding process, and a comprehensive cybersecurity training and education program. In light of the evolving nature of cybersecurity risks, there can be no guarantee that these efforts will succeed in avoiding or mitigating the potential impact of cybersecurity incidents, and CVC Credit cannot control the cybersecurity practices and systems of issuers or third-party service providers. In addition, as the use of technology has become more prevalent, CVC Credit and its Clients have potentially become more susceptible to operational risks through cybersecurity attacks. Anti-Money Laundering Regulatory Developments In August 2024, the United States Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule requiring certain registered investment advisers (“RIAs”) and investment advisers that report to the SEC as exempt reporting advisers (“ERAs”) to implement an anti-money laundering program, file suspicious activity reports, and to maintain additional records related to such activities. Implementation of the final rule is expected to impose increased compliance costs, regulatory obligations, and reporting burdens on investment advisers, including CVC Credit. Counterparty Risk Clients will be exposed to the credit risk of the counterparties with which CVC Credit and Clients transact. These parties may include trading counterparties, clearing agents, exchanges, clearing houses, custodians, prime brokers, trustees, administrators, and other financial intermediaries. These parties may default on their obligations to CVC Credit Clients due to bankruptcy, lack of liquidity, operational failure or other reasons and such failure of a broker may result in adverse consequences for the assets held by such party, which may in turn have an adverse effect on the value of the investments. Material Non-Public Information Investment professionals at CVC Credit may acquire confidential information concerning an entity in which Clients have invested, or in which CVC Credit is considering an investment on behalf of one or more Clients. Acquiring material, non-public information may limit CVC Credit’s ability to buy or sell particular securities or other instruments of the entity on behalf of a Client, and this in turn may limit the investment opportunities or exit strategies available to a Client. CVC maintains an information barrier to isolate and prevent communication of material, non-public information held by CVC Secondary Partners, Private Credit, CVC Capital Partners and/or CVC DIF on the one hand, to Liquid Credit on the other hand, except as expressly provided for in CVC’s information barrier procedures and subject to appropriate procedural oversight. The purpose of this information barrier is, among other things, to confine any material, non-public issuer-specific or price sensitive information obtained by CVC Secondary Partners, Private Credit, CVC Capital Partners and/or CVC DIF personnel, such that the investment activities of Liquid Credit are not restricted as a result of material non-public information being imputed to the personnel on the Liquid Credit side of the barrier. As a result of this information barrier, Liquid Credit personnel may not be able to use, act on or otherwise be aware of information that is known by or in the possession of the personnel of CVC Secondary Partners, Private Credit, CVC Capital Partners and/or CVC DIF. Collaboration between Liquid Credit personnel and CVC Secondary Partners, Private Credit, CVC Capital Partners or CVC DIF personnel may therefore be limited; this in turn may reduce potential synergies across CVC. CVC also presently maintains an information barrier to control the communication of material, nonpublic information and certain other information held by CVC Marathon on the one hand and the rest of

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CVC on the other. As a result, collaboration between CVC Marathon personnel and the rest of CVC may be limited, which in turn may reduce potential synergies across CVC. CVC Capital Partners, CVC Secondary Partners and CVC DIF will, consistent with procedures administered by CVC Compliance, share or receive information regarding borrowers, issuers, and funds with or from Private Credit. Private Credit will also receive information regarding borrowers and issuers from Liquid Credit consistent with procedures administered by CVC Compliance. This information may include material non-public information. Consequently, the investment activities of Private Credit may be restricted as a result of material non-public information held by CVC Capital Partners, CVC Secondary Partners, CVC DIF and/or Liquid Credit being imputed to personnel of Private Credit. Under certain circumstances, additional temporary information barriers may be put into place with respect to certain issuers, assets, personnel, or investment teams to manage the flow of information amongst the different investment teams of CVC Credit, CVC Capital Partners, CVC Secondary Partners and CVC DIF. Due to this information sharing, Private Credit may be restricted from transactions involving issuers about which CVC Capital Partners, CVC Secondary Partners, CVC DIF and/or Liquid Credit have confidential or non-public information. Consequently, Private Credit may not be able to buy or sell a particular security or other instrument on behalf of its Clients because one or more personnel of CVC Capital Partners, CVC Secondary Partners, CVC DIF and/or Liquid Credit possesses material, nonpublic information concerning the instrument’s issuer or the market for the issuer’s securities or other instruments. Similarly, in such circumstances, Private Credit may not be able to dispose of a security or other instrument owned by a Client, even in a declining market, until the information becomes publicly available or immaterial and the trading in the issuer’s securities or instruments is no longer restricted. CVC may in the future establish or modify these or other information barriers between one (1) division of CVC, on the one hand, and the rest of CVC on the other, or between the investment teams across divisions of CVC. Additionally, the terms of confidentiality or other agreements with or related to companies in which CVC has or has considered making an investment or which is otherwise an advisory client of CVC may restrict or otherwise limit the ability of CVC Credit to make investments in or otherwise engage in businesses or activities competitive with such companies. CVC may enter into one (1) or more strategic relationships in certain regions or with respect to certain types of investments that, although may be intended to provide greater opportunities for CVC, may require CVC to share such opportunities or otherwise limit the amount of an opportunity that CVC, including CVC Credit, can otherwise take. Trading in Possession of Information In connection with certain loan and securities transactions, CVC Credit may, to the extent permitted by applicable law, cause a Client to enter into agreements (commonly referred to as "big boy" letters) under which the parties acknowledge a possible information disparity and agree to proceed notwithstanding it. Such letters are intended to limit liability under applicable securities and common law, but the governing law continues to evolve and there can be no assurance that they will be effective to avoid liability. Public Company Holdings A Client’s investment portfolio may contain securities issued by publicly held companies. Such investments may subject the Client to risks that differ in type or degree from those involved with investments in privately held companies. Such risks include but are not limited to greater volatility in the valuation of such companies, increased obligations to disclose information regarding such companies, limitations on the ability of the Client to dispose of such securities at certain times, increased likelihood of shareholder litigation against such companies’ board members, including CVC Credit investment professionals, and increased costs associated with each of the aforementioned risks. Privately Held Companies Privately held companies generally maintain less comprehensive financial information than listed companies. Therefore, CVC Credit may make investment decisions, and monitor investments, after reviewing information which is less comprehensive than that available to an investor in a listed public

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company. A public market for investments may never develop, and it may be difficult for Clients to liquidate investments or find prospective buyers in the private market. Regulatory Risk CVC Credit cannot give any assurance that any individual borrower is, or will continue to be, fully compliant with all applicable regulations. This risk is more significant in the case of unlisted companies than listed companies. Additionally, unlisted companies are not regulated by equivalent levels of disclosure and investment protection regulations that apply to listed companies. Also, changes in regulatory conditions may adversely affect the marketability and financial performance of certain investments, which in turn may affect the distributions which a CVC Credit Client receives from such investments. Regulatory restrictions may reduce the number of investment opportunities available to Clients or result in a Client being unable to pursue certain elements of its investment strategy. Clients may make investments in borrowers operating in industries that are subject to greater amounts of regulation than other industries generally. These more highly regulated industries may include energy, healthcare, financial services (including banking and mortgage servicing), insurance, transportation (e.g., aviation) and businesses that serve primarily customers that are governmental entities. Investments in borrowers that are subject (or whose primary customers are subject) to greater amounts of governmental regulation pose additional risks relative to investments in other companies generally. Changes in applicable laws or regulations, or in the interpretations of these laws and regulations, could result in increased compliance costs or the need for additional capital expenditures and/or regulatory capital requirements in the case of banks or similarly regulated entities. If a borrower fails to comply with these requirements, it could also be subject to civil or criminal liability and the imposition of fines and other disciplinary measures. A borrower also could be materially and adversely affected as a result of statutory or regulatory changes or judicial or administrative interpretations of existing laws and regulations that impose more comprehensive or stringent requirements on such company. Governments have considerable discretion in implementing regulations that could impact a borrower’s business and governments may be influenced by political considerations and may make decisions that adversely affect a borrower’s business. Additionally, certain borrowers may have a unionized work force or employees who are covered by a collective bargaining agreement, which could subject any such company’s activities and labor relations matters to complex laws and regulations relating thereto. Moreover, a borrower’s operations and profitability could suffer if it experiences labor relations problems. Upon the expiration of any of such borrower’s collective bargaining agreements, it may be unable to negotiate new collective bargaining agreements on terms favorable to it, and its business operations at one or more of its facilities may be interrupted as a result of labor disputes or difficulties and delays in the process of renegotiating its collective bargaining agreements. A work stoppage at one or more of any such borrower’s facilities could have a material adverse effect on its business, results of operations and financial condition. Additionally, any such problems may bring scrutiny and attention to the relevant Client, which could adversely affect such Client’s ability to implement its investment objectives. Foreign Investment Controls General Foreign investment in loans and securities of companies in certain of the countries in which a Client may invest is restricted or controlled to varying degrees. Investments may, for example, be made in assets which are subject to local or national regulatory approval or oversight (including by bodies such as the Committee on Foreign Investment in the United States and similar regulatory bodies in other jurisdictions) which could place onerous obligations or other restrictions on a Client holding and/or realising such assets. For example, some foreign investment regimes require prior approval for certain inbound foreign investments, which, if applicable to an investment of a Client, may result in foreign regulatory review and approval prior to the acquisition of the investment. If such review and approval are required for an investment (or are otherwise deemed advisable in connection with an investment), CVC Credit may determine to disclose to the foreign regulatory authorities as part of the approval process the identities of investors who are considered to be affiliated with a foreign government or whose commitment to a Client exceeds a certain percentage of such Client’s aggregate commitments, as well as the identities of some or all other investors and/or their underlying beneficial owners (if applicable). Such disclosure requirements may extend to the investment activities of other Clients, where regulators may require disclosure of certain investors participating in Clients more generally and Form ADV 2A | Page 19 of 80

irrespective of their potential participation as an investor (indirectly via the relevant Client) in the relevant investment which has initiated the relevant regulatory review filing. The requirements for disclosure are subject to change and the foreign regulatory agencies may require the disclosure of the identities of all investors depending on government policy at that time and the nature of the investment. Some foreign investment regime approval processes may take four to six months or longer, and there may not be any statutory or other mandated timeframe for approval. In addition, other jurisdictions are in the process of ongoing reform (or may introduce future reform) that may establish further restrictions and increase risk by enhancing governments’ powers to scrutinise, impose conditions on, and potentially block mergers, acquisitions and other transactions. These requirements and disclosure processes may result in certain investors being excused or excluded from participating in certain investments, and/or delay or otherwise impact a Client’s acceptance and drawdown of commitments from certain investors and/or approval of transfers by or to certain investors, in each case to the extent deemed necessary or advisable by CVC Credit in order to avoid or minimise any potential significant delay in a Client consummating certain investments or any potential onerous obligation or restriction with respect to such fund holding certain investments. The foregoing requirements may also result in circumstances in which a Client experiences significant delays and incurs significant costs in respect of certain investment opportunities, is impeded or restricted from effecting a syndication or sale of certain investments to prospective buyers, and/or determines not to pursue certain potential investment opportunities in certain countries at all, all of which could adversely affect a Client’s ability to meet its investment objectives. Outbound Investment Rule In August 2023, the President of the United States issued an executive order setting forth the framework for outbound investment controls regulating U.S. investment in companies related to “countries of concern” deemed to be adverse to U.S. national security and foreign policy interests. Pursuant to this executive order, the U.S. Department of the Treasury has implemented a new outbound investment regime, the Provisions Pertaining to U.S. Investments in Certain National Security Technologies and Products in Countries of Concern (the “Outbound Investment Rule”), which took effect on January 2, 2025. The Outbound Investment Rule prohibits certain investments, and requires the notification of certain investments, by U.S. persons in persons and entities associated with “countries of concern” (currently only China, Hong Kong and Macau) that are engaged in certain covered activities in the semiconductors and microelectronics, quantum information technologies, and artificial intelligence sectors. Investments by U.S. persons subject to the Outbound Investment Rule include acquisitions of equity interests, certain debt financing, and establishment of joint ventures. The rule also applies to certain investments by a U.S. person as a limited partner in a non-U.S. person pooled investment fund that such U.S. person knows likely will invest in a person or entity that is associated with a “country of concern” and that is in the semiconductors and microelectronics, quantum information technologies, or artificial intelligence sectors. In addition, the Outbound Investment Rule prohibits a U.S. person from knowingly directing a transaction by a non-U.S. person that such U.S. person knows at the time of the transaction would be a prohibited transaction if engaged in by a U.S. person. If any potential transaction by a Client could be within the scope of the Outbound Investment Rule, CVC Credit or the general partner, as applicable, could take, or abstain from taking, actions as it deems necessary or advisable with respect to such transaction, including abstaining from engaging in any prohibited transactions or submitting certain notifications to the U.S. Department of the Treasury related to notifiable transactions. The Outbound Investment Rule could also potentially limit the range of prospective investments available to a Client, make it more difficult to identify buyers for sales transactions, impede or restrict syndication or sale of a Client’s assets to certain buyers, adversely affect the governance and operations of Client or its affiliates, and/or cause delays and costs, all of which could adversely affect a Client’s ability to meet its investment objective. Furthermore, given the Outbound Investment Rule’s infancy and its evolving interpretation and implementation, it is unclear how it, and any related future regulations, may be interpreted, amended, and implemented by the United States government. Therefore, CVC Credit cannot fully anticipate the scope or impact on Clients of the Outbound Investment Rule.

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Antitrust Risk Borrowers will be subject to antitrust and competition rules that apply in the United States and the countries or regions where they do business, and there has been increased scrutiny from antitrust regulators around the world. The application of those rules and the increased scrutiny by authorities could result in sanctions, fines or penalties, including civil damage actions, delays or other difficulties in consummating a Client’s investments or divestments. This could also negatively affect the CVC brand and reputation and could be distracting to management. This has become particularly true in Europe. There have also been governmental investigations and lawsuits alleging that certain club deals or consortium bids constituted an illegal attempt to collude and drive down the price on acquisitions. There can be no assurances that CVC, a Client or borrowers will not be subject to litigation or investigations involving consortium bids or allegations of other anticompetitive activity or a Client or the borrowers in which it invests will not be impacted. Corruption Risk Corruption remains a significant problem in some European countries in which Clients are expected to invest. Corruption can result in huge economic losses due to fraud, theft and waste. Moreover, corruption can corrode critical public institutions, such as the courts, law enforcement and public pension administration, undermining property rights, public confidence and social stability, its effects seriously constrain the development of local economies, and its macroeconomic and social costs are significant. As a result, corruption could dramatically increase the systemic risks in some of the jurisdictions in which Clients will invest. Corruption scandals in certain European countries are common and are likely to remain so going forward. In particular, there often exists insufficient anti-corruption legislation and co-ordination of anti-corruption initiatives. Clients and prospective investors are thus exposed to the increased costs and risks of corruption (which might include reputational risk for Clients and/or the investors) in the jurisdictions in which Clients might invest, and there can be no assurance that any reform efforts will have a meaningful effect during the term of such funds. Regulatory agency counterparties might have the right to terminate an agreement relating to a borrower where management or/or employees have committed bribery, corruption or another fraudulent act in connection with the investment by a Client in such borrower. Most capital put toward such an investment will not be compensated in these circumstances. In addition, activities of certain businesses that are conducted by a portfolio company in which a Client invests could be more susceptible to irregular accounting or other fraudulent practices. In the event of fraud by (or involvement with corrupt payments by) any company or issuer in which a Client invests, such Client could suffer a partial or total loss of capital invested in that company or issuer. U.S. Presidential Election The impact of past and future U.S. presidential and other elections could create significant uncertainty with respect to legal, tax and regulatory regimes in which CVC and its Clients operate. In particular, in January 2025, Donald J. Trump became President of the United States and the Republican Party came into control of Congress. The full scope of the government’s executive, legislative and regulatory agenda is not yet fully known, though changes in U.S. policy resulting from the new administration could result in a number of changes to U.S. and non-U.S. economic, national security, fiscal, tax and other policies, as well as the global financial markets generally. Any significant changes in, among other things, economic policy (including with respect to interest rates, foreign trade and regulatory changes leading to greater availability of bank debt), the regulation of the asset management industry, tax law, immigration policy and/or government entitlement programs could have a material adverse impact on Clients and their investments. Trade Policy Some foreign governments, including China, have in the past instituted retaliatory tariffs on certain U.S. goods and have indicated a willingness to impose additional tariffs on U.S. products in the future. Other countries, including Mexico, have threatened retaliatory tariffs on certain U.S. products. Global trade disruption, significant introductions of trade barriers and bilateral trade frictions, together with any future downturns in the global economy resulting therefrom, could adversely affect the financial performance of a Client and its investments. However, while certain countries may agree to trade deals to address disputes with other countries, certain trade disputes may remain unresolved, which can be an ongoing source of instability, potentially resulting in significant currency fluctuations and/or have other adverse Form ADV 2A | Page 21 of 80

effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise). While certain disputes have had negative economic consequences on U.S. markets, if trade-related issues persist, including as a result of geo-political tensions, to the extent that this trade dispute escalates into a “trade war” between the United States and China, which could lead to additional significant impacts on the industries in which a Client participates, the jurisdiction of investments and other adverse impacts on investments. In recent years, the United States and China have each been implementing increased tariffs on imports from China and the United States, respectively, and the United States has also adopted certain targeted measures such as export controls or sanctions implicating Chinese companies and officials. A continued trade dispute between the United States and China would be an ongoing source of instability, potentially resulting in significant currency fluctuations, and/or have other adverse effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise), which could presenting similar and/or additional potential risks and consequences for a Client and their portfolio investments. While certain trade agreements have been agreed to between the two countries, the trade dispute is still developing, and the United States and China have yet to reach a compromise. There remains much uncertainty as to whether the trade negotiations between the United States and China will be successful and how the trade dispute between the United States and China will progress. If the trade dispute between the United States and China continues or escalates, or if additional tariffs or trade restrictions are implemented by the United States, China or other countries in connection with a global trade dispute or “trade war,” there could be material adverse effects on the global economy and a Client and borrowers in which they invest could be materially and adversely affected. In particular, the Trump administration recently enacted and proposed to enact significant new tariffs on imports from certain countries. Additionally, President Trump has directed various federal agencies to further evaluate key aspects of U.S. trade policy and there has been ongoing discussion and commentary regarding potential significant changes to U.S. trade policies, treaties and tariffs. There continues to exist significant uncertainty about the future relationship between the United States and other countries with respect to such trade policies, treaties and tariffs. These developments, or the perception that any of them could occur, may have a material adverse effect on global economic conditions and the stability of global financial markets, and may significantly reduce global trade and, in particular, trade between the impacted nations and the United States. Any of these factors could depress economic activity, which in turn could negatively impact a Client. Enhanced Scrutiny and Potential Regulation of Private Fund Industry There have been significant legislative developments affecting the private equity industry and there continues to be significant discussion regarding enhancing governmental scrutiny and/or increasing the regulation of the private investment fund industry. Future legislative, judicial or administrative action could adversely affect Clients' ability to achieve their investment objectives, as well as the ability of the Clients to conduct their operations. Legal, tax, and regulatory changes could occur during the terms of the Clients and adversely affect the Clients, their borrowers, or investors. The alternative asset management and financial services industries are subject to enhanced governmental scrutiny and/or increased regulation, and a number of legislative initiatives have been signed into law affecting alternative investment firms, including the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act") a key feature of which is the potential extension of prudential regulation by the Board of Governors of the Federal Reserve System (the "Federal Reserve Board") to nonbank financial companies that are not currently subject to such regulation but that are determined to pose risk to the U.S. financial system. The Dodd-Frank Act defines a "nonbank financial company" as a company that is predominantly engaged in activities that are financial in nature. The Financial Stability Oversight Council (the "FSOC"), an interagency body created to monitor and address systemic risk, has the authority to subject such a company to supervision and regulation by the Federal Reserve Board (including capital, leverage and liquidity requirements) if the FSOC determines that such company is systemically important, in that its material financial distress or the riskiness of its activities could pose a threat to the financial stability of the United States. The Dodd-Frank Act does not contain any minimum size requirements for such a determination by the FSOC and it is possible that it could be applied to private funds, particularly large, highly leveraged funds, although no such funds have Form ADV 2A | Page 22 of 80

been designated as systemically important by the FSOC to date. If regulations were to extend the regulatory and supervisory requirements, such as capital and liquidity standards currently applicable to banks, or Clients were considered to be engaged in "shadow banking," either in the United States or in any other jurisdiction in which a Client engages in investment activities, the regulatory and operating costs associated therewith could adversely impact the implementation of a Client's investment strategy and its returns and may become prohibitive. The Dodd-Frank Act also imposes a number of restrictions on the relationship and activities of banking organizations with certain private equity funds and hedge funds and other provisions that affect the private equity industry, either directly or indirectly. For example, the Dodd-Frank Act added section 13 to the U.S. Bank Holding Company Act of 1956, as amended from time, commonly referred to as the "Volcker Rule," which (together with its implementing regulations), among other things, generally prohibits, subject to certain exceptions, any "banking entity" (generally defined as (i) any insured depository institution, subject to certain exceptions including for a depository institution that (together with every company that controls it) has $10 billion or less in total consolidated assets and trading assets and liabilities that are less than 5% of total consolidated assets, (ii) any company that controls such an institution, (iii) a non-U.S. bank that is treated as a bank holding company for purposes of U.S. banking law, and (iv) any affiliate or subsidiary of the foregoing entities) from sponsoring, investing in, or conducting certain activities with a private equity fund, hedge fund or other fund that is not subject to the provisions of the 1940 Act in reliance solely upon either Section 3(c)(1) or Section 3(c)(7) of the 1940 Act. Prospective investors in a Client that are banking entities for purposes of the Volcker Rule should consult their bank regulatory counsel prior to making an investment. Future legislation may have an adverse effect on the private equity industry generally and/or on CVC or Clients, specifically. Therefore, there can be no assurance that any continued regulatory scrutiny or initiatives will not have an adverse impact on CVC or otherwise impede a Client's activities. Federal, state, and local legislators and regulators regularly introduce measures or take actions that may modify the regulatory requirements applicable to the financial industry. Changes in laws, regulations or regulatory policies, including resulting from changes in U.S. executive administration or Congressional leadership, could adversely affect the private equity industry generally and/or CVC or Clients in substantial and unpredictable ways. CVC cannot predict what impact, if any, potential future legislative developments, including resulting from changes in U.S. executive administration or congressional leadership, will have on CVC or Clients. Although CVC Credit is registered under the Advisers Act, the enactment of these reforms and/or other similar legislation could nonetheless have an adverse effect on the private investment funds industry generally and on CVC and/or Clients specifically and may impede a Client's ability to effectively achieve its investment objectives. As a registered investment adviser under the Advisers Act, CVC Credit will be required to comply with a variety of periodic reporting and compliance-related obligations under applicable federal and state securities laws (including, without limitation, the obligation of CVC Credit and its affiliates to make regulatory filings with respect to a Client and its activities under the Advisers Act (including, without limitation, Form PF, Rule 206(4)-1 under the Advisers Act (the "Marketing Rule") and Form ADV)). In addition, CVC Credit will be required to comply with a variety of regulatory reporting and compliance-related obligations under applicable federal, state and foreign securities laws (including, without limitation, reports or notices in connection with the AIFMD and/or CFTC as well as other international jurisdiction-specific obligations). In light of the heightened regulatory environment in which Clients, the general partners and CVC Credit operate and the ever-increasing regulations applicable to private investment funds and their investment advisers, it has become increasingly expensive and time-consuming for Clients, the general partners, investment adviser and their affiliates to comply with such regulatory reporting and compliance-related obligations. Similarly, the Marketing Rule modified the advertising rules that SEC-registered investment advisers are subject to, and among other things, enhanced certain disclosure and substantiation requirements. Any expenses incurred in connection with compliance with the Marketing Rule, including for marketing materials that are prepared for existing and/or prospective investors, shall be treated as fund expenses. In each case, such expenses are likely to be material, including on a cumulative basis over the life of Clients. Additionally, Clients may in the future engage third party service providers to perform some or a significant portion of the reporting and compliance related matters and functions under a Client's supervision (including, without limitation, draft preparation and the filing of Form PF), which could result in increased compliance costs and expenses borne by Clients. Any further increases in the regulations applicable to private investment funds generally or Clients and/or CVC Credit in particular may result in increased expenses associated with a Client's activities and additional resources of CVC Credit being devoted to Form ADV 2A | Page 23 of 80

such regulatory reporting and compliance-related obligations, which may reduce overall returns for the investors and/or have an adverse effect on the ability of Clients to effectively achieve its investment objective. European Market Infrastructure Regulation On August 16, 2012, the European Market Infrastructure Regulation (EU No. 648/2012) (including, where the context requires, as implemented into the laws of the United Kingdom, "EMIR") entered into force. EMIR introduces certain requirements in respect of derivative contracts, which apply primarily to "financial counterparties" ("FCs") such as investment firms authorized by an EU Member State, credit institutions, insurance companies, undertakings for collective investment in transferable securities ("UCITS") and alternative investment funds managed by EU authorized alternative investment fund managers, and "non-financial counterparties" ("NFCs"), which are entities established in the EU that are not financial counterparties. NFCs whose transactions in over-the-counter ("OTC") derivative contracts exceed EMIR's prescribed clearing threshold ("NFC+s") are generally subject to more stringent requirements under EMIR than NFCs whose transactions in OTC derivative contracts do not exceed such clearing threshold (including because such contracts are excluded from the threshold calculation on the basis that they are entered into in order to reduce risks directly relating to the NFC's commercial activity or treasury financing activity) ("NFC-s"). Broadly, EMIR's requirements in respect of derivative contracts are (i) mandatory clearing of OTC derivative contracts declared subject to the clearing obligation; (ii) risk mitigation techniques in respect of uncleared OTC derivative contracts (such as the exchange and segregation of collateral); and (iii) reporting and record-keeping requirements in respect of all derivative contracts. EMIR was amended by Regulation (EU) 2019/834 of May 20, 2019 (the "EMIR REFIT") which came into effect on June 17, 2019. The EMIR REFIT expanded the definition of FC to capture AIFs that are authorized, registered or have their principal place of business in an EEA member state ("EU AIFs") (irrespective of the location of the alternative investment fund manager) and, where relevant, their EU alternative investment fund managers, in addition to, as under the original definition, AIFs (irrespective of location) with an authorized or registered alternative investment fund manager. EMIR REFIT also impacts the classification of a non-EU AIF with a non-EU alternative investment fund manager. Originally, such non-EU AIFs were classified as third country entities that would be NFCs if they were established in the EU. However, from June 17, 2019, non-EU AIFs with non-EU alternative investment fund managers were re-classified as third country entities that would be financial counterparties if they were established in the EU. EMIR, including as amended by the EMIR REFIT, was retained in the UK as part of its 'onshoring' of EU legislation at the end of the Brexit transition period. Under the EMIR regime as it has effect in the UK, an AIF managed by a UK alternative investment fund manager would constitute an FC. There are already differences in the technical standards under the parallel EU and UK regimes, it is possible that the requirements and obligations under such regimes will diverge further over time, therefore giving rise to duplicative obligations and higher costs for Clients. The EU and UK regulatory frameworks and legal regimes relating to derivatives are set not only by EMIR and EMIR REFIT but also by MiFID II. In particular, MiFID II requires certain transactions between FCs and NFC+s in sufficiently liquid OTC derivatives to be executed on a trading venue that meets the requirements of the MiFID II regime. As a Client is established outside the EU and is not managed by an alternative investment fund manager ("AIFM") authorized under Alternative Investment Fund Managers Directive ("AIFMD"), the Client is not directly subject to the requirements of EMIR; however, where a Client transacts with in-scope EU counterparties, such counterparties may be required to apply certain provisions of EMIR so that the EU counterparty can fulfill its regulatory obligations and ensure that the transaction is EMIR-compliant. It is difficult to predict the full impact of these regulations on Clients. Prospective investors should be aware that the regulatory obligations arising from EMIR, EMIR REFIT and MiFID II may in due course

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significantly raise the costs of entering into derivative contracts and may adversely affect Clients' ability to engage in transactions in derivatives. Social Media and Publicity Risk The use of social networks, message boards, internet channels and other platforms has become widespread within the United States, the UK, the EU and globally. As a result, individuals now have the ability to rapidly and broadly disseminate information or misinformation, without independent or authoritative verification. Any such information or misinformation regarding CVC could have a material and adverse effect on the value and performance of Client and/or its investments. Market Stability The operation of a Client’s investments may be affected by sovereign or political risk. Major disturbances such as wars, riots, strikes, blockades, acts of terrorism or outbreak of associated military or responsive action have the potential to adversely affect the costs or revenues of a Client’s investments, which could have a material adverse effect on the earnings of the Client and its ability to make distributions. General economic conditions, including interest rates, the availability of financing, the price of securities and participation of other investors in the financial markets may adversely affect the value and number of investments made by a Client. There is a risk, particularly given the recent instability in the financial sector that counterparties may default on their contractual obligations to the Client or its investments. Any such counterparty default would be likely to have an adverse effect on the value of the investments and on the returns to investors. The public markets are currently experiencing significant volatility and many observers believe a global economic downturn or recession is possible. The extent and duration of such environment is currently unknown. A recession, slowdown and/or sustained downturn in the global economies (or any particular segment thereof) or weakening of credit markets will adversely affect a Client’s ability to effectively deploy capital, impede the ability of a Client’s investments to perform under or refinance their existing obligations, and impair a Client’s ability to effectively exit investments on favorable terms. Any of the foregoing events could result in substantial or total losses to a Client in respect of certain investments, which losses will likely be exacerbated by the presence of leverage in a particular investment’s capital structure. CVC Credit itself could also be affected by difficult conditions in the capital markets and any overall weakening of the financial services industry in particular, or global economies generally. Recent Developments in the Banking Sector Actual events involving limited liquidity, defaults, non-performance or other adverse developments that affect financial institutions, transactional counterparties or other companies in the financial services industry or the financial services industry generally, or concerns or rumors about any events of these kinds or other similar risks, have in the past and may in the future lead to market-wide liquidity problems. As a consequence of banking closures or related uncertainty in the financial markets, for example, Clients may be delayed or prevented from accessing money, making any required payments under their own debt or other contractual obligations or pursuing key strategic initiatives, and investors in Clients may be impacted in their ability to honor capital calls and/or receive distributions. In addition, such bank failures or instability could affect, in certain circumstances, the ability of both affiliated and unaffiliated joint venture partners, co-investors, syndicate members or other parties to undertake and/or execute transactions with Clients, which in turn would result in fewer investment opportunities being made available to Clients, result in shortfalls or defaults under existing investments, or impact the Clients’ ability to provide additional follow-on support to borrowers. In addition, in the event that a financial institution that provides credit facilities and/or other financing to Clients closes or experiences distress, there can be no assurance that such bank will honor its obligations or that Clients will be able to secure replacement financing or capabilities at all or on similar terms. There can be no assurances that Clients will establish banking relationships with multiple financial institutions, and Clients are expected to be subject to contractual obligations to maintain all or a portion of their respective assets with a particular bank (including, without limitation, in connection with a credit facility or other financing transaction). Uncertainty caused by recent bank failures and general concern regarding the financial health and outlook for other financial institutions could have an overall negative effect on banking systems and financial markets generally. There is a risk that these recent developments will also have other Form ADV 2A | Page 25 of 80

implications for broader economic and monetary policy, including interest rate policy. For the foregoing reasons, there can be no assurances that conditions in the banking sector and in global financial markets will not worsen and/or adversely affect Clients. United Kingdom (“UK”) – Future Trade with the European Union (“EU”) The withdrawal of the UK from the EU has resulted in some divergence between the laws and regulations applicable in the UK and the EU. This divergence is expected to increase over time and will as such, increase the compliance and regulatory burden of the Managed Funds. Although the arrangements between the UK and EU following the UK’s withdrawal provide for zero tariffs and zero quotas on all goods that comply with the appropriate rules of origin (subject to both parties maintaining a level playing field in areas such as environmental protection, social and labor rights, investment, competition, state aid, and tax transparency), market access for those firms that conduct cross-border trade in goods will fall below what the single market previously allowed. Non-tariff barriers, customs declarations, customs checks, restrictions on movements of employees, withdrawal of recognition of previously recognized professional qualifications, changes in the status of the UK visà-vis the EU for tax and value-added tax (“VAT”) purposes, and other sources of friction have the potential to impair the profitability of a business, require it to adapt, or even relocate to operate through an establishment in the EU. Understanding and adapting to these new arrangements may result in increased operational and compliance burdens for the Managed Funds. In addition, there may be an adverse effect on Clients, the performance of their investments and their ability to fulfil their investment objectives (especially if its investments include, or expose it to, businesses that have historically relied on access to the single market for their custom or that have historically relied on sourcing goods, materials or labor from the single market). Environmental Matters Environmental laws, regulations and regulatory initiatives play a significant role in certain industries and can have a substantial impact on investments in these industries. For example, global initiatives to minimize pollution have played a major role in the increase in demand for natural gas and alternative energy sources, creating numerous new investment opportunities. Conversely, required expenditures for environmental compliance have adversely impacted investment returns in a number of segments of the industry. Certain industries will continue to face considerable oversight from environmental regulatory authorities and significant influence from non-governmental organizations and special interest groups. A Client may invest in investments that are subject to changing and increasingly stringent environmental and health and safety laws, regulations and permit requirements. New and more stringent environmental and health and safety laws, regulations and permit requirements or stricter interpretations of current laws or regulations could impose substantial additional costs on investments or potential investments. Compliance with such current or future environmental requirements does not ensure that the operations of a Client’s investments will not cause injury to the environment or to people under all circumstances or that a Client’s investments will not be required to incur additional unforeseen environmental expenditures. Environmental hazards could expose the investments to material liabilities for property damages, personal injuries or other environmental harm, including costs of investigating and remediating contaminated properties. Moreover, failure to comply with regulatory or legal requirements could have a material adverse effect on a borrower or project, and there can be no assurance that borrowers will at all times comply with all applicable environmental laws, regulations and permit requirements. Any noncompliance with these laws and regulations could subject a Client and its positions to material administrative, civil or criminal penalties or other liabilities. Under certain circumstances, environmental authorities and other parties may seek to impose personal liability on the limited partners of a partnership (such as a Client) subject to environmental liability. However, an investor may reduce its risk of such personal liability by avoiding activities with respect to a Client’s investments other than as specifically contemplated by the partnership or loan agreements. Additionally, as consensus builds that global warming is a significant threat, initiatives seeking to address climate change through regulation of greenhouse gas emissions have been adopted by, are pending or have been proposed before international and regional regulatory authorities. Many industries (e.g., manufacturing, transportation and insurance) face various climate change risks, many of which could conceivably materially impact them. Such risks include (i) regulatory/litigation risk (e.g., changing legal requirements that could result in increased compliance costs, changes in business operations, the Form ADV 2A | Page 26 of 80

discontinuance of certain operations and related litigation); (ii) market risk (e.g., declining market for products and services seen as greenhouse gas intensive); and (iii) physical risk (e.g., risks to plants or property owned, operated or insured by a company posed by rising sea levels, increased frequency or severity of storms, drought and other physical occurrences attributable to climate change). These risks could result in unanticipated delays or expenses, especially for electricity, and, under certain circumstances, could prevent or impede completion of investment activities once undertaken, any of which could have an adverse effect on a Client. Certain regions in which Clients invest or conduct activities related to investments may be particularly sensitive to weather and climate conditions. Prolonged changes in climatic conditions could have a significant impact on the revenues, expenses and conditions of certain investments. While the precise future effects of climate change are unknown, it is possible that climate change could affect precipitation levels, cause droughts, affect wind levels, annual sunshine levels, sea levels and the severity and frequency of storms and create or substantially contribute to other severe weather events and increased volatility in seasonal temperatures. In the event that climate change causes sea levels to rise, certain investments might be forced to incur expenses to prevent assets from being damaged or rendered unusable by such rising sea levels. Moreover, if the evidence supporting climate change continues to mount, various regulatory agencies may enact more restrictive environmental regulations. These more restrictive regulations could materially impact the revenues and expenses of an investment. Damage resulting from extreme weather may not be fully insured. Certain regions in which Clients may invest or conduct activities related to investments are also susceptible to natural disasters that could have a severe impact on the value of, and even destroy, assets in those regions. Health or other government regulations adopted in response to natural calamities may require temporary closure of corporate and governmental offices upon a disaster, which would severely disrupt a Client’s operations in the affected area. Clients’ investments are therefore subject to significant geological risks that could lead to significant loss of life and economic loss. Such catastrophic losses may either be uninsurable or insurable at such high rates as to make such coverage impracticable. If such a major uninsured loss were to occur with respect to any Client’s investments, such Client could lose both invested capital and anticipated profits. CVC Credit has also developed a business continuity plan that is designed to minimize the disruption of normal business operations in the event of a cybersecurity or other incident, such as a natural disaster, that would impact CVC Credit’s normal operations. While CVC Credit believes that this plan is comprehensive and should enable the Firm to continue or reestablish normal business operations in a timely manner in the event of an adverse incident, there are inherent limitations in such plans, including the possibility that contingencies have not been anticipated and procedures do not work as intended. In the case of a broader Significant Business Disruption, it is possible that CVC Credit or our key service providers could be prevented from providing services to Clients, or able to provide only limited services to Clients, for an extended periods of time. These circumstances may include, without limitation, acts of governments, any act of declared or undeclared war or of a public enemy (including acts of terrorism), power shortages or failures, utility or communication failure or delays, labor disputes, strikes, epidemics, shortages, supply shortages, and system failures or malfunctions. Possibility of Fraud and Other Misconduct of Employees and Service Providers Misconduct by employees of CVC Credit, service providers to CVC Credit or to Clients and/or their respective affiliates could cause significant losses to such Clients. Misconduct may include entering into transactions without authorization, the failure to comply with operational, compliance and risk procedures, including due diligence procedures, improper allocation of expense to Clients, misrepresentations as to investments being considered by such Clients, the improper use or disclosure of confidential or material non-public information, which could result in litigation, regulatory enforcement or serious financial harm, including limiting the business prospects or future marketing activities of such Clients and noncompliance with applicable laws or regulations and the concealing of any of the foregoing. Such activities may result in reputational damage, litigation, business disruption and/or financial losses to such Clients. CVC Credit has controls and procedures through which we seek to minimize the risk of such misconduct occurring. However, no assurances can be given that CVC Credit will be able to identify or prevent such misconduct.

Form ADV 2A | Page 27 of 80

Economic Sanctions, Trade Controls and Anti-Corruption Considerations Economic sanction laws and other trade controls in the United States, the European Union, the United Kingdom and other jurisdictions may prohibit CVC Credit, CVC Credit investment professionals and the Clients from transacting with or in certain countries and with certain individuals and companies. For example, in the United States, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) administers and enforces laws, Executive Orders and regulations establishing U.S. economic and trade sanctions. Such sanctions prohibit, among other things, transactions with, and the provision of services to, certain foreign countries, territories, entities and individuals. These entities and individuals include specially designated nationals, specially designated narcotics traffickers and other parties subject to OFAC sanctions and embargo programs. The lists of OFAC prohibited countries, territories, persons and entities, including the List of Specially Designated Nationals and Blocked Persons, as such list may be amended from time to time, can be found on the OFAC website at www.treas.gov/ofac. Other jurisdictions maintain different and/or additional economic and trade sanctions, including their own lists of prohibited countries, territories, persons and entities. In addition, certain economic sanction programs prohibit dealing with individuals or entities in certain countries or territories regardless of whether such individuals or entities appear on such lists. The United States and other jurisdictions also administer and enforce other trade controls, including export controls, that may prohibit or limit activities involving certain countries, entities, or individuals. These types of sanctions and trade controls may restrict Clients’ investment activities. In some countries, there is a greater acceptance than in the United States of government involvement in commercial activities. CVC Credit and CVC Credit investment professionals are committed to complying with anti-corruption laws, anti-bribery laws and regulations, as well as anti-boycott regulations, to which they are subject. As a result, a Client may be adversely affected because of its unwillingness to participate in transactions that violate such laws or regulations. Such laws and regulations may make it difficult in certain circumstances for a Client to act successfully on investment opportunities and for borrowers to obtain or retain business. In recent years, the U.S. Department of Justice and the SEC have devoted greater resources to enforcement of the U.S. Foreign Corrupt Practices Act (“FCPA”). In addition, the United Kingdom has continued to broadly enforce the UK Bribery Act of 2010 (“UK Bribery Act”). Affiliates of borrowers may engage in activities that could result in violations of the FCPA, the UK Bribery Act, or other applicable anti-corruption laws or anti-bribery laws. Any determination that CVC Credit has or may have violated economic sanctions, trade controls including export controls or the FCPA, the UK Bribery Act or other applicable anti-corruption laws or anti-bribery laws could subject CVC Credit to, among other things, reputational harm, civil and criminal penalties, material fines, profit disgorgement, injunctions on future conduct, securities litigation and a general loss of investor confidence, any one of which could adversely affect CVC Credit’s business prospects and/or financial position, as well as a Client’s ability to achieve their investment objective and/or conduct its operations. Clients may also incur costs and expenses associated with inquiries or investigations relating to economic sanctions, trade controls including export controls or anti-corruption laws or anti-bribery laws. Force Majeure Investments may be affected by events beyond the control of the relevant company in which the Clients have made an investment, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, and so on. Some of these “force majeure” events may adversely affect the ability of a company to perform its obligations until it is able to mitigate the effects of the event, or the underlying circumstances change. These risks could, among other effects, adversely impact the cash flows available from a company in which the Clients have invested, cause personal injury or loss of life, damage property, or instigate disruptions of service. In addition, the cost to a company in which the Clients have invested of repairing or replacing damaged assets resulting from such force majeure event could be considerable. Events that persist for a lengthy period of time, for which no mitigation is available, may have a permanent adverse effect on a company in which the Clients have invested. Form ADV 2A | Page 28 of 80

Certain events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally, or in any of the countries in which the Clients may invest specifically. Additionally, a major governmental intervention into industry, including the nationalization of an industry or the assertion of control over one or more companies in which the Clients have invested or its assets, could result in a loss to the Clients, including if the investment in such companies is cancelled, unwound or acquired (which could be without adequate compensation). Any of the foregoing may therefore adversely affect the performance of CVC Credit’s Clients and their investments. Impact of EU and UK Sustainable Finance Regulatory Developments The European regulatory environment for alternative investment fund managers and financial services firms continues to evolve and increase in complexity, making compliance more costly and timeconsuming. There is growing regulatory interest, both in the EU and the United Kingdom, in improving transparency around how asset managers define, measure and disclose impact of sustainability factors on the performance of their funds and financial products, in part, to avoid the practice of ‘greenwashing’ but principally to enable prospective investors to make informed choices in pursuit of their own responsible investment or sustainability policies. The EU has published a number of strategic initiatives in recent years that are designed to transform the entire financial system and reorient capital flows towards sustainable investment, which is to be achieved through the selection of appropriate investments by well-informed, or suitably advised, investors who may themselves be under an obligation to disclose to their own stakeholders how they integrate sustainability into their own decision-making. It is difficult to predict whether the EU’s measures will succeed in reorienting capital flows and, if it is successful, the impact it will have on the returns to investors. There is a risk that the value of investments made by Client in pursuing its investment strategy could be adversely affected over its life by changes to economic conditions brought about by the EU’s initiatives. As part of the above, the EU adopted the Sustainable Finance Disclosure Regulation (2019/2088) (the “SFDR”), which took effect from 10 March 2021 (as supplemented by delegated legislation specifying detailed regulatory technical standards (“RTS”)) and which requires transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in an alternative investment fund manager’s processes and the provision of sustainability-related information with respect to AIFs. In addition, the regulation on the establishment of a framework to facilitate sustainable investment (2020/852) (the “Taxonomy Regulation”) establishes a framework (and detailed criteria in regulatory technical standards made under the Taxonomy Regulation) to determine whether an economic activity qualifies as an environmentally sustainable economic activity, and requires in-scope financial products to disclose whether, and if so the degree to which, the financial product is invested in investments with exposure to such environmentally sustainable economic activities. In November 2025, the European Commission proposed significant changes to the SFDR regime, which are anticipated to come into effect during 2028. The proposals will be subject to the EU’s legislative processes being completed but, if the proposals are ultimately adopted in substantially their proposed form, this would result in the introduction of a categorisation system for financial products subject to minimum regulatory requirements in respect of their investment strategies, and the removal of the current disclosure-based approach. A Client that is open-ended or evergreen would be required to adapt to the new regulatory requirements. It is unclear as to how any such future changes could impact the management of such Client in line with its investment strategy or as to what additional costs could be borne by it; however, adapting to the new requirements is likely to involve short-term costs to such Client, and there could be increased ongoing costs and/or an impact on such Client’s investment strategy depending on how it chooses to adapt to the new requirements. The UK has introduced sustainability-related disclosure requirements for asset managers, including disclosures for certain UK asset managers that align to the recommendations of the Taskforce on Climate-related Financial Disclosures, and rules establishing a new regime for Sustainability Disclosure Requirements (“SDR”) and investment labels, and including new naming and marketing requirements for funds that have sustainability-related characteristics. In general, the above UK sustainability-related disclosure requirements are expected to have limited direct impact on non-UK funds managed by nonUK asset managers as they will apply only to UK authorised firms and do not currently extend to Form ADV 2A | Page 29 of 80

overseas funds. Nonetheless, there is still uncertainty as to the potential indirect impacts of this SDR and investment labels regime. The FCA has stated its belief that the regime would be enhanced by including additional funds within scope of the new SDR and investment labels regime, including overseas funds; however, this will require secondary legislation to be introduced by the UK government. If the UK’s sustainability-related disclosure requirements were to become applicable to Clients, this could result in additional regulatory costs. Compliance with the SFDR, the Taxonomy Regulation and other applicable sustainability-related rules is expected to result in increased legal, compliance, reporting and other associated costs and expenses which will be borne by the Clients, including costs and expenses of collecting and calculating data and the preparation of policies, disclosures and reports, in addition to other matters that relate solely to marketing and regulatory matters, and such costs and expenses may reduce investor returns. CVC Credit and Clients reserve the right to adopt such arrangements as it deems necessary or desirable to comply with any applicable requirements of the SFDR, the Taxonomy Regulation and any other applicable legislation or regulations. Service Providers and Value-Added Investors Certain advisors, consultants and other service providers (including services provided by CVC or its employees to a CVC Fund, a special purpose vehicle or a portfolio company) or their affiliates (including accountants, administrators, lenders, bankers, brokers, attorneys, consultants, and investment or commercial banking firms) may provide services to CVC Capital borrowers or companies to which CVC Credit Clients are material lenders and/or the broader CVC group, as well as providing services or having other relationships with such borrowers or companies. These relationships could influence CVC Capital and/or CVC Credit when deciding whether to select or recommend any such advisor or service provider to perform services for a Client or a underlying investment (the cost of which will generally be borne directly or indirectly by such Client). Notwithstanding the foregoing, CVC Credit will generally seek to engage advisors and service providers (which includes services provided by employees of CVC) for Clients on the basis of overall quality of advice and other services provided as well as cost and other relevant considerations. While cost considerations are relevant they are unlikely to be determinative and advisors and service providers often charge different rates or otherwise agree to different terms. In comparing costs and such terms, relevant comparisons might not be available for a number of reasons, including, without limitation, as a result of a lack of a substantial market of providers of users of such services or the confidential and/or bespoke nature of such services. In addition, fees for any given project will vary depending on the complexity of the matter in question as well as the time and expertise demands placed on the advisor or service provider. Certain advisors and service providers (including law firms) temporarily provide their personnel to CVC or its affiliates, funds and accounts managed or advised by CVC (including CVC Credit) or underlying investment pursuant to various arrangements, including at cost or at no cost. While often Clients and their underlying investments are the beneficiaries of these types of arrangements, CVC Creidt is from time to time the beneficiary of these arrangements as well, including in circumstances where the advisor or service provider also provides services to a Client in the ordinary course. Such personnel often provide services in respect of multiple matters, in respect of matters related to CVC Secondary, CVC Secondary Funds their respective affiliates and/or underlying investments. CVC Credit and its affiliates and/or CVC Credit executives (and executives of its affiliates) may provide certain services to a underlying investments or intermediate entity of an administrative nature, including the provision and arrangement of office space, the provision of directors, local personnel (including salary and benefits), tax administrative services (including in respect of reporting required pursuant to any existing or future tax reporting regime) and other general administrative services (including in respect of any reporting required pursuant to any existing or future legal or regulatory reporting regime). In addition, CVC Credit and/or CVC Credit executives (and executives of its affiliates) may incur, charge, attribute or allocate fees, costs and expenses related to the provision of other in-house services (including any related costs incurred in connection therewith) including, without limitation, administrative, accounting (including tax services (e.g., tax compliance, tax oversight and tax structuring)), legal, data infrastructure and science, core tech stack and infrastructure services, regulatory, reporting, risk management and monitoring, digitalization services, information technology, Form ADV 2A | Page 30 of 80

cybersecurity, artificial intelligence (“AI”), hedging, currency and treasury management, transfer pricing, sustainability-related (including, without limitation, transaction-related expenses, expenses in connection with the collection and benchmarking of data and preparation of filings, reports, disclosures and notices) and similar services for the benefit of a CVC fund (including Clients), and/or any underlying investment or below-the-fund structures, which may be allocated to CVC funds (including Clients) in accordance with CVC Credit Partners’ expense allocation policy. Such services may include services across the full investment lifecycle of a Fund, underlying investments or intermediate entity, and include services related to the assessment, design, development, deployment and ongoing operation (including in relation to strategy and value creation) of artificial intelligence, machine learning, data science, automation (including AI agents), robotics and other physical automation, and software solutions; data engineering, analytics and data infrastructure; digitisation and business process redesign and automation; information technology advisory and implementation, including cloud, infrastructure and enterprise applications; cyber security; technology, AI and data due diligence in connection with investments, financings and exits; sourcing, negotiating and managing technology and AI vendors, licences and partnerships on behalf of a Fund and its underlying investments, including foundational model providers and specialist deployment partners; AI and data governance, risk and regulatory compliance; technology and AI talent assessment, recruitment support and organisational design; executive education and immersion programmes; and ongoing monitoring and benchmarking of AI and technology value creation in each case delivered by CVC personnel directly or together with, or through, affiliated entities, joint ventures and third-party specialists. CVC Credit may determine the cost of such in-house services by reference to the aggregate annual compensation (including, without limitation, salary, bonus, benefits, profit interests, payroll taxes, equity interests of other incentive-based compensation) of the personnel performing such services, plus an estimate of the overhead and other fixed costs allocable to such personnel, and the approximate amount of time spent by the relevant personnel in providing such services, in each case, in its discretion. CVC Credit takes into account a variety of considerations when determining the extent to which fees, costs and expenses are to be allocated to a Client or another CVC fund (and the extent to which fees, costs and expenses may be allocated to any other CVC funds), and uses methods that it believes are fair and reasonable. CVC’s in-house expense calculation and allocation processes are expected to rely on certain judgments and assessments that in turn are based on information and estimates from various inputs, and the calculations and allocations that result may not be exact. In addition, relevant comparisons may not be available for a number of reasons, including as a result of a lack of a substantial market of providers or users of such services or the confidential or bespoke nature of such services. Any methodology, or choice among methodologies, involves potential conflicts of interest, and the use of any particular methodology may lead a Client or another CVC fund to bear relatively more costs in certain instances and relatively less in other instances compared to what such Client or other CVC fund would have borne if a different methodology had been used. In the future, CVC may use additional or different methodologies to allocate fees, costs and expenses in a manner that it determines to be fair and reasonable. CVC (including CVC Credit) and/or such CVC executives (including CVC Credit executives) may receive a fee from a Client or another CVC fund or the relevant underlying investments or intermediate entity (as applicable) in return for providing the services described in this paragraph and CVC (including CVC Credit) and/or such CVC executives (including CVC Credit executives) will not be required to account to a Client or another CVC fund for any such fees nor will such fees be subject to an offset against the management fee or the management fee paid by such CVC fund (including a Client) which would otherwise apply to, e.g., directors’ fees. Public Health Risks and Deterioration in Market Conditions A pandemic, epidemic or other public health crisis, or the threat thereof, may occur from time to time, which could adversely impact Clients. Many countries have experienced outbreaks of infectious illnesses in recent decades, including swine flu, avian influenza, Ebola, SARS and COVID-19. Such outbreaks of infectious illnesses have resulted and, along with any other future outbreaks of infectious illnesses, may result in numerous deaths and the imposition of both local and more widespread quarantine and other measures and restrictions, border closures and other travel restrictions, causing social unrest and commercial disruption on a global scale. Such outbreaks of infectious illnesses (including, for example, COVID-19) have had and may in the future have a material adverse impact on local economies in affected jurisdictions and also on the global economy (including on cross-border commercial activity and market sentiment).

Form ADV 2A | Page 31 of 80

Clients’ operational and financial performance could be adversely impacted by pandemics, epidemics or other public health crises, including through the reinstatement of any quarantine measures, business closures and suspensions, travel restrictions and health issues impacting CVC personnel and service providers to Clients. Disruptions to commercial activity relating to the imposition of quarantines, social distancing measures or travel restrictions (or more generally, a failure of containment efforts), as well as the impact of any public health emergency on overall supply and demand, supply chains, economic markets, goods and services, investor liquidity, consumer confidence and spending levels, and levels of economic activity, could adversely impact Clients. Any such events or effects, which are highly uncertain and unpredictable, could materially and adversely affect a Client’s ability to implement their investment strategies or achieve their investment objectives. Artificial Intelligence and Machine Learning Developments Recent technological advances in artificial intelligence and machine learning technologies (collectively, “AI Technologies”), including, for example, the OpenAI ChatGPT application, create opportunities for CVC, its Clients and borrowers, as well as risks. In addition, the overall adoption of artificial intelligence throughout society could exacerbate or create new and unpredictable competitive, operational, legal and regulatory risks to the CVC group, CVC Credit, the Clients and borrowers. CVC uses and may expand its use of AI Technologies in connection with its business and investment activities and expects its borrowers and investments will use such technologies. Actual usage of such AI Technologies will vary across its business and the business of its borrowers, and while CVC has adopted usage policies and procedures governing the use of AI Technologies by its personnel, which it intends to adjust from time to time as AI Technology continues to evolve, there is a risk of misuse of such AI Technologies. Nevertheless, AI Technologies are highly reliant on the collection and analysis of large amounts of data and complex algorithms and it is not possible or practicable to incorporate all relevant data into models that AI Technologies utilize to operate, nor does CVC expect to be involved in the collection of such data or development of such algorithms in the ordinary course. Therefore, it is expected that data in such models will contain a degree of inaccuracy and error, and potentially materially so, and that such data as well as algorithms in use could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of AI Technologies and could adversely impact CVC, Clients or the borrowers, or their respective affiliates or service providers, and investments to the extent they rely on the work product of such AI Technologies. The volume and reliance on data and algorithms also make AI Technologies, and in turn CVC, Clients and borrowers more susceptible to cybersecurity threats. In addition, CVC, Clients and borrowers could be exposed to risks to the extent third-party service providers, or any counterparties or other organizations connected to them use AI Technologies in their business activities. CVC will not be in a position to control the manner in which third-party products are developed or maintained or the manner in which thirdparty services utilizing AI Technologies are provided. In addition, AI Technologies may be competitive with the business of borrowers or increase the potential for obsolescence of a borrower’s products or services (particularly as the capabilities of AI Technologies improve). This may include AI Technologies competing with, or contributing to the obsolescence of, other AI Technologies. Such developments could impede the use of AI Technologies and/or have an adverse effect on a Client, borrowers or their respective businesses (whether directly or indirectly). Moreover, use of AI Technologies by any of the parties described in the previous paragraphs could include the input of confidential CVC information (including material non-public information and personal information) by CVC entities, CVC executives or third parties in contravention of non-disclosure agreements and, while CVC has policies and procedures in place to mitigate such events, the use of AI Technologies, the nature and availability of such technologies limits CVC’s ability to control all use and as a result CVC’s policies and/or non-disclosure agreements could be breached by CVC entities, CVC executives or third parties. Additionally, the use of AI Technologies could nevertheless result in such confidential ifnormaiton becoming part of a dataset that I accessible by AI Technologies applications and users. Further, the use of AI Technologies could result in claims by third parties of infringement, misappropriation or other violations of intellectual property, including based on the use of large datasets to train AI Technologies, or the use of output generated by AI Technologies, in either case which may contain or be substantially similar to third-party material protected by intellectual property, including patents, copyrights or trademarks. Similar claims could also be made against providers of AI Technologies (which may affect the use of and any operations reliant on such AI Technologies) where such AI Technologies are considered to have similarities to other AI Technologies. CVC may not be in a position to control the manner in which third-party products or services utilizing AI Form ADV 2A | Page 32 of 80

Technologies are provided, developed, used or maintained. Regulations related to AI Technologies may also impose certain obligations on organizations, and the costs of monitoring and responding to such regulations, as well as the consequences of non-compliance, could have an adverse effect on CVC, Clients and borrowers. For example, the EU has introduced a new regulation applicable to certain AI Technologies and the data used to train, test and deploy them (the "EU AI Act"). The EU AI Act entered into force on 1 August 2024, and its requirements started becoming effective on a staggered basis from 2 February 2025. The EU AI Act imposes material requirements on both the providers and deployers of AI Technologies, with infringement punishable by sanctions of up to 7% of annual worldwide turnover or EUR 35 million (whichever is higher) for the most serious breaches. Preparing for and complying with the EU AI Act and other regulations related to AI Technologies could involve material compliance costs and/or adversely affect the operations or results of CVC and/or an investment, and have an adverse impact on the Clients Funds. AI Technologies and their current and potential future applications including in the private investment and financial sectors, as well as the legal and regulatory frameworks within which they operate, continue to rapidly evolve, and it is impossible to predict the full extent of current or future risks related thereto. Use of AI Technologies could pose conflicts of interests, including if a particular technology favours (even subconsciously or inadvertently) CVC’s interests over the interests of one or more Clients; CVC has an economic incentive to use AI Technologies to reduce its overhead expenses despite limitations on the reliability of certain AI Technologies; or CVC obtains data that is relevant to the Clients’ investment strategies that CVC cannot use for the benefit of such Clients due to use, sharing or other restrictions to which such data is subject. Whilst CVC continues to evaluate and adjust its internal practices and guidelines governing the use of AI Technologies by its personnel in connection with its investment activities, the use of AI Technologies poses certain risks and potential conflicts of interest such as those outlined above that cannot be eliminated. Risk of a Software “Bubble” Public and private market valuations for software and technology-enabled businesses have, at times, reflected, and may in the future reflect, high growth expectations, favorable financing conditions, and elevated multiples that may not be sustainable. Market enthusiasm for AI Technologies and software business models may contribute to inflated valuations, “crowded” trades, speculative investment behavior, and increased correlation among technology assets. If the market’s perception of growth prospects, unit economics, addressable markets, competitive dynamics, or interest rate expectations changes, valuations of software and technology businesses may decline rapidly and materially. Such a re-rating may result from, among other things, slower-than-expected customer adoption, pricing pressure, increased churn, longer sales cycles, reduced IT budgets, heightened regulatory burdens, adverse litigation outcomes, or disappointment in anticipated AI-driven productivity gains. A downturn in technology valuations - whether characterized as a “bubble” bursting or otherwise - could impair exit opportunities, prolong holding periods, restrict access to follow-on financing for portfolio companies, force down-round financings, increase dilution, require portfolio companies to reduce headcount and spending, and result in write-downs or realized losses for the Fund. Geopolitical Risk including the effects of ongoing Russo-Ukranian conflict On February 21, 2022, Russian President Vladimir Putin ordered the Russian military to invade two regions in eastern Ukraine (the Donetsk People’s Republic and Luhansk People’s Republic regions). On February 22, 2022, the United States, United Kingdom and European Union announced sanctions against Russia. On February 24, 2022, President Putin commenced a full-scale invasion of Russia’s pre-positioned forces into Ukraine, including Russia’s forces pre-positioned in Belarus. In response, the United States, United Kingdom, European Union, and several other nations announced a broad array of new or expanded sanctions, export controls, and other measures against Russia, Russia-backed separatist regions in Ukraine, and certain banks, companies, government officials, and other individuals in Russia and Belarus, as well as a number of Russian oligarchs. Additional sanctions, export controls, and other measures continue to be adopted as the conflict continues. For example, in September and October of 2022, following the purported annexation by Russia of four territories of Ukraine, several nations imposed additional sanctions, export controls, and other measures against Russia and those outside of Russia that provided political or economic support for the purported annexation. Russia’s invasion of Ukraine, the resulting displacement of persons both within Ukraine and to neighboring Form ADV 2A | Page 33 of 80

countries and the increasing international sanctions could have a negative impact on the economy and business activity globally (including in the countries in which a Client invests), and therefore could adversely affect the performance of a Client’s investments. Furthermore, given the ongoing nature of the conflict between the two nations and its ongoing escalation (such as Russia’s decision to place its nuclear forces on high alert and the possibility of significant cyberwarfare against military and civilian targets globally), it is difficult to predict the conflict’s ultimate impact on global economic and market conditions, and, as a result, the situation presents material uncertainty and risk with respect to a Client and the performance of its investments or operations, and the ability of a Client to achieve its investment objectives. Furthermore, if after subscribing to a Client, an Investor is included on a sanctions list, a Client may be required to cease any further dealings with the Investor’s interests until such sanctions are lifted or a license is sought under applicable law to continue dealings. Although CVC and its affiliates expend significant effort to comply with the sanctions regimes in the countries where it operates, one of these rules could be violated by a Client’s activities or investors, which would adversely affect a Client. Furthermore, geopolitical relations may further worsen between the U.S. government (as well as other governments) and China over Taiwanese sovereignty, which may have significant macroeconomic effects on the global economy (including, but not limited to, currency fluctuations and/or other adverse effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise)). To the extent that this situation escalates, there could be additional significant impacts on the industries and sectors in which the Client seeks to make investments, the jurisdiction of investments and other adverse impacts on investments or Client more generally. In addition, geopolitical and trade disputes may develop between other countries, which may have similar or more pronounced risks and consequences for Client and/or the Client’s investments. Conflict in the Middle East

On October 7, 2023, Hamas (which controls the Palestinian territory of Gaza) commenced an assault on Israel. In response, the United States has announced sanctions and other measures against Hamas-related persons and organizations, and the United States and/or other countries may announce further sanctions related to the ongoing conflict in the future.

Starting in mid-November 2023, the Houthis, a Yemeni militia group backed by Iran, began attacking merchant vessels transiting the Red Sea and other critical waterways in the region in response to the war in Gaza, causing many commercial ships to be rerouted, with increased costs and delays, which may have significant impacts on regional and global supply chains.

In 2024, there were numerous attacks by Israel and Iran against each other, which significantly escalated in June 2025, with Israel and the United States carrying out strikes on Iranian military and nuclear targets.

In February 2026, the United States and Israel began a coordinated series of direct strikes on Iran, prompting Iranian retaliatory strikes affecting Israel and certain Gulf states, including the United Arab Emirates, the State of Qatar and the Kingdom of Bahrain.

The conflicts have resulted in significant regional spillover, including escalating hostilities between nation states and various militia groups in the region. The ongoing conflicts and rapidly evolving measures in response to such conflicts could have a negative impact on the economy and business activity globally (including in countries in which a Client invests and/or in countries in which CVC and/or any of its service providers or their respective affiliates maintain operations). This could, in turn, adversely affect the performance of a Client and its investments. Further, the severity and duration of the conflict and its future impact on global economic and market conditions (including, for example, oil prices) are impossible to predict, and, as a result, the situation presents material uncertainty and risk with respect to a Client and the performance of its investments or operations, and the ability of the Client to achieve its investment objectives. Governmental Intervention Since 2008, the global financial markets have undergone disruptions which have led to certain governmental intervention, including more recently, further disruptions as a consequence of the spread of COVID-19, that led to certain governmental intervention. Such intervention in certain cases was Form ADV 2A | Page 34 of 80

implemented on an “emergency” basis, suddenly and substantially eliminating market participants’ ability to continue to implement certain strategies or manage the risk of their outstanding positions. In addition, these interventions have typically been unclear in scope and application, resulting in confusion and uncertainty which in itself has been materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. If governmental intervention programs are unwound, there could likewise be uncertainty and adverse effects on the markets. It is impossible to predict what additional interim or permanent governmental restrictions (or easing of restrictions) may be imposed on the markets or the effect of such restrictions on the Client strategies. The U.S. government has recently indicated its intent to alter its approach to international trade policy and in some cases to renegotiate or potentially terminate, certain existing bilateral or multi-lateral trade agreements and treaties with foreign countries, and has made proposals and taken actions related thereto. For example, the U.S. government has imposed, and it is possible in the future will further increase, tariffs on certain foreign goods, such as steel and aluminum, and the Trump administration has imposed and indicated its intention to impose additional tariffs on imports of certain products into the United States. Some foreign governments have instituted retaliatory tariffs on certain U.S. goods and have indicated a willingness to impose additional tariffs on U.S. products. New trade policy could also create a legal burden for and negatively impact a Client or its investments, including by increasing costs and requiring the Client to exit certain Investments. Further governmental actions related to the imposition of tariffs or other trade barriers or changes to international trade agreements or policies could further increase costs, decrease margins, reduce the competitiveness of products and services offered by current and future borrowers and adversely affect the revenues and profitability of companies whose businesses rely on the importing of goods into, and the exporting of goods out of, the United States. The Trump administration has further signaled its intention to implement significant changes to the size of the federal government and to various other government policies. The potential downsizing of the U.S. federal government workforce and shutting down or defunding of certain government agencies (or offices thereof), including of federal agencies tasked with protecting investors, along with the changes in U.S. trade policy discussed above, could introduce market instability, reduce investor confidence, and weaken investor protection. For example, substantial reductions in government spending and personnel could negatively affect certain of a Client’s borrowers that rely on or benefit from government subsidies or contracts, destabilize the U.S. government contracting market, impede borrowers’ ability to implement their business plans, and impede CVC’s and the Client’s ability to achieve expected returns. Moreover, the Trump administration’s signaled changes to government policy with respect to tax, immigration, labor, infrastructure, energy, education, business regulations (including U.S. anticorruption policies), international relations, and international economic development could create uncertainty and volatility for the Client and borrowers. In light of these developments, there can be no assurances that political and regulatory conditions will not worsen and/or adversely affect a Client, borrowers, or their respective financial performance. Trade Policy Uncertainty In recent years, political leaders in the U.S. and certain European nations have been elected on protectionist platforms, fuelling doubts about the future of global free trade. For example, the U.S. government has indicated its intent to alter its approach to international trade policy and in some cases to renegotiate, or potentially terminate, certain existing bilateral or multi-lateral trade agreements and treaties with non-U.S. countries. In addition, the U.S. government has recently imposed tariffs on certain non-U.S. goods, including steel and aluminium, and has indicated a willingness to impose tariffs on imports of other products. Some non-U.S. governments, including China, have instituted retaliatory tariffs on certain U.S. goods and have indicated a willingness to impose additional tariffs on U.S. products. Governments of other countries have introduced, or may in the future introduce, protectionist and other similar trade policies that could adversely a ffect free trade. In particular, there have been a number of recent developments and events that have increased tensions between the U.S. and China, including in respect of trade policies, technology transfers, human rights, the status of Taiwan, sanctions and countersanctions and the handling of the COVID-19 outbreak. In April 2018, the U.S. government began imposing tariffs on Chinese imports. China, in turn, retaliated with its own tariffs on U.S. imports. The Biden administration has maintained the tariffs on Chinese goods and most of the sanctions that were implemented during the Trump administration, and the relationship between the countries remains complex. As time goes on, it can be expected that the U.S. and/or China may threaten, and possibly implement, additional tariffs on goods and services from each country. Although the U.S. and China Form ADV 2A | Page 35 of 80

have agreed to a partial trade deal with respect to their ongoing trade dispute, there are still ongoing trade disputes, which have already had, and if they remain unresolved, could lead to additional adverse economic effects on global markets, and may negatively affect borrowers. In addition, a continued trade dispute between the U.S. and China would be an ongoing source of instability, potentially resulting in significant currency fluctuations and/or have other adverse effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise), which could present similar and/or additional potential risks and consequences for the Client s and its investments. While this dispute (including the recent trans-Pacific dispute relating to TikTok and WeChat) has already had negative economic consequences on the U.S. markets, to the extent that this trade dispute escalates into a “trade war” between the U.S. and China, there could be additional significant impacts on the industries in which the Clients participates and other adverse impacts on the Clients and its investments. In addition, trade disputes may develop between other countries, which may have similar or more pronounced risks and consequences for the Clients and its investments. Global trade disruption, significant introductions of trade barriers and bilateral trade frictions, together with any future downturns in the global economy resulting therefrom, could adversely affect the financial performance of a Client and its investments. Recent developments in the United States and certain European nations have fuelled doubts about the future of global free trade. The U.S. administration under President Donald Trump has advocated greater restrictions on trade generally and significant increases on tariffs on certain goods imported into the United States, particularly from China, Canada and Mexico. The imposition of new tariffs could significantly affect the U.S. and broader global economy. Specifically, these new tariffs could further inflation through increased prices of gas, food, and other consumer items. The U.S. government has also imposed tariffs on certain foreign goods, including steel and aluminium, in recent years and has indicated a willingness to maintain those tariffs and impose new tariffs on imports of other products. Other foreign governments, in addition to China, have instituted retaliatory tariffs on certain U.S. goods and have indicated a willingness to impose additional tariffs on U.S. products. The U.S. government has indicated its intent to alter its approach to international trade policy and in some cases to renegotiate, or potentially terminate, certain existing bilateral or multi-lateral trade agreements and treaties with foreign countries and has made proposals and taken actions related thereto. In addition, on June 3, 2021, President Biden issued Executive Order 14032, entitled “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China”. This order prohibits the purchase or sale by U.S. persons of any publicly traded securities, or any publicly traded securities that are derivative of such securities or are designed to provide investment exposure to such securities, of identified Chinese companies that are deemed to be part of the “Chinese Military-Industrial Complex.” Further restrictions prohibiting these identified companies and, in some cases, their controlled affiliates or subsidiaries, from contracting with the U.S. Departments of Defense and Homeland Security are set to go into effect throughout 2026 and 2027. Global trade disruption, significant introductions of trade barriers and bilateral trade frictions, together with any future downturns in the global economy resulting therefrom, could adversely affect the financial performance of the Clients and borrowers. However, while certain countries may agree to trade deals to address disputes with other countries, certain trade disputes may remain unresolved, which can be an ongoing source of instability, potentially resulting in significant currency fluctuations and/or have other adverse effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise). Certain trade disputes have had negative economic consequences on U.S. and China markets and could present additional potential risks and consequences for the Clients and their investments in the future. Notably, as of July 2024, the U.S. Secretary of Commerce has designated China, including Hong Kong Special Administrative Region and Macau Special Administrative Region, as one of the foreign adversaries. If a trade-related dispute between the United States and China persists, such dispute could escalate into a “trade war” between the United States and China, which could lead to additional significant impacts on the industries in which the Client participates, the jurisdiction of investments and other adverse impacts on investments. Beginning April 2025, the Trump administration has announced a universal baseline tariff on all imports and the additional, so-called “reciprocal” tariffs for key trading partners that contribute to large, persistent US trade deficits. Following this news, the S&P saw its worst week since 2020. There remains uncertainty as to the further actions that will be taken under the Trump administration with respect to Form ADV 2A | Page 36 of 80

U.S. trade policy and the reactions of its trading partners. An intensifying trade war could create uncertainties and undermine growth for countries globally, some of which are the major net exporters into the U.S. In addition, while CVC Credit and the Clients intend to comply with applicable laws, rapid changes in laws and/or uncertain interpretation and implementation thereof, could affect the Client’s capacity to comply. New trade policy could also create a legal burden for and negatively impact the Client and its investments, including by increasing costs and requiring the Clients to exit certain investments. Further governmental actions related to the imposition of tariffs or other trade barriers or changes to international trade agreements or policies could further increase costs, decrease margins, reduce the competitiveness of products and services offered by current and future borrowers and adversely affect the revenues and profitability of companies whose businesses rely on the importing of goods into, and the exporting of goods out of, the United States. The Trump administration has further signalled its intention to implement significant changes to the size of the federal government and to various other government policies. The potential downsizing of the federal government workforce and shutting down or defunding of certain government agencies (or offices thereof), including of federal agencies tasked with protecting investors, along with the changes in U.S. trade policy discussed above, could introduce market instability, reduce investor confidence, and weaken investor protection. For example, substantial reductions in government spending and personnel could negatively affect certain of the borrowers that rely on or benefit from government subsidies or contracts, destabilize the U.S. government contracting market, impede borrowers’ ability to implement their business plans, and impede CVC Credit’s and the Client’s ability to achieve expected returns. Moreover, the Trump administration’s signalled changes to government policy with respect to tax, immigration, labour, infrastructure, energy, education, business regulations (including U.S. anticorruption policies), international relations, and international economic development could create uncertainty and volatility for the Clients and borrowers. In light of these developments, there can be no assurances that political and regulatory conditions will not worsen and/or adversely affect the Client, borrowers, or their respective financial performance. Inflation Inflation and rapid fluctuations in inflation rates are having, and may in the future continue to have, negative effects on economies and financial markets, particularly in emerging economies. For example, if a borrower is unable to increase its revenue in times of higher inflation, its profitability may be adversely affected. Borrowers may have revenues linked to some extent to inflation, including, without limitation, by government regulations and contractual arrangement. As inflation rises, a borrower may earn more revenue but may incur higher expenses. As inflation declines, a borrower may not be able to reduce expenses commensurate with any resulting reduction in revenue. Furthermore, wages and prices of inputs increase during periods of inflation, which can negatively impact returns on investments. In an attempt to stabilize inflation, countries may impose wage and price controls or otherwise intervene in the economy. Governmental efforts to curb inflation often have negative effects on the level of economic activity. Further, certain countries, including the United States, have recently seen increased levels of inflation and there can be no assurance that continued, and more wide-spread inflation will not be a serious problem in the future and thus have an adverse impact on Clients’ returns. Indemnification; Hedge Clauses The transactional nature of the business of Clients exposes Clients to risks of third-party litigation. Under the Clients’ governing documents, the Clients will generally be responsible for indemnifying CVC Credit for costs incurred with respect to litigation. Such liabilities may be material. For example, CVC Credit may be subject to claims brought by borrowers. The indemnification obligations of a Client would be payable from its own assets, including (as applicable) the undrawn commitments of the investors in a Managed Fund. CVC Credit may recall distributions previously made to an investor, subject to certain limitations set forth in the partnership agreements. In addition, because Clients may advance the costs and expenses of an indemnitee pending the outcome of the particular matter (including determination as to whether or not the person was entitled to indemnification or engaged in conduct that negated such person’s entitlement to indemnification), there may be periods in which a Client advances expenses to an individual or entity not aligned with or adverse to such Client. These indemnification obligations may impair the financial condition of a Client and its ability to acquire assets or otherwise achieve its investment object or meets its obligations.

Form ADV 2A | Page 37 of 80

The governing documents for the Clients generally contain provisions (sometimes referred to as “hedge clauses”) that provide that CVC Credit and its agents have no responsibility or liability for any loss incurred by the Clients or any investor arising in connection with their activities on behalf of, or their association with, the Clients provided that such exculpation will not apply: (i) where such person acted in bad faith, was fraudulent or acted with willful misconduct; and (ii) with respect to any matter resulting from such person’s gross negligence or material breach of the applicable governing documents, save where the relevant actions are undertaken in good faith and in reliance upon and in accordance with the advice of reputable legal counsel, where appropriate, or other qualified professional advisers. Hedge clauses are limited by, among other things, Section 206 of the Advisers Act, which the SEC has interpreted to impose certain duties on investment advisers that are not waivable. The determination of the whether CVC Credit is entitled to be indemnified, or the applicability of a hedge clause to particular conduct, by CVC Credit, may create a conflict of interest with a Client. However, notwithstanding this potential conflict of interest, CVC Credit will make any such determination in good faith. Pay-to-Play Laws, Regulations and Policies A number of states and public pension plans have adopted “pay-to-play” laws, regulations or policies which prohibit, restrict or require disclosure of payments and certain contacts with state officials by individuals and entities seeking to do business with state entities, including investments by or advising public retirement funds. The SEC also has adopted Rule 206(4)-5 under the Advisers Act that, among other things, prohibits an investment adviser from providing advisory services for compensation to a government plan investor for two years after a contribution is made by the adviser or certain of its executives or employees to certain elected officials or candidates. Advisers are also required to implement compliance policies designed, among other things, to comply with this rule. If CVC or its employees or affiliates fail to comply with pay-to-play rules whether or not such non-compliance was intentional any such non-compliance could have an adverse effect on a Managed Fund by, for example, providing the basis for the withdrawal of the affected government plan investor and could be the basis for a violation of an applicable regulation. In addition, a disqualifying contribution presents potential enforcement risk, which may subsequently result in a monetary fine or, more significantly, a disqualification from reliance on the Regulation D exemption, further impacting CVC’s investment advisory business. Material Risks of Investment Strategies Reinvestment Risk For certain Clients, CVC Credit will generally reinvest without limitation any proceeds from investments for a specified period of time. The objective of reinvesting such capital contributions is to provide ongoing additional capital to potentially increase the total return from the investments to the investors. However, if such proceeds are reinvested, the investor’s capital will continue to be subject to the risk of loss for a longer period of time. If reinvested proceeds are lost, such loss would offset at least a portion of any gains that may have been realized from prior investments, and it is possible that any such loss could exceed any such prior gains, thereby resulting in a possible loss of at least a portion of the investor’s investment. Interest Rate Risk In response to inflationary pressures, central banks across the globe, including the European Central Bank, the Bank of England, and the Federal Reserve System of the United States, often raise their base rates of interest. A Client’s investments will expose it to interest rate risk, meaning that any further changes in prevailing market interest rates could negatively affect the value of such investments. In addition to inflationary pressures, factors that can affect market interest rates include, without limitation, deflation, slow or stagnant economic growth or recession, unemployment, money supply, governmental monetary policies, international disorders and instability in domestic and foreign financial markets. There could be significant unexpected movements in interest rates, which movements could have adverse effects on investments and the economy as a whole. CVC Credit, on behalf of its Clients, generally invests in a combination of floating rate and fixed income securities. Generally, the value of fixed income securities will change inversely with changes in interest Form ADV 2A | Page 38 of 80

rates. As interest rates rise, the market value of fixed income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed income securities tends to increase. This risk will be greater for long-term securities than for short-term securities. The value of equity securities is also affected by changes in interest rates. CVC Credit may or may not attempt to minimize the exposure of the portfolios of its Clients to interest rate changes through the use of interest rate swaps, interest rate futures and/or interest rate options. Even if CVC Credit does attempt to do so, there can be no guarantee that it will be successful in mitigating the impact of interest rate changes. Credit Ratings are Not a Guarantee of Quality Credit ratings of assets represent the rating agencies’ opinions regarding their credit quality and are not a guarantee of quality. A credit rating is not a recommendation to buy, sell or hold assets and may be subject to revision or withdrawal at any time by the assigning rating agency. In the event that a rating assigned to any corporate debt obligation is lowered for any reason, no party is obligated to provide any additional support or credit enhancement with respect to such corporate debt obligation. Rating agencies attempt to evaluate the safety of principal and interest payments and do not evaluate the risks of fluctuations in market value; therefore, ratings may not fully reflect the true risks of an investment. Also, rating agencies may fail to make timely changes in credit ratings in response to subsequent events, so that an obligor’s current financial condition may be better or worse than a rating indicates. Consequently, credit ratings of any corporate debt obligation should be used only as a preliminary indicator of investment quality and should not be considered a completely reliable indicator of investment quality. Rating reductions or withdrawals may occur for any number of reasons and may affect numerous assets at a single time or within a short period of time, with material adverse effects upon the corporate debt obligation. It is possible that many credit ratings of assets included in or similar to the corporate debt obligation will be subject to significant or severe adjustments downward. Investment in Loans The value of any loans held on behalf of Clients may be detrimentally affected to the extent that a borrower defaults on its obligations. The value of loans can be impaired not only by borrower default or insolvency but by a range of borrower actions, including delayed payment, prepayment, and modification of key terms applicable to the debt, as well as credit quality deterioration and reputational harm affecting the borrower. While CVC Credit may in certain instances attempt to minimize the risk of loan value deterioration by obtaining collateral, there can be no assurance that the value assigned by CVC Credit to collateralize an underlying loan can be realized upon liquidation, nor can there be any assurance that any such collateral will retain its value. Furthermore, circumstances could arise (such as in the bankruptcy of a borrower) that could cause a Client’s interest in the loan’s collateral to be invalidated. Also, much of the collateral will be subject to restrictions on transfer intended to satisfy securities regulations, which will limit the number of potential purchasers if CVC Credit intends to liquidate such collateral on behalf of a Client. Even where a loan is believed to be secured, collateral may decline in value, be subject to competing creditor claims, be difficult to recover or liquidate, and measures intended to protect a Client's interests as a lender may prove inadequate. The amount realizable with respect to a loan may be detrimentally affected if a guarantor, if any, fails to meet its obligations under a guarantee. Finally, there may be a monetary, as well as a time cost involved in collecting on defaulted loans and, if applicable, taking possession of various types of collateral. CVC Credit may, on behalf of its Clients, invest in second lien loans. Second lien loans are subject to the same investment risks generally applicable to loans, as described above. Second lien loans are also subordinate in right of payment to one or more senior loans of the related obligor. As a result, second lien loans are subject to additional risk that the cash flow of the related obligor and the property securing the second lien loan may be insufficient to repay the scheduled payments to the lender after giving effect to any senior secured obligations of the related obligor. In the event a borrower enters bankruptcy, junior lien holders can be forced to consent to the use of cash collateral, sales of collateral, and debtor-in-possession financings, potentially eliminating or materially impairing the value of their position. Second lien loans are also expected to be more illiquid than senior first lien loans. Additionally, CVC Credit may, on behalf of its Clients, invest in unsecured loans. Unsecured loans are subject to the same investment risks generally applicable to loans described above but are subject to additional risk that the assets and cash flow of the related obligor may be insufficient to repay the scheduled payments to the lender after giving effect to any secured obligations of the obligor. Form ADV 2A | Page 39 of 80

Unsecured loans will be subject to certain additional risks to the extent that such loans may not be protected, and such loans are not secured by collateral, financial covenants or limitations upon additional indebtedness. Unsecured loans are also expected to be a more illiquid investments than senior loans. Furthermore, under the agreements governing most syndicated loans, if a holder of an interest in a syndicated loan wishes to call a default or exercise remedies against a borrower, it generally may not do so without the agreement of at least a majority of the other lenders. In addition, actions could be taken by a majority of the other lenders, or in some cases, a single agent bank, without the consent of all lenders. Each lender would nevertheless be liable to indemnify the agent bank for its ratable share of expenses or other liabilities incurred in such connection and, generally, with respect to the administration and any renegotiation or enforcement of the syndicated loans. Moreover, an assignee or participant in a loan may not be entitled to certain gross-up payments in respect of withholding taxes and other indemnities that otherwise might be available to the original holder of the loan. As lenders, CVC Credit Clients may be subject to the foregoing risks. Furthermore, the terms of syndicated loans may be amended, waived, or modified by majority or supermajority lender vote, without the Client's consent, and such modifications may be adverse to the Client's interests. CVC Credit invests, on behalf of its Clients, in senior loans acquired through assignment or participations. In purchasing participations, the Client will usually have a contractual relationship only with the selling institution, and not the borrower. A Client generally will have no right directly to enforce compliance by the borrower with the terms of a loan agreement, nor any rights of set-off against the borrower, nor will it have the right to object to certain changes to or waivers under the loan agreement, which was agreed to by the selling institution. A Client may not directly benefit from the collateral supporting the related senior loan and may not be subject to any rights of set-off that the borrower has against the selling institution. In addition, as noted above, the terms of syndicated loans may be amended, waived or modified, typically by a majority vote of lenders. Where a Client invests in a loan through a participation interest or through a derivative instrument, it may not be entitled to vote on such amendments or waivers at all, and must rely on the selling institution or counterparty to represent its interests. In addition, in the event of the insolvency of the selling institution in participation, a Client may be treated as a general creditor of such selling institution and may not have any exclusive or senior claim with respect to the selling institution’s interest in, or the collateral with respect to, the senior loan. Consequently, a Client may be subject to the credit risk of the selling institution as well as of the borrower. Certain senior loans or loan participations may be governed by the law of a jurisdiction other than the United States or a U.S. state which may present additional risks with regards to the characterization under such laws of such participation in the event of the insolvency of the selling institution or the borrower. CVC Credit may aggregate bank debt investments to be purchased by one or more Clients with bank debt investments to be purchased by other Clients. In order to effect a bank debt purchase on behalf of multiple Clients, CVC Credit may be required by the selling institution, or may otherwise elect for investment, administrative, or other reasons to cause a single Client to purchase the bank debt and be the holder of record of the bank debt, and enter into sub-participation agreements or other similar arrangements with other Clients, allowing multiple Clients to participate in the positive and negative economic performance of the bank debt or other investments without actually owning the bank debt directly. This arrangement can, in certain cases, create conflicts among participating Client accounts. To address conflicts regarding the pricing of sub-participations, CVC Credit prices the sub-participations at the price paid by the issuing Client to the third-party from which it purchased the debt so that the economic effect of the transaction is the same as if the participants purchased directly from the thirdparty seller. Additionally, under the terms of participation arrangements, one or more Clients can be required to make future payments to another Client, and if any other fund or account were to default on its respective obligations to the Client that issues the participation, that Client could be adversely impacted. Also, where the issuing Client acts as the lender of record with respect to any purchase of bank debt or other investments, it may have greater administrative burdens and greater exposure to third-party claims than other Clients that hold the interest by participation. When the issuing Client holds bank debt or other investments in a Client account managed by CVC Credit, the interest of the issuing Client and other participating Clients are typically aligned, and CVC Credit engages in Form ADV 2A | Page 40 of 80

administrative and risk oversight of the position on behalf of the issuing Client and all participating Clients. Where an issuing Client or participating Client seeks to liquidate a position, CVC Credit may be required to terminate the entire position, even if it would not otherwise seek to terminate the position for other Clients. CVC Credit may seek to establish an alternative issuing Client, reallocate participations in accordance with internal procedures for cross or principal transactions and applicable law, or take other steps to mitigate these risks, but the opportunity to mitigate these risks will not be available in all cases and/or may involve additional expenses and potential loss of capital. Investment in Leveraged Loans The underlying investments made by CVC Credit are comprised primarily of leveraged loans (loans to entities with substantial existing debt and/or low credit ratings), which have significant liquidity and market value risks since they are not generally traded on an organized exchange but are traded by banks and other financial institutional investors engaged in loan syndications. Because loans are privately syndicated and loan agreements are privately negotiated and customized, loans are not purchased or sold as easily as publicly traded securities. Leveraged loans may have fewer financial maintenance covenants, rights or remedies than a traditional credit agreement, making the investment more sensitive to credit risk factors and potentially hindering the ability to undertake restructurings intended to mitigate losses. Because leveraged loans are made to borrowers with substantial existing debt, counterparty risks associated with investments in leveraged loans are higher than those associated with loans made to less leveraged borrowers. Investing in Non-U.S. Assets CVC Credit may, on behalf of its Clients, invest in non-U.S. assets. Investing in securities or other instruments issued outside of the United States involves considerations and possible risks not typically involved in investing in instruments of companies domiciled and operating in the United States, including the possibility of expropriation, limitations on the use or removal of funds or other assets, changes in governmental administration or economic or monetary policy (initiated from the United States or from abroad) or changed circumstances in dealings between nations. The application of foreign tax laws (e.g., the imposition of withholding taxes on dividend, interest or other payments) or confiscatory taxation may also affect investment in non-U.S. securities or other instruments. Higher expenses may result from investment in non-U.S. instruments than would from investment in U.S. securities or other instruments because of the costs incurred in connection with conversions between various currencies and the fact that foreign brokerage commissions may be higher than commissions charged in the United States. Non-U.S. securities markets also may be less liquid, more volatile and less subject to governmental supervision than U.S. markets. Investments in non-U.S. countries could be affected by other factors not present in the United States, including lack of uniform accounting, auditing and financial reporting standards and potential difficulties in enforcing contractual obligations. Leverage CVC Credit may, on behalf of its Clients, utilize leverage through margin borrowing, use of derivatives, and through certain other financial transactions. Leverage increases returns to Clients if they earn a greater return on leveraged investments than their cost of such leverage. However, the use of leverage exposes the Client to additional levels of risk including (i) greater losses from investments than would otherwise have been the case had the Client not borrowed to make the investments, (ii) margin calls or changes in margin requirements may force premature liquidations of investment positions, (iii) losses on an investment where the investment fails to earn a return that equals or exceeds the Client’s cost of leverage related to the investment and (iv) fluctuations in interest rates on the Client’s borrowings, which may have a negative effect on the Client’s profitability. In case of a sudden, precipitous drop in value of a Client’s assets, the Client might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying the losses incurred by the Client. In addition to the enhanced portfolio volatility and risk that may arise from the use of leverage, the financial transactions that establish leverage generally subject Clients to credit risk with respect to the counterparty. Leveraging transactions often involve the transfer of legal title, pledge, or other encumbrance of underlying investments. Accordingly, the insolvency or bankruptcy of a financing counterparty may result in legal action that impairs the value, marketability, or ownership rights of the underlying investments used as collateral.

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Difficulty and Cost of Locating Suitable Investments There is no guarantee that suitable deal flow will be available so that Clients will be able to invest the aggregate commitments during their commitment periods or that any such investments will be successful. The success of Client investments depends on the ability of CVC Credit to identify and select, effect and realize appropriate investments. The availability of investment opportunities generally will be subject to market conditions. In particular, in light of changes in such conditions, certain types of investments may not be available to a particular Client on terms that are as attractive as the terms on which opportunities were available to other Clients historically. Accordingly, Clients may make only a limited number of investments. Since these investments may involve a high degree of risk, poor performance by a few could significantly affect the return to investors. To the extent that any of the aggregate commitments are not invested, Clients’ potential for return may be diminished. No assurances can therefore be given that the target returns of any Client portfolio will be achieved. Borrowings and Leverage; Subscription Facilities Borrowers in which Clients invest are expected to incur debt from CVC Credit and, in certain cases, from other sources. Leverage often imposes restrictive financial and operating covenants on a company, in addition to the burden of debt service, and may impair its ability to finance future operations and capital needs. The leveraged capital structure of borrowers will increase the exposure of Client investments to any deterioration in a company’s condition or industry, competitive pressures, an adverse economic environment or rising interest rates and could accelerate and magnify declines in the value of such Client’s investments in the leveraged borrowers in a down market. In the event any borrower cannot generate adequate cash flow to meet debt service, the relevant Client is expected to suffer a partial or total loss of capital invested in the borrower, which could adversely affect the returns of the Client. Certain Clients enter into credit facilities (sometimes referred to as “subscription facilities”) the collateral for which are the undrawn commitments of investors in the relevant Client. Typically, a Client will borrow under these credit facilities to fund the initial cost of investment (for either a new investment or a follow-on investment) with any amounts outstanding being repaid by the Client drawing capital from its investors. The four main effects of these credit facilities are: 1. Initial Rate of Return (“IRR”) – the IRR for the relevant Client is likely to be higher than it otherwise would be without credit facility borrowing. This is because IRR is calculated based on the dates on which the capital is drawn from and returned to investors, and the use of the capital call facility to make or facilitate either investments in borrowers or distributions to investors has the effect of shortening the period of this calculation; however, the interest expense and other costs of any such borrowings will be a Client expense and, accordingly, will decrease net returns of the Client; 2. Preferred Return – the accrued preferred return is likely to be lower as it is based off the date on which the investor capital is drawn and the use of the capital call facility is to shorten the period of this calculation; 3. Money on Money (“MoM”) - funding an investment with a credit facility reduces the overall capital gain given the interest expense and associated costs is an additional expense of the fund. This results in the relevant fund reporting a lower MoM multiple to investors; and 4. Carried Interest – a lower capital gain will reduce the amount of carry that a fund generates given carried interest is typically calculated as the lower of (i) a percentage of the total capital gain and (ii) the delta between the actual capital gain and the preferred return. Certain of these effects are expected to provide an incentive for Clients to use a credit facility to fund the initial cost of an investment or to fund distributions to limited partners (for example, to be able to use a higher IRR in marketing presentations) when doing so may not necessarily benefit the Client or its limited partners.

Form ADV 2A | Page 42 of 80

Valuation Risks There is no actively traded market for some of the positions owned by certain Clients in the more illiquid strategies managed by CVC Credit. A majority of these Clients' investments may be fair valued by CVC, if applicable. When determining fair value, CVC Credit will apply a methodology based on its best judgment that is appropriate in light of the nature, facts and circumstances of the investments and will make certain assumptions about future events. CVC Credit's methodology may rely significantly on third party pricing services and other third-party data, but there can be no guarantee that such third-party inputs are accurate. There can be no assurance that investments will ultimately be realized for amounts equal to, or greater than, these valuations, or that the past performance information based on such valuations will accurately reflect the ultimate realization value of such investments, and the difference between any such valuation and the ultimate sale price or realization could be material. The actual realized returns generated by unrealized investments will depend on, among other factors, future operating results, the value of the assets and market conditions at the time of disposition, and any related transaction costs and performance data. Valuations are subject to determinations, subjective judgments and opinions. Valuation of distressed, non-performing or restructured investments presents particular challenges. The value of such investments may depend on the outcome of pending litigation, restructuring negotiations or other legal or regulatory processes, and may be highly sensitive to assumptions about recovery rates, the timing of resolution and the value of collateral or other credit support. In such cases, valuations may be based principally on estimated recovery scenarios, which are inherently speculative. Investors or other third parties may disagree with such valuations and / or their underlying methodologies and assumptions. With respect to these Clients, the exercise of discretion in valuation by CVC Credit gives rise to conflicts of interest, including (without limitation) in relation to the impact of valuations (including, for instance, the determination of when an investment should be written down or written off) on CVC Credit’s track record (including its ability to raise capital for future CVC Credit funds), the performance allocation in certain Managed Funds, and the amount and timing of performance fees and calculation of management fees. There could be circumstances where CVC Credit is incentivized to determine valuations that differ from the actual fair value of such investments. CVC Credit will value the Clients’ assets using pricing feeds, quoted prices, or fair value determinations. CVC Credit may engage independent qualified valuers to assist in these determinations, however, it is not required to do so unless required by a specific regulatory or Fund requirement. Given the nature of the Clients’ investments, valuation may be difficult. There may be a relative scarcity of market comparables on which to base the value of the Clients’ assets. Side Letters CVC may enter into side letters or other similar agreements with particular investors in connection with their admission to Managed Funds generally without the approval of any other investor, which has the effect of establishing rights under or supplementing the terms of the partnership agreements with respect to such investor in a manner more favourable to such investor than those applicable to other investors. Such rights or terms in any such side letter or other similar agreement are expected to include, without limitation, (i) excuse rights applicable to particular investments (which will increase the percentage interest of other investors in, and contribution obligations of other investors with respect to, such investments) or withdrawal and/or related rights with respect to the Managed Fund generally in certain limited regulatory and/or policy related circumstances, (ii) reporting obligations of CVC, (iii) waiver of certain confidentiality obligations, (iv) management fee discounts, (v) consent of CVC to certain transfers by such investor, (vi) preferential access to co-investment opportunities, or (vii) rights or terms necessary in light of particular legal, regulatory or public policy characteristics of an investor. Certain side letters grant certain investors the right to nominate a member to a Managed Fund’s advisory board; such membership may result in preferential access to confidential Managed Fund information. Such side letters will permit such investors to take actions on the basis of information not available to other investors that do not have the benefit of such agreements. Any rights or terms established in a side letter with an investor will govern solely with respect to such investor (and any of such investor’s assignees or transferees if so specified in the side letter) and will generally not require the approval of any other investor. In addition, side letter arrangements with certain investors of the Managed Funds may impose additional restrictions on investing in certain types of assets, geographies or industries in order to meet certain legal, tax, regulatory, internal policy or other requirements of such

Form ADV 2A | Page 43 of 80

investors. While these restrictions are intended to apply solely to such investors, they may ultimately restrict the investments made by an applicable Managed Fund. Limited Access to Information Investors will have limited rights to information regarding a Client and its investments. It is anticipated that CVC Credit will obtain material information regarding investments that will not be disclosed to investors. In addition, certain investors may request information from CVC Credit relating to a Client and its investments and CVC Credit provide such investors with the information requested (subject to availability, confidentiality obligations and other similar considerations). Any such investors that request and receive such information will consequently possess information regarding the business and affairs of a Client that is not generally known to other investors. As a result, certain investors may be able to take actions on the basis of such information which, in the absence of such information, other investors do not take. Furthermore, at certain times CVC Credit may be restricted from disclosing to investors material non-public information regarding any investments. Diverse Investor Group The investors in Clients are expected to be diverse and to be based in a variety of jurisdictions and take a variety of forms. Investors may have conflicting investment, tax and other interests with respect to their investment in Clients. The conflicting interests of individual investors arise from, among other things, the nature of a Client's investments, the structuring or the acquisition of investments and the timing of disposition of a Client's investments. Conflicts of interest may arise in connection with decisions made by CVC Credit that are more beneficial for one investor than for another investor, especially with respect to an investor's individual tax situation. In selecting, structuring, acquiring and disposing of investments appropriate for Clients, CVC Credit intends to consider the investment, tax and other relevant objectives of Clients and the investors as a whole, and not the investment, tax or other objectives of any investor individually. However, there can be no assurance that a result will not be more advantageous to some investors than to others or to CVC Credit and/or their affiliates than to a particular investor. In addition, Clients will make investments without regard to the impact on related investments made by the investors in separate transactions unrelated to their interest in any funds managed by CVC Credit. Parallel Investment Vehicles CVC Credit reserves the right to establish one or more separate managed accounts or parallel investment vehicles ("Parallel Investment Vehicles") for the benefit of certain investors in Clients, including CVC Credit, which may employ investment strategies that are the same as or that overlap with those of one or more Clients or have the same or similar investment objectives as one or more Clients and have terms that differ from those of such Clients. Parallel Investment Vehicles may have terms that are more beneficial than those of the Clients alongside which it invests. For any investments that fall within the investment objectives of the relevant Clients and the Parallel Investment Vehicles, such Parallel Investment Vehicles will generally invest and divest in each such investment at substantially the same time and on substantially the same terms pro rata based on available capital, unless the relevant general partner or portfolio manager determines in good faith that a different allocation or terms are reasonably necessary or appropriate due to legal, regulatory, tax, accounting and other considerations (which may include investment limitations, investor preferences and/or other reasons). While CVC Credit will seek to allocate investments among the relevant Client and the Parallel Investment Vehicles, it is acknowledged and agreed that certain Parallel Investment Vehicles may not necessarily participate in each investment as a result of the terms of the governing agreement of a relevant Parallel Investment Vehicle, legal, tax, regulatory or other considerations, which will from time to time result in an increase or decrease in a Client's allocable share of such investment. By acquiring units and/or interests, as applicable, investors will be deemed to have acknowledged and consented to any such arrangements and transactions and a Client's participation therein for purposes of all applicable law (including, without limitation, the Advisers Act). In addition to different investor preferences, investors should also note that the terms of Parallel Investment Vehicles (including the economic terms, investment limitations and veto rights with respect to investments, investment period and suspension rights related thereto, diversification parameters, co-investment and any board or governance rights afforded to limited partners of Parallel Investment Vehicles) may materially differ from, and may in some instances be more favorable to the limited partners of Parallel Investment Form ADV 2A | Page 44 of 80

Vehicles than, the terms of the relevant Clients. Such different terms will from time to time create potential conflicts of interests for the relevant general partner, portfolio manager or their affiliates, including with respect to the allocation of investment opportunities. In particular, the carried interest charged and/or management fees paid by the relevant Clients may be less than or exceed the amount of carried interest charged and/or management fees paid by a Parallel Investment Vehicle. Such variation may create an incentive for CVC Credit to allocate a greater percentage of an investment opportunity to such Clients or such Parallel Investment Vehicles. CVC Open-Ended Evergreens CVC has established, and may in the future establish, commingled vehicles with a perpetual investment period and term ("Evergreen Vehicles") that pursue strategies that are the same as or overlap with those of other Clients. CVC is entitled to ongoing economic benefits from Evergreen Vehicles and as Evergreen Vehicles have a continuous need to deploy capital, conflicts of interest may arise in allocating investment opportunities between Evergreen Vehicles and finite-life Clients. CVC will allocate opportunities in accordance with its allocation policy, but a Client may receive a smaller allocation of an opportunity that also falls within the objective of an Evergreen Vehicle. Participation in Clients by Members of CVC CVC and its partners, executives and investment professionals may invest in or alongside a particular Client from time to time. For example, CVC Credit may agree to one or more CVC entities purchasing interests in a Client or its relevant holding entities or otherwise making amounts available for the benefit of a Client (directly or indirectly), including (without limitation) for the purposes of: (i) providing a source of liquidity to such Client, (ii) providing seed capital for prospective investments, and (iii) enabling such CVC entities to participate in respect of any matter in which an investor may cast votes. Such participation may be made on economic terms preferential to other investors (and such other terms CVC Credit considers reasonable having regard to the circumstances). Whilst such CVC investment should generally align the interests of CVC Credit and such persons with the interests of the particular Client and its investors, situations could arise in which CVC Credit or such persons have interests which conflict with the interests of the particular Client and its investors notwithstanding such CVC investment. In addition, CVC personnel may trade in securities or other instruments for their own accounts, subject to restrictions and reporting requirements as may be required by law and subject as provided in the partnership agreements and to any other restrictions implemented from time to time by CVC Credit with respect to such trading activity (including CVC Credit's Code of Ethics). Such trading activity may include buying or selling securities or other instruments in which a particular Client has invested or in securities or other instruments in investment opportunities which were considered by a CVC entity for recommendation to the particular Client but which that particular Client turned down. CVC personnel may also have other separate interests relating to investment opportunities that have been recommended to a particular Client by any of the CVC entities and turned down, including through directorships, subject to relevant policies and procedures implemented by CVC Credit from time to time with respect to such interests. A conflict of interest may arise because through such investing CVC personnel will, for some investments, benefit from the evaluation, investigation, and due diligence undertaken by CVC entities with respect to a potential investment by the particular Client. In such circumstances, the investing CVC personnel will not share in, or reimburse the particular Client or any CVC entity for, any expenses incurred in connection with presenting the investment opportunity to that particular Client. In addition, the terms offered to CVC personnel in respect of such investment opportunity and the circumstances in which such terms are offered may vary from the terms which were offered to the particular Client, and the circumstances that existed at the time of such offer to the particular Client, in respect of such investment opportunity. No Right to Control Clients' Operations Pursuant to the relevant governing document of the various Clients' entities, investors will have no right to control the day-to-day operations of a Client, including investment and divestment decisions.

Form ADV 2A | Page 45 of 80

Nature of Investment An investment in a Client is speculative and requires a medium to long-term commitment with no certainty of return. For certain Clients, the value of units in a Client (and the distributions in respect of it) can fluctuate and may go down as well as up, and an investor may not be repaid the total amounts invested in such Client. Returns generated by a Client's investments may be insufficient to compensate investors adequately for the business and financial risks that must be assumed. A Client's investments will involve a high degree of business and financial risk which can result in substantial losses, including the loss of an investor's entire investment in such Client. In addition, any forward-looking statements (including, without limitation, projections of future earnings or value) contained in a Client's memorandum are subject to known and unknown risks (such as general economic and political conditions which may affect a Client), uncertainties and other factors which may cause actual results to be materially different from those contemplated by such statements. Actual events or results or the actual performance of a Client may differ materially from those reflected or contemplated in such forward-looking statements. Continuous Offering – Deployment of Capital In light of the nature of certain Clients' continuous offering in relation to such Clients' investment strategy and the need to be able to deploy potentially large amounts of capital quickly to capitalize on potential investment opportunities, if such a Client has difficulty identifying and investing in investments on attractive terms, there could be a delay between the time it receives net proceeds from the issue of units in this or subsequent offerings or as part of any private offering and the time such Client invests the net proceeds. Such a Client may also from time to time hold cash pending deployment into investments or have less than its targeted leverage, which cash or shortfall in target leverage may at times be significant, particularly at times when such Client is receiving high amounts of proceeds for issuing units and/or times when there are few attractive investment opportunities. Such cash may be held in an account for the benefit of investors that may be invested in money market accounts or other similar temporary investments, each of which are subject to the management fee (where such cash is committed for investment but not yet deployed) and incentive allocation (to the extent applicable). In the event such a Client is unable to find suitable investments such cash may be maintained for longer periods which would be dilutive to overall investment returns. This could cause a substantial delay in the time it takes for an investor's investment to realize its full potential return and could adversely affect such Client's performance. It is not anticipated that the temporary investment of such cash into money market accounts or other similar temporary investments pending deployment into investments will generate significant interest, and investors should understand that such low interest payments on the temporarily invested cash may adversely affect overall returns. In the event such a Client fails to timely invest the net proceeds of the issuance of units or does not deploy sufficient capital to meet its leverage ratio, such Client's results of operations and financial condition may be adversely affected. Continuous Offering – Effect of Redemption Requests Economic events affecting the global economy, such as general negative performance could cause investors in certain Clients to seek to redeem their units pursuant to such Client's redemption program at a time when such events are adversely affecting the performance of such Client's investments. Even if such a Client decides to satisfy all resulting redemption requests, such Client's cash flow could be materially adversely affected. In addition, if such a Client determines to sell investments to satisfy redemption requests, it may not be able to realize the return on such investments that it may have been able to achieve had it sold at a more favorable time, and such Client's results of operations and financial condition, including, without limitation, breadth of its investments, could be materially adversely affected. Continuous Offering – Liquidity Risk While investors in certain Clients will have the possibility to redeem their units on any redemption dates of such Client, there can be no guarantee that investors seeking to redeem their units on any given redemption date will be able to do so in full or at all, and circumstances may arise in which CVC Credit Form ADV 2A | Page 46 of 80

deems is necessary or advisable to impose restrictions on redemptions. Accordingly, prospective investors should not assume that they will always be able to achieve full liquidity for their units during the life of such Client. Prospective investors in such Clients should further note that circumstances may arise where it is not possible to run a scheduled redemption date as normal and suspensions or modifications to the redemption program (including, without limitation, modifications to the limits set out in the fund governing documents) need to be imposed on any redemption date (including because of certain macro-economic trends and other circumstances outside of CVC Credit's control). Such suspensions and/or modifications to the redemption program may reduce investors' ability to redeem their units and negatively impact the liquidity profile of the units they hold. More generally, prospective investors in such Clients should note that the price that may be achieved on a redemption date may in certain circumstances be discounted and subject to certain fees, costs, expenses or other charges, and as a result may be redeemed below the most recently reported relevant NAV per unit. No guarantee can be given as to the price that will be achieved for investors seeking to redeem their units on any given redemption date. Furthermore, the redemption price may in certain circumstances vary from one investor to another based not only on the number of units being redeemed, but also to take account of different classes and any discounts, fees, costs, expenses and other charges that may be applied with respect to a certain investor and their units. Investors should be aware that such factors may adversely affect the redemption price and general liquidity for its units on any redemption date. Continuous Offering – Distributions Certain Clients do not intend to make distributions and have not established a minimum payment level for distributions, and such Clients' ability to make distributions (if any) to its unitholders could be adversely affected by a number of factors, including the risk factors described in this brochure. Such a Client with no track record may not generate sufficient income to make distributions to such Client's unitholders or otherwise make any distributions at all. CVC Credit will make determinations regarding distributions based upon, among other factors, such Client's financial performance, debt service obligations, debt covenants, tax requirements and capital expenditure requirements. Among the factors that could impair such a Client's ability to make distributions to its unitholders are: the inability to invest the proceeds from sales of units on a timely basis; the inability to realize attractive risk-adjusted returns on investments; the high levels of expenses or reduced revenues that reduce such Client's cash flow or non-cash earnings; and defaults in such Client's investment portfolio or decreases in the value of investments. As a result, such a Client may not be able to make distributions to its unitholders at any time in the future, and the level of any distributions such Client does make to unitholders may not increase or even be maintained over time, any of which could materially and adversely affect the value of unitholders' units in such Client. Such a Client may not generate sufficient cash flow from operations to fully fund distributions to unitholders, particularly during the early stages of such Client's operations. Therefore, such a Client may fund distributions to unitholders from sources other than cash flow from operations, including, without limitation, the sale of assets, borrowings, return of capital or offering proceeds (including from the issuance of units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities). The extent to which such a Client pays distributions from sources other than cash flow from operations will depend on various factors, including the level of participation, the extent to which CVC Credit or its affiliate elects to receive its incentive allocation (if any) in interests of parallel funds (as applicable), how quickly such Client invests its proceeds and the performance of the investments. Funding distributions from the sales of assets, borrowings, return of capital or proceeds of the offering will result in such Client having less funds available to acquire investments. As a result, the return unitholders realize on their respective investment in such Client may be reduced. Doing so may also negatively impact such Client's ability to generate cash flows. Such a Client may be required to continue to fund such Client's regular distributions from a combination of some of these sources if investments fail to perform, if expenses are greater than such Client's revenues or due to numerous other factors. Such a Client has not established a limit on the amount of its distributions that may be paid from any of these sources. Form ADV 2A | Page 47 of 80

To the extent such a Client or any such Client entity borrows funds to pay distributions, it would incur borrowing costs and these borrowings would require a future repayment. The use of these sources for distributions and the ultimate repayment of any liabilities incurred could adversely impact such Client's ability to pay distributions in future periods, decrease such Client's NAV, decrease the amount of cash such Client has available for operations and new investments and adversely impact the value of the unitholders' investment in such Client. Certain Clients may also defer certain fund expenses (including organizational and offering expenses) or pay fund expenses (including the fees of CVC Credit or distributions to CVC Credit or its affiliate) with units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities of such Client in order to preserve cash flow for the payment of distributions. The ultimate repayment of these deferred expenses could adversely impact such Client's operations and reduce the future return on the unitholders' investment in such Client. Such a Client or any such Client entity, as applicable may redeem units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities of such Client from CVC Credit and/or CVC Credit or its affiliates, as applicable shortly after issuing such units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities of such Client as compensation. The payment of expenses in units of the fund, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities of such Client will dilute investors' ownership interest such Client's portfolio of assets. There is no guarantee any of such Client's fund expenses will be deferred and CVC Credit and CVC Credit and/or its affiliates, as applicable, are under no obligation to receive future fees or distributions in units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities (as applicable) of such Client and may elect to receive such amounts in cash. Continuous Offering – Mandatory Redemption CVC Credit or certain Clients may require the redemption of all or any part of the units of any investor at any time for reasons including (without limitation) if an investor is a Prohibited Person, regardless of any outstanding redemption requests and any priority given thereto. Any such mandatory redemption will be subject to the terms as set out in the relevant Client memorandum and fund governing documents unless otherwise determined by the general partner in its discretion. A "Prohibited Person" is any person, firm, partnership or corporate body (including a unitholder (and/or an underlying investor where the unitholder subscribed to the units on its behalf of such underlying investor and/or for such underlying investor's benefit)): that is not eligible to acquire units and/or a given class as per the terms of the memorandum (or that ceases for any reason to be eligible to hold such units and/or given class as per the eligibility criteria and conditions set out in the relevant Client memorandum (including with respect to a specific class); and/or whose holding of units, in the sole opinion of CVC Credit or an affiliate may be detrimental to the interests of such Client, the other unitholders, the general partner and/or CVC Credit, any Client and/or any CVC fund having a credit strategy which is managed, advised and/or operated by, or affiliated with, CVC Credit (each, a "CVC Credit Fund") (including but not limited to cases where the holding of units by such unitholder (or relevant underlying investor where such unitholder subscribed to the units on behalf of such underlying investor and/or for such underlying investor's benefit) may result in a breach of any law or regulation, whether in the United States or abroad, or if as a result thereof such Client, the other unitholders, the general partner and/or CVC Credit, any Client and/or any CVC fund may become exposed to regulatory, tax, economic or reputational damage, obligations, disadvantages, fines or penalties that it would not have otherwise incurred were such unitholder (or relevant underlying investor where a unitholder subscribed to the units on behalf of such underlying investor and/or for such underlying investor's benefit) not invested in such Client). Continuous Offering – In-Kind Remuneration CVC Credit may may elect to receive the management fee and/or incentive allocation attributable to it with respect to a Client in the form of the units of such Client, the aggregators or any parallel fund and/or shares, interests or units (as applicable) of intermediate entities in lieu of certain fees or distributions which may have a dilutive effect in respect of investors in such Client. Redemptions of such Client's units used to satisfy the management fee are not subject to such Client's redemption limitation or early Form ADV 2A | Page 48 of 80

redemption deduction, and such sales may receive priority over other units being put for redemption during such period as set out in the fund governing documents. In-Kind Redemptions and Distributions to Investors In certain circumstances certain Clients may distribute securities and other assets to investors that are not freely traded on an exchange or are otherwise illiquid, including in connection with redemption proceeds. The risk of losses in respect of any such assets or securities (including as a result of any delay in liquidating such assets or securities) will be borne by the investors receiving such assets or securities, with the result that investors could receive less cash than was reflected in the fair value of such assets or securities as determined pursuant to the memorandum. In addition, when investments are distributed to investors in-kind, such investors could then become minority holders in, or lenders to, the relevant investments (or former investments) of such Client and might be unable to protect their interests effectively. No assurances can be given as to how the specific assets or securities to be distributed to investors in such circumstances will be selected and the general partner and/or CVC Credit or any Client will have discretion to select such assets or securities for distributions as it deems appropriate, provided that redeeming investors will only receive in-kind distributions with their consent. In the event that any in-kind distributions are made to investors, the auditor of such Client or any other auditor may establish a report in respect of the in-kind distribution at the request of the Client, general partner, CVC Credit or an affiliate. Accounting Disclosure and Regulatory Standards Accounting, auditing, financial and other reporting standards, practices and disclosure requirements in certain countries in which the Clients may invest are not equivalent to those in the U.S. and certain Western European countries and may differ in fundamental ways. Accordingly, information available to the Clients, including both general economic and commercial information and information concerning specific enterprises, borrowers or assets, may be less reliable and less detailed than information available in more economically sophisticated countries and less information may be available to investors. In addition, in certain instances, a Client may not have access to all available information to determine fully the origination, credit appraisal and underwriting practices utilized with respect to the investments or the manner in which the investments have been operated. As a result, CVC Credit’s due diligence activities may provide less information than due diligence reviews conducted in more developed countries. The lower standards of due diligence in certain countries will increase the risk related to the investments in these countries. While CVC Credit expects that it will endeavor to conduct appropriate due diligence in connection with each investment, no guarantee can be given that they will obtain the information or assurances that an investor in a more sophisticated economy would obtain before proceeding with an investment. Fund Closing The general partner of a Managed Fund shall be under no obligation to proceed with a closing until it determines, in its absolute discretion, that a sufficient level of commitments has been raised to enable a Managed Fund to pursue its strategic objectives. If a Managed Fund does not hold a first closing, investors will not be admitted to the Managed Fund and no funds will be drawn down from investors. Co-Investment Opportunities In certain situations, a Client may not take up an entire investment opportunity or retain an investment in full and CVC Credit or an affiliated general partner may determine that one or more parties should participate in such investment alongside the particular Managed Fund(s) and other Clients at the time such investment is made or following a syndication process. CVC Credit and its affiliates may offer coinvestment opportunities in their sole discretion, are not expected to offer co-investment with respect to all investment opportunities, and may allocate any such opportunities in their sole discretion, including for example, on the basis of the size of investor commitments to Managed Funds, perceived ability for a co-investor to respond rapidly or in certain amounts to co-invest opportunities, or on the basis of any other factor or factors CVC Credit or an affiliate considers appropriate. Consequently, all investors in a Managed Fund may not be afforded an equal opportunity to participate in co-investments, and third parties that are not investors in the Managed Fund may be offered co-investment opportunities that are not offered to investors in the Managed Fund. For example, a Managed Fund may co-invest with current Form ADV 2A | Page 49 of 80

or former clients of CVC Credit or other market participants with which CVC Credit has or wants to develop important business relationships. Such relationships could influence the decisions made by CVC Credit with respect to the purchase or sale of an investment involving co-investment with a coinvestor. Furthermore, a co-investor could have interests that may be contrary to the investment objectives of the Managed Fund. Prospective investors should also note that investors are not required, solely by virtue of their investment in a Managed Fund, to participate in co-investments. Moreover, transaction-specific returns, and an investor’s overall returns from its exposure to the investments of a Managed Fund, may be affected significantly by the extent to which investors are offered and choose to participate in co-investment opportunities. The actual number of co-investment opportunities made available to investors may be higher or lower than those made available in connection with other CVC Credit Managed Funds and other Clients. Syndication of Co-investments and Warehousing CVC may, in its discretion and subject to applicable CVC policies, offer co-investment opportunities alongside the Client to other parties, including other CVC Clients or funds. Certain investors may receive preference or priority for co-investment opportunities based on factors such as their commitments to Clients or CVC funds or relationships with CVC parties. The Client may temporarily fund (“warehouse”) the entire cost of an initial acquisition of an investment with the expectation that a portion will later be reallocated to co-investors or syndicated to other investors, which may include CVC entities and/or other funds or Clients. All warehousing and syndication decisions are made in CVC's sole discretion, and a Client’s investors will not have an opportunity to evaluate or approve such transactions. There is no assurance that the Client will successfully reallocate or syndicate warehoused investments, or that such transactions will occur on favourable terms. The Client may not recover all expenses incurred in connection with warehousing (including borrowing costs), and may not receive interest or retain income accrued during its ownership period. If reallocation or syndication is unsuccessful, the Client may hold greater concentration in an investment than intended, potentially reducing overall returns. Conflicts of interest arise in connection with these transactions. Where CVC is involved on both sides, CVC entities have a conflict in deciding whether, when, and at what price to transfer assets between the Client and other CVC entities, funds or clients. Investments transferred from the Client may subsequently experience improved performance, and the transferee will not be obligated to transfer its share back to the Client. Transfers may be made at cost (plus interest or carrying costs and any related expenses and taxes), and the benefit of any up-front fees, original issue discount, and accrued interest may be shared between transferor and transferee or passed in full to the transferee, in CVC's discretion. CVC may also use fair market value or another methodology for pricing transfers. CVC entities and/or Clients may receive a profit from, and/or the Client may incur a loss on, such transfers. CVC also receives management fees and performance-based compensation from CVC entities that may acquire warehoused investments. CVC has conflicts of interest in connection with warehousing arrangements, including with respect to timing, structuring, pricing, and fees received from acquiring or transferring warehoused assets. Conflicts will not necessarily be resolved in favour of a Client. Risk of Default to Investors Any default by an investor in advancing capital in respect of its commitments to a Managed Fund could have an adverse impact upon the Managed Fund’s ability to complete a transaction and/or could increase the relative exposure of non-defaulting investors to such transactions. Default of an Investment Performance and yield on CVC Credit’s investments may be affected by the default or perceived credit impairment of investments made by CVC Credit and by general or sector specific credit risk spread widening. Credit risks associated with the investments may include the possibility that the earnings of an obligor may be insufficient to meet the debt service obligations, or an obligor’s assets declining in value. An economic downturn and/or rising interest rates could severely disrupt the market for the investments and adversely affect the performance. Any such investment may become defaulted for a Form ADV 2A | Page 50 of 80

variety of reasons, including non-payment of principal or interest, as well as breaches to the contractual covenants. In the event of a default, CVC Credit and those Clients who hold the investment will bear the risk of loss of principal and accrued interest on that investment. Prepayment Risk The terms of loans in which Clients may invest may permit the borrowers to voluntarily prepay loans at any time, either with no or a nominal prepayment premium. This prepayment right could result in the borrower repaying the principal on an obligation held by the Clients earlier than expected. This may happen when there is a decline in interest rates or when the borrower’s improved credit or operating or financial performance allows the refinancing of certain classes of debt with lower cost debt. The yield of the Client’s investment may be affected by the rate of prepayments differing from CVC Credit’s expectations. Assuming an improvement in the credit market conditions, early repayments of the debt held by Clients could increase. To the extent early prepayments increase, they may have a material adverse effect on Client’s investment objectives and profits. In addition, if a Client is unable to reinvest the proceeds of such prepayments received in investments expected to be as profitable, the proceeds generated by Clients will decline as compared to CVC Credit’s expectations. Investment Modification Risk The terms and conditions of loan agreements and related assignments may be amended, modified or waived only by the agreement of the lenders. Generally, any such agreement must include a majority or a super majority (measured by outstanding loans or commitments) or, in certain circumstances, a unanimous vote of the lenders. Consequently, the terms and conditions of the payment obligation arising from investments in liquid assets could be modified, amended or waived in a manner contrary to the preferences of the Clients if a sufficient number of the other lenders concurred with such modification, amendment or waiver. There can be no assurance that any obligations arising from an investment will maintain the terms and conditions to which such Clients originally agreed. The exercise of remedies may also be subject to the vote of a specified percentage of the lenders thereunder. Clients may consent to certain amendments, waivers or modifications to the investments requested by obligors or the lead agents for loan syndication agreements. Clients may extend or defer the maturity, adjust the outstanding balance of any investment, reduce or forgive interest or fees, release material collateral or guarantees, or otherwise amend, modify or waive the terms of any related loan agreement, including the payment terms thereunder. CVC Credit will have the authority to cause the Clients to consent to certain amendments, waivers or modifications to investments in liquid assets requested by obligors or the lead agents for loan syndication agreements. Any amendment, waiver or modification of an investment could adversely impact the Clients’ returns. Bankruptcy and other Significant Events Clients may be a borrower and a creditor through debt investments held by it. Bankruptcy laws may delay the ability of Clients to realize the collateral for debt held by it, or may adversely affect the priority of debt through equitable subordination and other rules. In addition, a borrower may be involved in restructurings, insolvency proceedings or reorganizations under the laws and regulations of one or more jurisdictions. Applicable bankruptcy laws and regulations may provide inferior protections to creditors that result in a restructuring of debt without the creditor’s consent under the certain provisions of applicable bankruptcy laws and may result in a discharge of all or part of a debt investment held by Clients without payment to the Clients. On the other hand, Clients as a borrower may be adversely affected by bankruptcy or other similar proceedings initiated against it or a portfolio company; Clients may not be able to restructure its own debt and instead be forced to sell assets to repay debt, including at inopportune moments, due to laws that afford creditors rights. A bankruptcy, change of control, restructuring or other significant event relating to CVC Credit could cause CVC Credit to have difficulty retaining personnel or may otherwise adversely affect CVC Credit and/or Clients and the Clients’ ability to achieve its investment objective. On April 30, 2024, shares in CVC Capital Partners plc were unconditionally admitted to listing and trading on Euronext Amsterdam (the “IPO”). For information purposes, all public documents relating to the listing are accessible in certain jurisdictions on the CVC website. Access to these documents is restricted in some jurisdictions due to relevant securities laws. CVC believes that the IPO will: (i) provide Form ADV 2A | Page 51 of 80

an enduring and long-term institutional structure to support CVC’s continued evolution as a world class private markets manager, (ii) provide access to the public capital markets, supporting our long-term growth and increasing CVC’s profile, and (iii) strengthen CVC’s ability to attract and retain world class professionals, and enable it to continue investing in its people. Key Personnel The performance of a Client depends substantially on the skill, expertise and continued service of CVC Credit and a limited number of key investment professionals. Clients generally have no employees and rely entirely on CVC Credit and its personnel to source, evaluate, execute and manage investments. The departure, incapacity or reallocation of one or more key personnel, or CVC Credit's inability to attract and retain professionals of comparable calibre, could have a material adverse effect on a Client's ability to achieve its investment objective. Jurisdiction-Specific Credit Risks The value of the investments in debt and other securities may be impacted by various laws enacted in the jurisdictions of incorporation of the borrowers thereunder and, if different, the jurisdictions from which the borrowers conduct their business and in which they hold their assets, which may adversely affect such borrowers’ abilities to make payment on a full or timely basis. A Client may find it necessary or desirable to enforce the security for loans that it holds. The enforcement process varies between different jurisdictions where the loan and/or the assets which secure the loan are located, and may be lengthy and expensive, and may result in differing rates of recovery from jurisdiction to jurisdiction. Borrowers may resist enforcement actions by asserting numerous claims, counterclaims and defenses against the Client, including lender liability claims and defenses, even when such assertions may have no basis in fact, in an effort to prolong enforcement actions and force lenders into a modification of the loans or a favorable buy-out of the borrowers’ positions. In certain jurisdictions, if the borrower files for bankruptcy or utilizes other debtor relief options, this may have the effect of staying any enforcement actions and further delaying the enforcement process. Such a stay on enforcement, and therefore payments to be made to the Client, would likely adversely affect the value of such Client’s investments. In the event of the bankruptcy of a borrower, the loan to such borrower and the security therefore will be subject to the creditor equalization provisions of the law applicable in the relevant jurisdiction (which may include forgiveness of debt, the creation of super-priority liens in favor of certain creditors and the application of certain well-defined claims procedures). Other limitations derived from borrower insolvency may affect the security; in certain jurisdictions, the amount secured by the security is limited to the value of the underlying collateral at the time of bankruptcy, and there may be other jurisdiction-specific issues that negatively impact borrowers’ ability to make payments to Clients, or the Client’s recovery in a restructuring or insolvency, which may adversely affect the Clients. A Client’s investments and the collateral underlying those investments may be subject to various laws for the protection of creditors in the jurisdictions of incorporation of the borrowers concerned and, if different, the jurisdictions in which they conduct business and/or hold assets. Such differences in law may also adversely affect the rights of the Client as a subordinated lender with respect to other creditors. Additionally, a Client, as a creditor, may experience less favorable treatment under different insolvency regimes than those that apply in other jurisdictions, including in cases where the Client seeks to enforce any security it may hold as a creditor. Currency Risks Investments in securities or other instruments that are denominated in a currency other than that in which an investment in a Client is made 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.

Form ADV 2A | Page 52 of 80

Benchmark Interest Rates To the extent investments in Debt and Other Securities made by Clients are subject to a variable interest rate based on (or calculated with reference to) the Secured Overnight Financing Rate (“SOFR”), the Secured Overnight Index Average (“SONIA”), the Euro Interbank Offered Rate (“EURIBOR”), the Canadian Dollar Offered Rate (“CDOR”) or any other offered rate, benchmark or index (collectively, “Benchmark Rates”), Clients will be subject to certain material risks, some of which are described below. Certain Benchmark Rates have historically been, may presently be, and/or may in the future become, the subject of manipulation, regulatory scrutiny and/or reform, phase-out, permanent discontinuation, replacement, tremendous volatility, and other change(s) which may have resulted and/or may result in: (i) any such Benchmark Rate being artificially lower (or higher) than it otherwise would have been; (ii) changes to the applicable calculation methodology; and/or (iii) market uncertainty as to the current and/or future status of any such Benchmark Rate. To the extent any investment in liquid assets bears interest based on (or calculated with reference to) a Benchmark Rate, any such investment in liquid assets may not appropriately embed a return that is commensurate with its risk exposure. Investors should be aware that: (a) any of these changes or any other changes to Benchmark Rates could affect the level of the relevant published rate, including to cause it to be lower and/or more volatile than it would otherwise be; (b) if the applicable rate of interest on any debt instrument is calculated with reference to a tenor or currency which is discontinued, such rate of interest may then be determined by the provisions of the affected debt instrument, which may include determination by the relevant calculation agent in its discretion, or the debt instrument may otherwise be subject to a degree of contractual uncertainty; (c) the administrators of Benchmark Rates will not have any involvement in a Client’s investment and may take any actions in respect of Benchmark Rates without regard to the effect of such actions on a Client or its investments; (d) any uncertainty in the value of a Benchmark Rate or, the development of a widespread market view that a Benchmark Rate has been manipulated, or any uncertainty in the prominence of a Benchmark Rate as a benchmark interest rate due to the recent regulatory reform may adversely affect liquidity of investments in liquid assets in the secondary market and their market value; and (e) an increase in alternative types of financing in place of Benchmark Rate-based debt instruments (resulting from a decrease in the confidence of borrowers in such rates) may make it more difficult to source debt or reinvest proceeds in debt that satisfy the reinvestment criteria specified herein. Any of the above or any other significant change to the setting of a Benchmark Rate could have a material adverse effect on the value of, and the amount payable under, (x) any debt instrument which pay interest linked to a Benchmark Rate and (y) investments in debt and other securities made by Clients. Spread Widening Risks For reasons not necessarily attributable to any of the risks set forth herein (for example, supply/demand imbalances or other market forces), the prices of investments may decline substantially. In particular, purchasing debt and other securities at what may appear to be "undervalued" or "discounted" levels is no guarantee that these assets will not be trading at even lower levels at a time of valuation or at the time of sale. It may not be possible to predict, or to hedge against, such "spread widening" risk. Additionally, the perceived discount in pricing from previous environments described herein may still not reflect the true value of the assets underlying debt investments. Senior Secured Loans Risk Senior secured loans are of a type generally incurred by the borrowers thereunder in connection with highly leveraged transactions. Senior secured loans are typically at the most senior level of the capital structure, but as a result of, among other things, the additional debt incurred by the borrower in the course of such a transaction, the borrower's creditworthiness is often judged by the rating agencies to be below investment grade. Senior secured loans are generally secured on shares in certain group companies and may also be secured by specific collateral or guarantees, including but not limited to, trademarks, patents, accounts receivable, inventory, equipment, buildings, real estate, franchises and common and preferred stock of the borrower and its subsidiaries. In continental Europe security is often limited to shares in certain group companies, accounts receivables, bank account balances and intellectual property rights. This security may well not be perfected. When a Client makes a senior secured loan to an underlying issuer, it generally shall take a security interest in the available assets of Form ADV 2A | Page 53 of 80

the underlying issuer, which should mitigate the risk that Clients will not be repaid. However, there is a risk that the collateral securing a Client's loans may decrease in value over time, may be difficult to sell in a timely manner, may be difficult to appraise, and may fluctuate in value based upon the success of the business and market conditions, including as a result of the inability of the portfolio company to raise additional capital. In some circumstances, a Client's lien could be subordinated to claims of other creditors and/or be subject to restrictions on the exercise of rights or remedies pursuant to subordination arrangements or otherwise. In addition, deterioration in an underlying issuer's financial condition and prospects, including its inability to raise additional capital, may be accompanied by deterioration in the value of the collateral for the loan. Consequently, the fact that a loan is secured does not guarantee that Clients will receive principal and interest payments according to the loan's terms, or at all, or that Clients will be able to collect on the loan should it be forced to enforce its remedies. Although any particular senior secured loan often will share many similar features with other loans and obligations of its type, the actual terms of any particular senior secured loan will have been a matter of negotiation and will thus be highly customized. Any particular loan or obligation may contain terms that are not standard and that provide less protection to creditors than might be expected, including in respect of covenants, events of default, security or guarantees. Sub-investment Grade and Unrated Debt Obligations Risk Clients may invest in other circumstances on an opportunistic basis. Investments in the sub-investment grade categories are subject to greater risk of loss of principal and interest than higher-rated instruments and may be considered to be predominantly speculative with respect to the obligor's capacity to pay interest and repay principal. Such investments may also be considered to be subject to greater risk than those with higher ratings in the case of deterioration of general economic conditions. Because investors generally perceive that there are greater risks associated with non-investment grade instruments, the yields and prices of such instruments may fluctuate more than those that are higher-rated. The market for non-investment grade instruments may be smaller and less active than those that are higher-rated, which may adversely affect the prices at which these investments can be sold or make it impracticable to sell such investments, resulting in losses to Clients, which, in turn, could have a material adverse effect on the performance of Clients. In addition, Clients may invest in investments which constitute obligations which may be unrated by a recognized credit rating agency, which may be subject to greater risk of loss of principal and interest than higher-rated debt obligations or debt obligations which rank behind other outstanding instruments and obligations of the obligor, all or a significant portion of which, may be secured on substantially all of that obligor's assets. Clients may also invest in investments which are not protected by financial covenants or limitations on additional indebtedness. In addition, evaluating credit risk for investments involves uncertainty because credit rating agencies throughout the world have different standards, making comparison across countries difficult. Any of these factors could have a material adverse effect on the performance of Clients. To the extent that a Client invests in sub-investment grade investments that are also stressed or distressed then the risks discussed above are heightened. Collateral Risks The collateral and security arrangements in relation to such secured obligations as Clients may invest in will be subject to such security or collateral having been correctly created and perfected and any applicable legal or regulatory requirements which may restrict the giving of collateral or security by an obligor, such as, for example, thin capitalization, over-indebtedness, financial assistance and corporate benefit requirements. If the investments do not benefit from the expected collateral or security arrangements, this may adversely affect the value of or, in the event of default, the recovery of principal or interest from such investments made by Clients. Moreover, under certain circumstances, collateral or security arrangements securing an investment may be released without the consent of Clients. Accordingly, any such failure to properly create or perfect, or the release of, collateral and security

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interests attaching to the investments could have a material adverse effect on the performance of Clients. A component of CVC Credit's analysis of the desirability of making a given investment relates to the estimated residual or recovery value of such investments in the event of the insolvency of the obligor. This residual or recovery value will be driven primarily by the value of the anticipated future cash flows of the obligor's business and by the value of any underlying assets constituting the collateral for such investment. The anticipated future cash flows of the obligor's business and the value of collateral can, however, be extremely difficult to predict as in certain circumstances market quotations and third-party pricing information may not be available. If the recovery value of the collateral associated with the investments in which Clients may invest decreases or is materially worse than expected by Clients, such a decrease or deficiency may affect the value of the investments made by Clients. Accordingly, there may be a material adverse effect on the performance of Clients. Cov-lite Loans Investments in liquid assets may include "cov-lite" loans. "Cov-lite" loans typically do not obligate the obligor to comply with financial covenants that would be applicable during reporting periods or do not contain common restrictions on the ability of the portfolio company to change significantly its operations or to enter into other significant transactions that could affect its ability to repay such loans. Investments comprised of "cov-lite" loans may expose Clients to different risks, including with respect to liquidity, price volatility and ability to restructure loans, than is the case with other loans. In addition, the lack of such financial covenants may make it more difficult to trigger a default in respect of such loans. Variable and Floating Rate Securities Clients may invest in floating rate debt instruments ("floaters"). The interest rate on a floater is a variable rate which is tied to another interest rate, such as a money-market index. The interest rate on a floater resets periodically. Because of the interest rate reset feature, floaters provide Clients with a certain degree of protection against increases in interest rates, although Clients will participate in any declines in interest rates as well. Clients also may invest in inverse floaters. An inverse floating rate security may exhibit greater price volatility than a fixed rate obligation of similar credit quality. In addition, some variable or floating rate securities are structured with put features that permit holders to demand payment of the unpaid principal balance plus accrued interest from the issuers or certain financial intermediaries. Therefore, such securities may not achieve their expected return. Lack of Liquidity of Assets, Valuation A Client’s assets may, at any given time, include securities and other financial instruments or obligations that are thinly traded or for which no market exists and/or which are restricted as to their transferability under applicable securities laws. The sale of any such investments may be possible only at substantial discounts, and it may be extremely difficult to value accurately any such investments. The process of valuing securities for which reliable market quotations are not available is based on inherent uncertainties, and the resulting values may differ from values that would have been determined had a ready market existed for such securities, from values placed on such securities by other investors and from prices at which such securities may ultimately be sold. Securities and other instruments held by Clients may routinely trade with significant bid-ask spreads. At times, third-party pricing information may not be available for certain positions held by a Client. CVC Credit Partners is entitled to rely, without independent investigation, upon pricing information and valuations furnished to CVC Credit Partners by third parties, including any independent third-party pricing services selected by CVC Credit Partners. In addition, certain cross-transactions and other transactions between Clients managed by CVC Credit Partners, to the extent permitted, are subject to valuation risk. Liquidity Risk Certain of the credit investments held by Clients are highly illiquid, and there can be no assurance that Clients will be able to realize these investments in a timely manner. It is unlikely that there will be a public market for certain of the investments held in Client portfolios. Clients generally will not be able to sell securities held in their investment portfolios publicly unless their sale is registered under applicable securities laws, or unless an exemption from such registration requirements is available. In some cases Form ADV 2A | Page 55 of 80

Clients may be prohibited by contract or regulatory requirements from selling investments for a period of time. In the event of a margin call or other loan repayment at a time when the Client does not have sufficient cash assets to cover such call or payment, it may be forced to liquidate certain investments at less than their expected returns, thereby resulting in lower realized proceeds to Client. Investments in Companies in Regulated Industries Certain industries, such as the energy, healthcare, communications, and technology industries, are heavily regulated. Clients may invest in underlying issuers operating in industries that are subject to greater amounts of regulation than other industries generally. Investments in underlying issuers that are subject to greater amounts of governmental regulation pose additional risks relative to investments in other companies generally. Changes in applicable laws or regulations, or in the interpretations of these laws and regulations, could result in increased compliance costs or the need for additional capital expenditures. If an underlying issuer fails to comply with these requirements, it could also be subject to civil or criminal liability and the imposition of fines. An underlying issuer also could be materially and adversely affected as a result of statutory or regulatory changes or judicial or administrative interpretations of existing laws and regulations that impose more comprehensive or stringent requirements on such issuer. Governments have considerable discretion in implementing regulations that could impact an issuer’s business and governments may be influenced by political considerations and may make decisions that adversely affect an issuer’s business. Additionally, certain underlying issuers may have a unionized workforce or employees who are covered by a collective bargaining agreement, which could subject any such underlying issuer’s activities and labor relations matters to complex laws and regulations relating thereto. An underlying issuer’s operations and profitability could suffer if it experiences labor relations problems. Expedited Transactions Investment analyses and decisions will often be undertaken on an expedited basis to take advantage of investment opportunities. In such cases, the information available at the time of the investment decision may be limited, and CVC Credit may not have access to the detailed information necessary for a more thorough evaluation of the investment opportunity. In addition, the financial information available regarding a potential investment may not be accurate or provided based upon accepted accounting methods. CVC Credit may rely upon independent consultants in connection with its evaluation of proposed investments. There can be no assurance that these consultants will accurately evaluate such investments. Concentrated Portfolio Since CVC Credit will, on behalf of its Clients, invest primarily in the credit markets, Client portfolios generally will not be as diversified as other investment vehicles and may end up with relatively fewer investments. In addition, because of the time it may take to source appropriate investments, certain Managed Funds and Managed Accounts will not initially be diversified. One risk of having a limited number of investments is that the aggregate returns realised by investors may be substantially adversely affected by the unfavourable performance of even a single investment. Accordingly, investments may be subject to a more rapid change in value than would be the case if CVC Credit were required, on behalf of its Clients, to maintain a wide diversification among types of securities, geographical areas, issuers and/or industries. Certain geographic regions and/or industries may be more adversely affected from economic pressures when compared to other geographic regions and/or industries. A concentration by a Client of portfolio assets or collateral securing portfolio assets of a limited number of obligors or obligors within a particular industry or region or a concentration of portfolio assets secured by a limited class of assets could impair the Client’s portfolio if the industry or region were to experience economic difficulties or if the asset class were to fall out of favour in the market. Risks Associated with Hedging Transactions and Derivative Instruments In connection with the financing of certain investments, CVC Credit may employ hedging techniques on behalf of its Clients designed to reduce the risks of adverse movements in interest rates, securities’ prices and/or currency exchange rates. However, even if CVC Credit seeks to hedge certain of these Form ADV 2A | Page 56 of 80

risks, some residual risk to Clients may remain as a result of imperfections and inconsistencies in the market and/or in the hedging contract. While such hedging transactions may reduce certain risks, they may create or magnify others, including, but not limited to, counterparty credit risk and risks associated with the use of derivatives. There may be an imperfect correlation between the instrument acquired for hedging purposes and the investments or market sectors being hedged, in which case, a speculative element is added to the position acquired through a derivative instrument primarily for hedging purposes. Failure to properly hedge the market risk in the investments and/or default of a counterparty in the performance of its obligations under a hedging contract could have a material adverse effect on the Client, and such adverse effects may exceed those which may have resulted had no hedging strategy been employed. Middle-Market Companies CVC Credit Partners, on behalf of its Clients, invests in the debt obligations or securities of middlemarket and/or less well-established companies in both the United States and Europe. While middlemarket companies may have the potential for rapid growth, they often involve higher risks than larger companies. Middle-market companies have more limited financial resources than larger companies and may be unable to meet their obligations under their debt obligations, which may be accompanied by deterioration in the value of any collateral and a reduction in the likelihood of Clients realising any guarantees they may have obtained in connection with their investment. Middle-market companies also typically have shorter operating histories, narrower product lines and smaller market shares than larger businesses, which tend to render them more vulnerable to competitors’ actions and market conditions, as well as general economic downturns. Less publicly available information may be available about these companies, and they may not be subject to the financial and other reporting requirements applicable to public companies. They are more likely to depend on the management talents and efforts of a small group of persons; therefore, the death, disability, resignation or termination of one or more of these persons could have a material adverse impact on the company and, in turn, on the Client. Middlemarket companies may also have less predictable operating results and may require substantial additional capital to support their operations, finance expansion or maintain their competitive position. They may also have difficulty accessing the capital markets to meet future capital needs, which may limit their ability to grow or to repay their outstanding indebtedness upon maturity. If these companies are private companies, there will not be as much publicly available information about these companies as there is for public companies and such information may not be of the same quality. CVC Credit Partners European and US mid-market strategy Managed Funds and Managed Accounts will generally focus on debt investments in middle-market companies. CVC Credit Partners may determine whether companies are US or European-based or qualify as (“Middle-Market”) in its sole discretion, subject to the terms of the relevant governing documents. Follow-On Investments Following an initial investment, CVC Credit may provide additional Client funds to the company. There is no assurance that CVC Credit will make follow-on investments or that Clients will have sufficient funds to make all or any of such investments. Any decision by CVC Credit not to make follow-on investments or its inability to make such investments may have a substantial adverse effect on the borrower in need of such an investment. Additionally, a failure to make such investments may result in a lost opportunity for a Client to increase its participation in a successful investments or result in the dilution of ownership in an investment if a third party makes the follow-on investment. Private Debt Terms A private debt investment may not be paid entirely in cash, but rather partially or wholly in-kind or as an accreting liquidation preference, thus lengthening the time before cash is received, and increasing a Client’s risk exposure. Factors, such as overall economic conditions, the competitive environment and the availability of potential purchasers of the securities may shorten or lengthen a Client’s holding period and some investments may take several additional years from the initial investment date to be realized. In some cases, Clients may be prohibited by contract from selling certain securities for a period of time.

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If a Client is required to liquidate all or a portion of its portfolio positions quickly, then the Client may realize significantly less than the value at which its investments were previously recorded. Direct Lending Some Clients may participate in direct lending investments. Risks associated with direct lending are in addition to risks associated with loans generally and include the possibility of material misrepresentation or omission on the part of the borrower. Such misrepresentation or omission may adversely impact the valuation of the collateral underlying the loan extended to the borrower or may impede a Client’s ability to perfect or effectuate a lien on the collateral securing the loan. CVC Credit will rely upon the accuracy and completeness of representations made by borrowers to the extent reasonable but cannot guarantee such accuracy or completeness. Clients may lend directly to high-risk borrowers, such as companies or individuals with limited or poor credit histories. The risk of default by such borrowers is high, and any such default may lead to material losses. There is no assurance that CVC Credit will correctly evaluate the value of the assets collateralizing loans held by a Client. Exposure to Originated Investments From time to time, certain CVC Credit Partners Clients will originate certain investments with the expectation of later syndicating a portion of such investment to other affiliated funds or third parties. Prior to such syndication, or if such syndication is not successful, such Client’s exposure to the originated investment will likely exceed the exposure that CVC Credit Partners intends for its Client to have over the long-term. Syndication of originated investments is subject to the state of credit markets and investor appetite at the time of syndication, neither of which can be predicted at the time of origination. Market disruptions, tightening credit conditions, adverse developments affecting the borrower or its sector, or a general lessening in risk appetite can impair or entirely prevent successful syndication, which would cause a Client to maintain a larger-than-intended and potentially prolonged exposure to an investment originally planned for syndication. This can result in over concentration in a single issuer, which will more heavily subject a client to risks associated with that issuer. Special Situations CVC Credit Partners may, on behalf of certain Clients, invest in companies involved in (or the target of) acquisition attempts or tender offers or in companies involved in workouts, liquidations, spin-offs, reorganizations, bankruptcies and similar transactions. In any investment opportunity of this nature, there exists the risk that the contemplated transaction will be unsuccessful, will take considerable time or will result in a distribution of cash or a new security whose value will be less than the purchase price. Similarly, if an anticipated transaction does not in fact occur, the Client may be required to sell its investment at a loss. Because there is substantial uncertainty concerning the outcome of transactions involving financially troubled companies in which CVC Credit Partners may invest, there is a potential risk of loss by the Client of its entire investment in such companies. Investments in Non-Performing Loans Certain of CVC Credit Partner’s investments are expected to include investments in non-performing and sub-performing loans which often involve workout negotiations, restructuring and the possibility of foreclosure. These processes are often lengthy and expensive. In addition, investments will likely include securities and debt obligations of financially distressed issuers, including companies involved in bankruptcy or other reorganization and liquidation proceedings. As a result, certain of CVC Credit Partner’s Clients may be subject to additional bankruptcy-related risks and returns on such investments may not be realized for a considerable period of time. Registration under the U.S. Commodity Exchange Act Registration with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a “commodity pool operator” or any change in a Managed Fund’s, its general partner’s or other CVC operations (including, without limitation, any change that causes CVC or its principals to be subject to certain specified covered statutory disqualifications) necessary to maintain CVC’s ability to rely upon an exemption from Form ADV 2A | Page 58 of 80

registration could adversely affect a Managed Fund’s ability to implement its investment program, conduct its operations and/or achieve its objectives and subject a Managed Fund to certain additional costs, expenses and administrative burdens. Furthermore, any determination by CVC to cease or to limit holding or investing in interests which may be treated as “commodity interests” in order to comply with the regulations of the CFTC may have a material adverse effect on a Managed Fund’s ability to implement its investment objectives and to hedge risks associated with its operations. High-Yield Securities CVC Credit may, on behalf of its Clients, invest in bonds or other fixed income securities, including without limitation, commercial paper and “higher yielding” (and, therefore, higher risk) debt securities, when CVC Credit believes that such securities offer opportunities for profit. These securities may be below “investment grade” and face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer’s inability to make timely interest and principal payments. The market values of certain of these lower-rated debt securities tend to reflect individual corporate developments to a greater extent than do higher-rated securities, which react primarily to fluctuations in the general level of interest rates and tend to be more sensitive to economic conditions (including increasing inflation) than are higher-rated securities. It is likely that a major economic recession or an environment characterized by a shortage of liquidity could severely disrupt the market for these securities and may have an adverse impact on their value or liquidity. Moreover, it is likely that any such economic downturn or liquidity squeeze could adversely affect the ability of the issuers of these securities to repay principal and pay interest thereon and increase the incidence of default for these securities. 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 lower-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. Distressed Assets CVC Credit Partners may on behalf of its Clients invest in “distressed assets” securities, private claims and obligations of entities that are experiencing significant financial or business difficulties or have filed for Chapter 11 protection under the U.S. Bankruptcy Code. Investments may include loans, commercial paper, loan participations, trade claims held by trade or other creditors, stocks, partnership interests and similar financial instruments, executory contracts and options or participations therein not publicly traded. Distressed assets may result in significant returns to Clients, but also involve a substantial degree of risk. A Client may lose a substantial portion or all of an investment in a distressed environment, may be required to accept cash or securities with a value less than the Client’s investment or wait extended periods of time to recover an investment in a distressed asset. Among the risks inherent in investments in entities experiencing significant financial or business difficulties is the fact that it frequently may be difficult to obtain information as to the true condition of these issuers. These investments also may be adversely affected by state and federal laws relating to, among other things, fraudulent conveyances, voidable preferences, lender liability and the bankruptcy court’s discretionary power to disallow, subordinate or disenfranchise particular claims. The market prices of these instruments are also subject to abrupt and erratic market movements and above average price volatility and the spread between the bid and ask prices of these instruments may be greater than normally expected. In trading distressed securities, litigation is sometimes required. Such litigation can be time-consuming and expensive and can frequently lead to unpredicted delays or losses. In addition, the markets for distressed assets are frequently illiquid. Mezzanine Investments Certain Clients may make mezzanine investments, which investments are expected to be unsecured and made in companies whose capital structures have significant indebtedness ranking ahead of the investments, all or a significant portion of which may be secured. While the investments may benefit from the same or similar financial and other covenants as those enjoyed by the indebtedness ranking ahead of the investments and may benefit from cross-default provisions and security over the issuer’s assets, some or all of such terms may not be part of particular investments. Moreover, the ability of a Form ADV 2A | Page 59 of 80

Client to influence such an issuer’s affairs, especially during periods of financial distress or following an insolvency, is likely to be substantially less than that of senior creditors. Many of the remedies available to mezzanine investors are available only after satisfaction of claims of senior creditors, and therefore, in the event that an issuer does not generate adequate cash flow to service its debt obligations to senior creditors, mezzanine investors could suffer a partial or total loss of their investment. Mezzanine investments generally are subject to various risks, including, without limitation: the possible invalidation of an investment transaction as a “fraudulent conveyance,” (ii) the recovery of liens perfected or payments made on account of a debt in the period before an insolvency filing as a “preference,” (iii) equitable subordination claims by other creditors, (iv) so called “lender liability” claims by an issuer of the obligations and (v) environmental liabilities that may arise with respect to collateral securing the obligations. Some mezzanine debt investments are also subject to early redemption features, refinancing options, prepayment options or similar provisions which, in each case, could result in the issuer repaying the principal on an obligation earlier than expected, which may adversely affect a Client's investment. Equity and Equity-Like Investments Certain CVC Credit Partners Clients may invest in preferred equity interests, convertible securities, warrants and otherwise in securities that have equity-like features and may otherwise end up owning equity securities as part of making or owning a debt instrument (e.g., in the case of foreclosure). Any equity interest owned by the Clients will generally rank junior to all existing and future indebtedness, including commercial mezzanine loans and senior debt. In the event of a bankruptcy, liquidation, reorganization or other winding-up with respect to an issuer in which the Client holds an equity interest, the Client will bear a risk of loss principal as such interests are not generally secured. Convertible Securities CVC Credit Partners, on behalf of its Clients, may invest in convertible securities, which are bonds, debentures, notes, preferred stocks or other securities that may be converted into or exchanged for a specified amount of common stock of the same or different issuer within a particular period of time at a specified price or formula. A convertible security entitles the holder to receive interest that is generally paid or accrued on debt or a dividend that is paid or accrued on preferred stock until the convertible security matures or is redeemed, converted or exchanged. Convertible securities have unique investment characteristics in that they generally (i) have higher yields than common stocks, but lower yields than comparable non-convertible securities, (ii) are less subject to fluctuation in value than the underlying common stock due to their fixed income characteristics and (iii) provide the potential for capital appreciation if the market price of the underlying common stock increases. Credit Derivatives CVC Credit Partners may, on behalf of its Clients, engage in trading in credit derivative contracts, which are contracts that transfer price, spread and/or default risks of debt and other instruments from one party to another, both for bona fide hedging of existing long and short positions, but also for independent profit opportunities. Such instruments may include one or more credits. The market for credit derivatives may be relatively illiquid, and there are considerable risks that may make it difficult either to buy or sell the contracts as needed or at reasonable prices. There are also risks with respect to credit derivatives in determining whether an event will trigger payment under the contract and whether the payment will offset the loss or payment due under another instrument. Generally, a credit event means bankruptcy, a failure to pay, the acceleration of an obligation or modified restructuring of a credit obligation or instrument. CVC Credit Partners may, on behalf of its Clients, be either the buyer or seller in these transactions. If CVC Credit Partners is a buyer of credit protection on behalf of its Clients and no credit event occurs, the Client may recover nothing. 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. Buyers of credit derivatives carry the risk of non-performance by the seller due to an inability to pay. As a seller of credit protection, a Client would typically receive 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 Form ADV 2A | Page 60 of 80

obligations. Sellers of credit derivatives carry the inherent price, spread and default risks of the underlying instruments. Credit default swaps involve greater risks than if the Client had invested in the reference obligation directly. In addition to general market risks, credit default swaps are subject to liquidity risk and credit risk. A buyer of credit protection also may lose its investment and recover nothing if no credit event occurs. If a credit event does 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 to the Client. Further, 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 such deliverable security is unavailable or illiquid. Such a delivery crunch is a distinct risk of these investments. The credit derivatives market is a rapidly evolving market. As a result, different participants in the credit derivatives markets may have different practices or interpretations with respect to applicable terms and definitions, and ambiguities concerning such terms or definitions may be interpreted or resolved in ways that are adverse to Clients. Additionally, there may be circumstances and market conditions (including the possibility of a large number of buyers of credit default swaps being required to deliver the same physical security in the same time frame) that have not yet been experienced and that could have adverse effects on a Client’s investments. Short Sales CVC Credit Partners may, on behalf of its Clients, engage in short sales of securities. Short sales can, in certain circumstances, substantially increase the impact of adverse price movements on a Client’s portfolio. A short sale involves the risk of sudden and substantial losses (for example in the case of an acquisition proposal at a substantial premium over an issuer’s market price), losses in an amount greater than the amount invested, and a theoretically unlimited risk of loss based on an unlimited potential increase in the market price of the particular investment sold short. These risks could in turn result in an inability to cover the short position, and CVC Credit Partners may be unable to cover short positions on a timely basis for other reasons, including the possibility that CVC Credit Partners will be prohibited from trading a security because it has material nonpublic information about the issuer or is otherwise subject to regulatory or operational impediments to trading. There is also a risk that a Client would be forced to return the securities it borrows in connection with a short sale, to the securities lender on short notice. If a request for the return of borrowed securities occurs at a time when other short sellers of the security are receiving similar requests, a short squeeze can occur, and a Client may be compelled to replace borrowed securities previously sold short with purchases on the open market at the most disadvantageous time, possibly at prices significantly in excess of the proceeds received in originally selling the securities short. Investment Litigation Risk Financial performance of underlying issuers in which CVC Credit has invested may be affected from time to time by litigation such as contractual claims, occupational health and safety claims, public liability claims, environmental claims, industrial disputes, tenure disputes and legal action from special interest groups. Such litigation could materially reduce the value of a Client’s investments. CVC Credit’s investment activities subject it, and Clients, to the normal risks of becoming involved in litigation by third parties. This risk is somewhat greater where CVC Credit exercises control or significant influence over a company’s direction. Participation on Creditors’ Committees CVC Credit, on behalf of its Clients may elect to appoint a representative to serve on creditors’ committees, official or unofficial, equity holders’ committees or other groups (in addition to boards of directors) to ensure preservation or enhancement of the investment as a creditor or equity holder. A member of any such committee or group may owe certain obligations generally to all parties similarly situated that the committee represents. If CVC Credit concludes that its obligations owed to the other parties as a committee or group member conflict with its duties owed to its Clients, it may resign from that committee or group, and the Clients may not realise the benefits, if any, of participation on the committee or group. In addition, and also as discussed above, if a Client is represented on a committee Form ADV 2A | Page 61 of 80

or group, it may be restricted or prohibited under applicable law from disposing of or increasing its investments in such underlying issuer while it continues to be represented on such committee or group and potentially thereafter. Furthermore, to the extent that CVC Credit is exposed to material non-public information about a company, it could limit CVC Credit’s ability to invest any Client in, or divest any Client of, securities issued by the company. Structured Products CVC Credit Partners may invest in structured products, including asset-backed securities (“ABAs”), CLOs and other securitisations or pooled vehicles (and in such cases a double layer of fees and expenses would be borne by investors), which are generally limited recourse obligations of the issuer payable solely from the underlying assets of the issuer or proceeds thereof. Consequently, holders of equity or other securities issued by such structured products must rely solely on distributions on the underlying assets or proceeds thereof for payment in respect thereof. The underlying assets may include, without limitation, broadly syndicated leverage loans, middle-market bank loans, CDO debt tranches, trust preferred securities, insurance surplus notes, asset-backed securities, mortgages, real estate or infrastructure investments, real estate investment trusts, high-yield bonds, mezzanine debt, second-lien leverage loans, credit default swaps and emerging market debt and corporate bonds, which are subject to liquidity, market value, credit, interest rate, reinvestment and certain other risks. Structured products often are extremely complex and are subject to various material risks, including default, basis, illiquidity, lack of transparency, market, geographical concentration, servicer and other counterparty non-performance, legal, and operational risks. Structured product transaction structures and investor terms vary widely, and the risks of a particular investment depend materially on its structural mechanics, including payment allocation waterfalls, treatment of credit losses, revolving versus static collateral pools, maturity and reversion mechanics and the extent and terms of credit enhancement and sponsor or obligor support. Many structured products contain covenants designed to protect the providers of debt financing to such structured products. A failure to satisfy those covenants could result in the untimely liquidation of the structured product and potentially a complete loss of the investment. In addition, if the particular structured product is invested in a security in which the Client is also directly invested, this would tend to increase the Client’s overall exposure to the credit of the issuer of such securities. The value of an investment in a structured product will depend on the investment performance of the underlying assets or interests in which the structured product invests and will, therefore, be subject to all of the risks associated with an investment in those underlying assets or interests. These risks include the possibility of a default by, or bankruptcy of, the issuers of such assets or a claim that the pledging of collateral to secure any such asset constituted a fraudulent conveyance or preferential transfer that can be subordinated to the rights of other creditors under applicable law. The returns received on an investment in structured products may be subject to significant fluctuations as a result of relatively small changes in interest rates; the rates of prepayments, modifications, defaults or late payments with respect to the relevant underlying assets; governmental regulation (e.g., loan forgiveness or forbearance programs); or other factors. Structured products may include one or more underlying issuers in which one or more of CVC Credit’s Clients have acquired an interest, including CVC Capital Portfolio Companies. In addition, in the case where the Client is invested in structured products, the diversification limitations set forth in the Client Agreements will be applied separately to each underlying issuer and/or borrower comprising such structured product. This may result in an unintended concentration of the Client’s investments in a limited number of issuers. Asset-Backed Securities Certain Clients invest in ABSs, which are securities and instruments backed by various types of assets. The investment characteristics of ABSs differ from traditional debt securities. Certain issuers of ABSs permit loan servicers to retain possession of the underlying obligations. If the servicer were to sell these obligations to another party, there is a risk that the purchaser would acquire an interest superior to that of the holders of the related ABSs. In addition, because of the large number of vehicles involved in a typical issuance and technical legal requirements, holders of ABSs might not have an enforceable Form ADV 2A | Page 62 of 80

security interest in all of the obligations backing such ABSs. Therefore, there is a possibility that recoveries on repossessed collateral might not, in some cases, be available to support payments on these securities. Returns from an ABS will depend primarily on the cash flow from or sale proceeds of the pool of assets serving as collateral for the ABS and, therefore, are subject to all the risks inherent to an investment in such pool of assets. The loans underlying ABSs are typically of shorter maturity than certain other types of loans and are less likely to experience substantial prepayments, although the principal may be prepaid at any time. The value of an ABS can be affected by changes in the market’s perception of the asset backing the security and the creditworthiness of the servicing agent for the loan pool, the originator of the loans or the financial institution providing any credit enhancement, as well as by the expiration or removal of any credit enhancement. In addition, investments in subordinated ABSs involve greater credit risk of default than the senior classes of the issue or series. Default risks are further pronounced in the case of ABSs secured by, or evidencing an interest in, a relatively small or less diverse pool of underlying loans. Certain subordinated securities absorb all losses from default before any other class of securities is at risk, particularly if such securities have been issued with little or no credit enhancement equity. Such securities, therefore, possess some of the attributes typically associated with equity investments. Structured Credit Instruments Clients may invest in structured credit instruments, including collateralized debt obligations, CLOs, collateralized bond obligations, collateralized mortgage obligations and other similar securities. These instruments may consist of fixed pools or may be managed pools of collateral, including commercial loans, high yield debt, structured securities and derivative instruments relating to debt. Such pools are typically separated into tranches representing different degrees of credit quality, with lower rated tranches being subordinate to senior tranches. The senior tranches, which represent the highest credit quality in the pool, have the greatest collateralization and pay the lowest spreads over treasuries. Lower rated tranches represent lower degrees of credit quality and pay higher spreads over treasuries to compensate for the attendant risks. Structured credit securities are subject to risks related to, among other things, changes in interest rates, the rate of defaults in the collateral pool, the exercise of redemption rights by more senior tranches and the possibility that a liquid market will not exist when the Client attempts to dispose of such investment. If the structured credit markets face uncertainty or deteriorate, Clients investing in structured credit instruments may not be presented with sufficient investment opportunities in other structured credit products, which may prevent such Clients from successfully executing investment strategies in such investments. Moreover, uncertainty or deterioration in the structured credit markets could result in declines in the market values of or increased uncertainty with respect to investments made or considered by Clients, which could require the Client to dispose of investments at a loss while such adverse market conditions prevail. CLOs Certain Clients of CVC Credit Partners may have investment strategies permissive of investments in CLO notes. The underlying assets of CLOs are typically actively managed by a manager, and as a result the underlying assets will be traded, subject to rating agency and other constraints, by such manager. The aggregate return on CLO equity securities will depend in part upon the ability of each investment manager to actively manage the related portfolio of underlying assets. Fees, costs and expenses of the Client and the CLOs in which the Client invests generally will be paid regardless of whether the Client or the CLOs produce positive investment returns. Generally, CLO notes will have limited liquidity and are subject to substantial transfer restrictions. CLO notes are often illiquid investments and there is no established secondary market for the notes. There can be no assurance that any secondary market for any of the notes will develop, or if a secondary market does develop. Securities issued in securitizations transactions may experience high volatility and significant fluctuations in market value. Additionally, some potential buyers of such securities may view securitization products as an inappropriate investment or may be unable to invest in them due to regulatory reasons (EU and Japanese securitization rules), thereby reducing the number of potential buyers and/or potentially affecting liquidity in the secondary market.

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CLOs issue notes in multiple tranches with differing rights to principal and interest. Payments on more junior or subordinated tranches are contingent upon satisfaction of senior claims and are often also contingent upon compliance with structural tests embedded in the CLO indenture, including overcollateralization tests and interest coverage tests. If such tests are not satisfied, cash flows that would otherwise be distributed to holders of junior notes may be redirected to pay down senior tranches or be held as credit enhancement. Clients investing in mezzanine or subordinated CLO tranches face the risk that distributions are reduced or eliminated, and that the market value of such notes decreases substantially. A CLO's ability to make payments on its notes depends primarily on the creditworthiness and performance of the underlying loans and other debt obligations comprising the CLO's portfolio. Defaults on loans in a CLO's portfolio may materially reduce the amounts received by CLO noteholders. The performance of a CLO is materially dependent upon the skills and judgment of the CLO's collateral manager in selecting, monitoring, and managing the underlying loan portfolio. Poor portfolio selection, inadequate credit surveillance, adverse trading decisions, failure to comply with the CLO indenture's eligibility criteria and concentration limits, or the insolvency, replacement, or resignation of the collateral manager may adversely affect the cash flows and market value of CLO notes held by a Client. CLO investments are governed by complex legal and transactional documentation. Interpretation disputes, legal uncertainties or unanticipated amendments to transaction documents may limit the ability of CLO noteholders to enforce their rights or may alter the economics of their investment. In addition, CLO notes may be subject to the laws of multiple jurisdictions, and applicable legal standards may evolve or change in ways that adversely affect CLO noteholders. Illiquidity in the CLO and Structured Credit Markets In the past, events in the CLO and structured credit markets have resulted in substantial fluctuations in prices for leveraged loans and high-yield debt securities and limited liquidity for such instruments. No assurance can be made that conditions giving rise to similar price fluctuations and limited liquidity may not emerge in the future. During periods of limited liquidity and higher price volatility, a Client’s ability to acquire or dispose of these investments at a price and time that a Client deems advantageous may be severely impaired. As a result, in periods of rising market prices, a Client may be unable to participate in price increases fully to the extent that it is unable to acquire desired positions quickly; and a Client’s inability to dispose fully and promptly of positions in declining markets may exacerbate losses suffered by a Client when collateral obligations are sold. CVC Capital Partners plc as a Public Company As a consequence of CVC Capital Partners plc’s status as a public company, the officers, directors, members, managers and personnel of CVC entities may take into account certain considerations and other factors that would not necessarily be taken into account if CVC Capital Partners plc were not a public company, including, for example, the need for the CVC Capital Partners plc board to generate value and returns for its shareholders. As a public company, CVC Capital Partners plc is subject to certain disclosures and reporting requirements which may necessitate the disclosure and/or reporting of information in a manner or timeframe which would otherwise not apply, and such disclosure or reporting could adversely affect the interests of CVC Capital Partners plc and other CVC entities, as well as the interests of Clients and investors to a greater extent than would otherwise be the case. While management of Clients is conducted independently from CVC Capital Partners plc, circumstances could arise in which decisions are taken by the CVC Capital Partners plc board in the interests of shareholders which may indirectly or directly impact Clients and which, more generally, do not necessarily align with Client interests. Risks Affecting Secondary Investments Certain Clients can allocate capital to secondaries opportunities in order to acquire, and hold as investments, interests in underlying credit funds. Such Clients are “secondary” funds of funds acquiring interests in the underlying funds from existing investors. Where a Client makes a secondary investment in an underlying fund by acquiring an interest in such underlying fund from an existing investor, the Client generally will not have the opportunity to negotiate the terms of the interests being acquired, other than the purchase price, or other special rights or privileges. In addition, Clients may receive inForm ADV 2A | Page 64 of 80

kind distributions of securities from underlying funds. There can be no assurance that securities distributed in kind by underlying funds to Clients will be readily marketable or saleable, and such Clients may be required to hold such securities for an indefinite period and/or may incur additional expense in connection with any disposition of such securities.

9. Disciplinary Information Neither CVC Credit nor its management personnel have been involved in or are the subject of any legal or disciplinary events that would be material to a Client’s or prospective Client’s evaluation of CVC Credit’s advisory business or the integrity of CVC Credit or its management personnel.

10. Other Financial Industry Activities and Affiliations Related Persons Relying Investment Advisers CVC Credit UK is a relying adviser of CVC Credit Partners, LLC and is authorized and regulated by the U.K. Financial Conduct Authority. CVC Credit UK is also registered as foreign company with the Australian Securities and Investments Commission. CVC Credit Partners European Investment Fund Manager Limited is also a relying adviser of CVC Credit Partners, LLC and is authorized and regulated by the Jersey Financial Services Commission. A single Executive Committee oversees the operations of CVC Credit. In addition, certain senior CVC Credit personnel are members of CVC Credit UK investment committees, and vice versa, and certain investment committees are joint, comprised of representatives from CVC Credit Partners, LLC and CVC Credit UK senior investment personnel. CVC Credit UK and CVC Credit Partners European Investment Fund Manager Limited are subject to the global CVC Code of Ethics (see Item 11 below) and their personnel are Access Persons of CVC Credit Partners, LLC. CVC Credit UK, CVC Credit Partners European Investment Fund Manager Limited and their personnel are subject to CVC Credit Partners, LLC’s regulatory oversight and its compliance policies and procedures, including those addressing books and records maintenance. CVC Credit UK manages CLOs, Managed Funds and Managed Accounts. CVC Credit UK Clients focus primarily on European investment opportunities. Nonetheless, Clients of CVC Credit Partners, LLC and CVC Credit UK invest in substantially similar assets classes and may, in some instances, invest in the same instruments. In an effort to mitigate potential conflicts of interest, CVC Credit follows the procedures described below in Item 10 for the allocation of investments that are suitable for both CVC Credit Partners, LLC and CVC Credit UK Clients. CVC Credit CLO Management Two separate investment advisers, CVC Credit Partners U.S. CLO Management LLC in the United States and CVC Credit Partners European CLO Management, LLP in the U.K. are part of CVC Credit Partners and under common control with CVC Credit Partners. Both of these entities have their own distinct set of employees and their own investment committee and investment process. CVC Credit CLO Management manages CLOs focused on investing in the United States and Europe. While each manager maintains its own compliance program, certain policies and practices (outside of the investment process) are similar and aggregated across all CVC Credit Partners’ investment management entities. Certain supervised persons of CVC Credit Partners are employees of CVC Credit CLO Management, and act on behalf of CVC Credit Partners pursuant to a personnel sharing agreement. Commodity Pool Operators and Commodity Trading Advisors Because certain Managed Funds and Managed Accounts may have the ability to invest in commodity interests, CVC Credit Partners may be subject to regulation under the Commodity Exchange Act and the regulations of the CFTC as a commodity pool operator or commodity trading adviser with respect Form ADV 2A | Page 65 of 80

to the services it provides to these Managed Funds and Managed Accounts. However, because CVC Credit Partner’s Managed Funds and Managed Accounts limit trading in commodity investments, are not offered to U.S. investors, make limited use of U.S. markets, and/or because interest in the Managed Funds and Managed Accounts are offered and sold without marketing to the public in the United States, CVC Credit Partners is exempt from registration as a commodity pool operator or commodity trading adviser with respect to these Managed Funds and Managed Accounts pursuant to applicable CFTC regulations.Pooled Investment Vehicles CVC Credit and its affiliates within the CVC business serve as sponsors or general partners of pooled investment vehicles including, but not limited to, collateralized debt obligations and private funds. CVC Credit Partners European Opportunities Limited CVC Credit Partners Income & Growth Limited (“CCPIGL”) is a closed-ended investment company limited by shares, registered and incorporated in Jersey under the Companies Law on 20 March 2013, with registration number 112635. CCPIGL is subject to, and required to comply with, certain regulatory requirements that are applicable to closed-ended investment companies which are domiciled in Jersey including compliance with any decision of the Jersey Financial Services Commission (“JFSC”). In addition, CCPIGL is subject to the continuing obligations imposed by the UK Listing Authority and the London Stock Exchange on all investment companies whose shares are admitted to the Official List and to trading on the Main Market. CCPIGL is self-managed with the board of its directors making all management decisions (including overseeing CCPIGL’s investment policy and investment strategy) on a majority basis. CVC Credit Partners Investment Services Management Limited CVC Credit Partners Investment Services Management Limited (“CVC Investment Services”) is party to a Trade Mark Licence Agreement with CCPIGL pursuant to which CCPIGL licenses the use of the marks “CVC” and “CVC Credit Partners” from CVC Investment Services. Separately, CCPIGL has appointed CVC Credit UK to provide marketing and financial intermediary services to CCPIGL pursuant to a corporate services and support agreement dated 29 March 2019 in exchange for CVC Credit UK charging a fee calculated as the aggregate cost incurred by CVC Credit UK in providing the relevant services, and allocating to CCPIGL the relevant proportion of that overall cost incurred by CVC Credit UK, as agreed by CVC Credit UK and CCPIGL from time to time. Affiliated Broker-Dealers CVC has established CVC Capital Markets, a European broker-dealer that primarily conducts certain capital markets activities using its own balance sheet capital, and CVC Funding, LLC a U.S. registered broker-dealer and wholly-owned subsidiary of CVC Credit Partners, LLC (“CVC Funding”, and together with CVC Capital Markets, “Affiliated Brokers”). Affiliated Brokers may, directly or through related lending vehicles, participate in underwriting syndicates and/or selling groups with respect to securities, loans, or other instruments issued by borrowers or other companies in which CVC Credit Clients have a financial interest (“CVC Portfolio Companies”), and provide capital markets and credit advisory services, acquisition financing, and other forms of advice and financing to Clients and/or CVC Portfolio Companies (together, “Affiliated Broker Activities”). The Affiliated Broker Activities may relate to securities, loans, and other instruments issued by a CVC Portfolio Company that are senior or junior in the capital structure to, or that otherwise afford different rights than, those held by Clients, including commitments to engage in such transactions in the future. Subject to applicable law, Affiliated Brokers may receive arm’s length underwriting, placement, syndication and transaction fees and other compensation from a CVC Portfolio Company or intermediate holding vehicle of a Client for Affiliated Broker Activities, which may be retained by the Affiliated Brokers without any reduction of, or offset against, the management fee payable by the Client. Subject to applicable law, Affiliated Brokers may also receive underwriting, placement, syndication and transaction fees, and other compensation, for transactions and services provided to companies that are not CVC Portfolio Companies, which compensation generally will not be shared with or reimbursed to Clients. Affiliated Brokers may also engage in transactions or provide advisory services to companies that are not CVC Portfolio Companies or otherwise affiliated with CVC, including with respect to transactions that would be an appropriate investment for a CVC Credit Client.

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Certain conflicts of interest in connection with Affiliated Broker Activities may arise, in particular in respect of any CVC Portfolio Companies or intermediate holding vehicles with respect to which an Affiliated Broker provides services. For example, CVC may be seen as incentivized to: (i) seek to influence the decision by a CVC Portfolio Company’s management to retain or otherwise transact with an Affiliated Broker instead of other third parties that may be more appropriate or offer better terms, but who are unaffiliated with CVC; (ii) structure CVC Portfolio Company transactions so that they require the use of an Affiliated Broker; or (iii) negotiate attractive fees or compensation for an Affiliated Broker. Conflicts could further arise where CVC may be incentivized to underwrite and/or syndicate securities as a result of the fees that could be earned from an Affiliated Broker underwriting the financing of an investment. Moreover, in situations where an Affiliated Broker, as a result of Affiliated Broker Activities, holds a position in a portfolio company in which a Client invests (including as a result of a shortfall arising as a result of an incomplete or failed syndication), the arrangement may lead to a conflict between an Affiliated Broker and the Client in the event of a default by, or the liquidation of, the portfolio company or a restructuring or renegotiation of the terms of a loan or other relevant securities. In certain circumstances, including by way of an example, where a CVC Portfolio Company becomes distressed and the participants in the relevant offering have a valid claim against the underwriter, the Client may have a conflict in determining whether to seek recourse or sue an Affiliated Broker. CVC may also in certain cases have incentives to not bring similar claims against, or otherwise to favor, unaffiliated broker-dealers with whom an Affiliated Broker has a material business relationship. While such potential conflicts cannot be excluded, an Affiliated Broker will generally seek to provide such underwriting activities as part of an underwriting syndicate where an Affiliated Broker would exercise any voting or other rights relating to a portfolio company in line with the voting and exercise of corresponding rights held by other non-CVC affiliated members of such syndicate, with any fees charged in connection with its services being charged on a consistent basis with other non-CVC affiliated entities providing similar services as part of such syndicate. An Affiliated Broker may in the future also engage in similar activities with respect to companies that are not CVC Portfolio Companies or otherwise affiliated with CVC, including with respect to transactions that would be an appropriate investment for Clients. Other potential conflicts of interest include the possibility that the participation of a Client in certain circumstances may be limited or prohibited due to tax law or regulatory constraints or may be more expensive or impractical due to other conflicts arising from the Affiliated Broker’s role in such transaction. Also, where an Affiliated Broker provides services to unaffiliated entities, the Affiliated Broker may have access to investment opportunities that are suitable for Clients. However, in these cases, the Affiliated Broker will have no obligation to make an investment opportunity available to Clients, and in some cases may be precluded from making such an opportunity available to Clients. CVC may also, on behalf of a Client, effect transactions where an Affiliated Broker is acting as a broker on the other side of the same transaction. The Affiliated Broker may retain commissions or other compensation earned in such transactions. CVC will approve any such transaction on behalf of a Client only where the Investment Manager believes in good faith that the transaction is appropriate for the Account and consistent with applicable law. CVC seeks to mitigate conflicts associated with Affiliated Brokers through conflicts of interest policies and procedures that impose certain controls on transactions involving Affiliated Brokers, as may be updated and amended from time to time without notice to Clients (to the maximum extent not prohibited by applicable law). CVC Funding also acts as distributor and/or placement agent for private funds managed by CVC Credit, CVC Capital Partners, CVC Secondary Partners and co-investment opportunities related to these funds. From time to time, underlying investors in Clients of CVC Credit may be solicited to invest in private funds managed by CVC Capital Partners or CVC Secondary Partners, and clients of CVC Capital Partners and CVC Secondary Partners may be solicited to invest in private funds managed by CVC Credit. CVC Funding receives compensation from CVC Credit in connection with such solicitation activities, but does not presently earn commissions or other transaction-based compensation from third parties for these activities. CVC Group Form ADV 2A | Page 67 of 80

Private Equity Business (CVC Capital Partners) CVC Advisors (U.S.), Inc. (“CVC US”) is an SEC-registered investment adviser and is wholly-owned by CVC Advisers (Luxembourg) Sàrl (“CVC Advisers Luxembourg”), which is principally held, through various intermediate subsidiaries, by CVC Capital Partners Advisory Group Holding Foundation, a foundation incorporated under the laws of Jersey, Channel Islands. CVC Advisers Jersey Limited (“CVC Advisers Jersey”)2 is a limited company incorporated in Jersey, Channel Islands. CVC Advisers Jersey acts as investment adviser to certain CVC private equity funds (each, a “CVC Capital Fund” or “CVC Fund”). Local CVC-affiliated sub-advisers organized in Europe, Asia and the Americas (including CVC US) make investment recommendations to CVC Advisers Jersey investment committees and cost approval committees. CVC’s private equity business is primarily engaged in advising and managing private equity funds that generally acquire controlling or significant minority interests in European, North American and Asian businesses. CVC’s global private equity platform includes investment professionals across 24 countries in Europe, the Americas and the Asia-Pacific region. CVC and its predecessors have operated as an independent investment advisory business since 1993. From time to time, CVC may pay compensation under a shared services agreement or through other means to personnel of CVC Capital Partners to provide certain investor relations services to Clients that are invested in CVC Capital Partners products, and to investment personnel of CVC Capital Partners for introducing or facilitating the completion of deals. As described in Item 4 above, CVC Credit and CVC Capital Partners are under common control of CVC Nominees Limited. CVC Secondary Partners A strategic partnership with CVC Secondary Partners, LLP and CVC Secondary Partners (U.S.), LLC (formerly Glendower Capital and collectively now referred to as ‘CVC Secondary Partners’) was announced in September 2021 to provide dedicated investment and liquidity solutions for secondary private markets through CVC Secondary Partners’ established fund portfolio and GP-led secondary private equity strategies. As described in Item 4 above, CVC Credit and CVC Secondary Partners are under common control of CVC Nominees Limited. The strategic partnership closed in January 2022. CVC Secondary Partners’ fund general partners that are formed following the date of the strategic partnership will be affiliates of CVC Secondary Partners and the broader CVC Group. The entities comprising CVC Secondary Partners are the primary investment advisers to a number of existing CVC Capital-managed secondaries funds. While CVC is the sole equity owner of CVC Secondary Partners, the senior management team of CVC Secondary Partners exercises independent authority over (i) the day-to-day operations of CVC Secondary Partners and (ii) the investment activities of the CVC Secondary Partners Funds, without involvement from the broader CVC Group. CVC Capital Markets As discussed above, CVC Capital has established CVC Capital Markets to conduct certain capital markets activities using its own balance sheet capital, including acting as underwriter and/or investing as principal on arm’s length terms in any offering or placement of debt and/or equity securities, loans or instruments issued by portfolio companies or intermediate holding vehicles of CVC Capital Funds. CVC DIF In September 2023, CVC announced its strategic acquisition of DIF Capital Partners, a leading midmarket infrastructure manager. This strategic acquisition provides CVC with a leading infrastructure

CVC Advisers Jersey has filed with the SEC as an exempt reporting adviser. Form ADV 2A | Page 68 of 80

platform, directly adjacent and complementary to its existing private equity, secondary and credit strategies. DIF Capital Partners, which was rebranded to “CVC DIF” in July 2024, is now the infrastructure business line of CVC. CVC Marathon As of July 1, 2026, all voting interests in CVC Marathon were acquired by CVC Capital Partners plc and, as a result, CVC Marathon is under common control with CVC Credit, CVC Capital, CVC Secondaries, and CVC DIF. This strategic acquisition extends CVC’s credit investing capabilities, complementing its established credit platform. While CVC Marathon is under common control with CVC Credit, CVC Capital, CVC Secondaries, and CVC DIF, the senior management team of CVC Marathon exercises independent authority over CVC Marathon’s day-to-day operations and investment activities without involvement from the other investment advisory entities within CVC. To mitigate conflicts of interest resulting from common ownership and overlapping investment strategies, in addition to the processes discussed below, policies and procedures have been adopted that establish information barriers between CVC Marathon and the other investment advisory entities within CVC that prevent the sharing of certain information between personnel of CVC Marathon and personnel of the other investment advisory entities within CVC. Managing Conflicts of Interest With respect to actual and potential conflicts of interest, CVC Credit’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using CVC Credit’s best judgment, but in its sole discretion. In resolving conflicts, CVC Credit considers various factors, including the interests of the applicable Clients with respect to the immediate issue and/or with respect to their longer-term courses of dealing. When conflicts arise, CVC Credit will seek to mitigate, but will not always be able to eliminate, conflicts of interest. There can be no assurance that a conflict will necessarily be resolved in a particular Client’s favor. Material conflicts that cannot be eliminated will be disclosed to all affected Clients. CVC Credit’s Conflicts Committee In the ordinary course of business, CVC Credit may engage in activities, investments, transactions, or business that give rise to potential conflicts of interest. Accordingly, CVC Credit has adopted a Conflicts Mitigation Policy (the “Conflicts Policy”), designed to help CVC Credit identify and mitigate any potential conflicts of interest which may arise from investment or other activities. CVC Credit has also established a CVC Credit Conflicts Committee (“Conflicts Committee”) comprised of the Firm’s Senior Management, and also includes the Head of Legal and Chief Compliance Officer (“CCO”). The Conflicts Committee is responsible for the review of any new potential and existing material conflicts of interest that may arise as part of the Firm’s ordinary course of business and meets periodically. The Conflicts Committee is also responsible for the review and approval of conflicts mitigating policies and procedures as well as material changes to conflicts disclosure. The below list is a comprehensive but not exhaustive list of conflicts that CVC Credit has encountered or may encounter in the future. Although CVC Credit has adopted policies and procedures designed to mitigate any conflicts or potential conflicts of interest. There can be no assurance that CVC Credit will resolve any conflict in a manner that is favorable to all Clients or to any particular Client. Investments in CVC Private Equity Portfolio Companies by CVC Credit Clients A CVC Private Equity Portfolio Company is a company in which a CVC Capital Partners Fund holds more than 50% share capital or has board majority. Any decision to purchase a primary credit investment or the initial purchase of a secondary credit investment in a CVC Private Equity Portfolio Company must be reviewed and approved by the relevant CVC Credit Investment Committee, and at minimum, a notification to the Conflicts Committee should be made. Subject to certain thresholds, approval by a majority of the Conflicts Committee must also be provided. Material Corporate Actions (i.e. amendments, deleveraging, covenant waivers, or any restructuring) of a CVC Private Equity Portfolio Company will be reviewed by the relevant Investment Committee and Chief Compliance Officer to determine whether there is a potential conflict of interest, and where Form ADV 2A | Page 69 of 80

applicable will be reviewed by the Conflicts Committee. Additionally, CVC Credit Clients may in certain circumstances be provided preferential opportunities to provide financing to portfolio companies of the private equity funds managed by CVC Capital before other sources of financing are considered. Where CVC Credit Clients provide financing to portfolio companies of the private equity funds managed by CVC Capital, the CVC Credit Clients will typically provide financing on arm’s length terms no more or less favorable than the terms on which other similarly situated lenders participate. Investments in Affiliated Entities by CVC Credit Clients CVC Credit will also cause certain CVC Credit Clients to invest in CLOs and securitization vehicles managed by CVC Credit or one of its affiliates. These investments introduce potential conflicts of interest because they may cause a CVC Credit Client to bear more expenses than it would if it had conducted such activities directly. Additionally, CVC will be paid through these CLOs with respect to the Client’s capital invested therein in addition to the fees, expenses and costs paid by the Client, which will result in the payment of two layers of fees to CVC Credit and/or its affiliates. These investments also benefit CVC Credit and/or its affiliates by providing such CLOs and securitization vehicles a larger, more stable capital base. This arrangement may incentivize CVC Credit to invest more of the Client’s capital into CLOs that are managed by CVC than would otherwise be the case. Additionally, the indemnification or other contractual provisions between CVC Credit and any such CLO and securitization vehicle may be more favorable to CVC Credit than the indemnification provisions applicable to the investing Client. CVC Credit will also at times acquire material non-public information regarding CLOs and securitization vehicles managed by CVC Credit or one of its affiliates, and may acquire material non-public information about a material portion of the investments held by a CLO or securitization vehicle managed by CVC Credit or one of its affiliates, which may limit CVC Credit’s ability to buy or sell interests in these vehicles, and this in turn may limit the investment opportunities or exit strategies available to a Client. CVC Credit Restricted Lists Private Credit is generally subject to a restricted list that includes restricted issuers of Liquid Credit and may be subject to restrictions applicable to CVC Capital Partners. Consequently, Private Credit may not be able to buy or sell a particular security or other instrument on behalf of its Clients because one or more personnel or investment teams of Liquid Credit or CVC Capital Partners possesses confidential and/or material, non-public information concerning the issuer or the market for the issuer’s securities or other instruments, and vice versa. Similarly, in such circumstances, Private Credit may not be able to dispose of a security or other instrument owned by a Client, even in a declining market, until the information becomes publicly available or immaterial and the trading in the issuer’s securities or instruments is no longer restricted. Separation Among Liquid Credit, Private Credit, CVC Secondary Partners, CVC Capital Partners, CVC Marathon and CVC DIF Private Credit, Liquid Credit, CVC Secondary Partners, CVC Capital Partners, CVC Marathon and CVC DIF, on behalf of their respective advisory clients, may make direct or indirect investments in the same or different parts of the capital structure of the same company, in which case certain conflicts of interest, or the appearance of conflicts of interest, may arise. Such conflicts (or appearances thereof) are mitigated by the CVC Credit, CVC Secondary Partners, CVC Capital Partners, CVC Marathon and CVC DIF governance structures, and by information barrier and conflict mitigation policies designed to ensure that the divisions each engage in independent decision-making. For example, CVC Liquid Credit, CVC Private Credit, CVC Secondary Partners, CVC Capital Partners, CVC Marathon and CVC DIF generally maintain separate investment committees and operating boards, although individuals may from time to time be management persons and/or members of an investment committee of multiple firms (“Dual Officers”). Our policies seek to identify and mitigate potential conflicts arising from these roles by requiring the recusal of Dual Officers from investment decisions regarding positions that introduce potential conflicts with positions held by clients of the other firm. Additionally, CVC’s information barrier policies are designed to ensure that Dual Officers do not transmit nonpublic information among CVC Secondary Partners, CVC Credit, CVC Capital Partners, CVC Marathon and CVC DIF, or among divisions thereof, without appropriate controls.

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Information Barrier As discussed in Item 8, CVC maintains information barriers and has adopted relevant policies and procedures for the proper handling of issuer-specific confidential information to prevent violation of laws and regulations prohibiting the misuse of such information and to avoid situations which might create the appearance of such misuse. The purpose of these information barriers is, among other things, to isolate confidential, material, non-public information held by Private Credit, CVC Secondary Partners, CVC Capital Partners and CVC DIF from Liquid Credit, such that the investment activities of Liquid Credit are not restricted because Private Credit, CVC Secondary Partners, CVC Capital Partners and/or CVC DIF may have material, non-public information that would be imputed to Liquid Credit in the absence of an information barrier. Subject to certain controls, the information barrier procedures permit interactions among the personnel of each of Liquid Credit, Private Credit, CVC Secondary Partners, CVC Capital Partners and CVC DIF, and establish appropriate procedural protections and compliance oversight of permitted communications. CVC also presently maintains an information barrier to control the communication of material, non-public information and certain other information held by CVC Marathon on the one hand and the rest of CVC on the other. CVC’s compliance teams are responsible for monitoring the information barriers established by CVC, administering the information sharing policies and procedures, and overseeing potential conflicts of interest. CVC Insurance Solutions CVC operates (or intends to operate) a business segment (whether by a current CVC entity or a new CVC entity to be established) with capabilities to provide investment advisory services or portfolio management services to insurers (each such insurer being an “Insurance Solutions Client”, and together “Insurance Solutions Clients”), including, among other services, asset allocation, analytics, asset and liability management, hedging, asset diligence, and merger and acquisition advice (“Insurance Solutions Services”). Certain Insurance Solutions Clients are, or may in the future be, owned, directly or indirectly, in whole or in part (including pursuant to a joint-venture arrangement), by CVC, a CVC Capital Fund, or other investment funds, vehicles, accounts, products and/or other similar arrangements sponsored, advised, and/or managed by CVC or its affiliates, whether currently in existence or subsequently established (in each case, including any related successor funds, alternative vehicles, supplemental capital vehicles, surge funds, over-flow funds, co-investment vehicles and other entities formed in connection with CVC or its affiliates side-by-side or additional general partner investments with respect thereto). Subject to the terms of the governing documents of a Fund, the provision of Insurance Solutions Services to Insurance Solutions Clients that are portfolio companies of a Fund, or that (directly or indirectly) invest in or otherwise have dealings with portfolio companies or that may be competitors to portfolio companies of a Fund, will not require the approval of investors in such Fund or a Fund’s advisory board. Such arrangements may give rise to conflicts of interest and there can be no assurance they will be resolved favourably for investors in a Fund. CVC and any CVC entity providing such Insurance Solutions Services may receive a fee or other compensation for providing Insurance Solutions Services (including from Insurance Solutions Clients that are portfolio companies of a Fund and/or participating third-party investors), and subject to the terms of the governing documents of the relevant Fund any such fees and compensation may not be offset against or reduce expenses of such Fund, management fees of such Fund or otherwise be shared with the Fund or investors in the Fund. As a result of the prospect of earning such fees and compensation, and CVC’s potential ownership of and/or strategic relationship with certain Insurance Solutions Clients, CVC may be incentivised to cause a Fund to participate in and pursue more insurance-related transactions. Further, if such fees and compensation are calculated by reference to the performance of investments recommended to the Insurance Solutions Client by CVC, this may create an incentive to recommend investments to Insurance Solutions Clients, including Insurance Solutions Clients that are portfolio companies of a Fund, that are more speculative and should such investments result in a negative return for an Insurance Solutions Client that is a portfolio company of a Fund, this may indirectly negatively impact such Fund. In addition thereto, Insurance Solutions Clients may be advised by CVC, either pursuant to a formal advisory arrangement or in connection with the marketing of a Fund, to invest in Funds, and the existence of fees payable to CVC or its affiliates for managing or advising such Funds may create incentives for CVC to recommend investments in Funds. As a result of the direct or indirect ownership of Insurance Solutions Clients by CVC (whether in whole or in part, or pursuant to any jointventure arrangement) or Insurance Solutions Clients being (directly or indirectly) advised by CVC Form ADV 2A | Page 71 of 80

(including pursuant to a contractual arrangement or as a result of their participation in a Fund) there may be circumstances in which there is an incentive for CVC to pursue the interests of such Insurance Solutions Clients in a manner, or to an extent, that is detrimental to a Fund or portfolio companies of a Fund. There may be circumstances in which CVC, via its interest in the Insurance Solutions Clients and a Fund, will be participating in transactions through a Fund as well as in a co-invest capacity in certain, but not all, of a Fund’s investments, which could give rise to conflicts of interest based on the selection methodology employed in connection with such deal by deal participation. In order to seek to mitigate any potential conflicts of interest with respect to transactions between CVC and Insurance Solutions Clients that are portfolio companies of a Fund, or in relation to Insurance Solutions Services provided to Insurance Solutions Clients that are portfolio companies of a Fund, CVC reserves the right, in its sole discretion, to (among other measures) involve independent members of the board of such Insurance Solutions Clients or a third party stakeholder to negotiate price and terms on behalf of the Insurance Solutions Clients in any transaction for services with CVC or any transaction involving an Insurance Solutions Client (including an Insurance Solutions Clients that are portfolio companies of a Fund) investing in a Fund. Insurance Solutions Clients may have larger investment mandates than other CVC-advised clients and funds, which may result in more concentrated positions or control positions in respect of an investment which a Fund or other co-investors are also participating, and this may (individually or in aggregate) create a conflict of interest between a Fund, on the one hand, and such Insurance Solutions Clients, on the other hand (including as a result of the degree to which they exercise control over such investment and/or certain requirements that they impose on CVC in relation to the management of the relevant investment). Mandates from Insurance Solutions Clients may include non-discretionary or partially non-discretionary arrangements, under which CVC's ability to make, modify, manage or exit investments on behalf of the Insurance Solutions Client is subject to the prior approval, direction or instruction of the Insurance Solutions Client (or its board, investment committee or other governing body). As a result, CVC may be unable to act as promptly, or in the same manner, as it would in respect of a discretionary mandate, which could adversely affect investment performance, limit CVC's ability to respond to changing market conditions in a timely manner, and result in investment decisions or portfolio positioning that differs materially from those adopted or which would otherwise be adopted for CVC's other clients, funds and accounts. Non-discretionary mandates may also give rise to situations in which CVC's investment recommendations are not followed, or are followed only in part or with delay, by the Insurance Solutions Client, which could require CVC to take actions which it would otherwise not take, and may affect the performance of the relevant mandate and could create divergence in outcomes as between the Insurance Solutions Client and other CVC-advised clients, funds or accounts pursuing similar strategies. Insurance Solutions Clients are typically subject to a greater degree of regulatory oversight and more stringent regulatory requirements than other CVC-advised clients, including, without limitation, requirements relating to solvency and capital adequacy, asset-liability matching, investment concentration limits, liquidity maintenance and prudential reporting. These heightened regulatory requirements may constrain the investment strategies that can be pursued on behalf of Insurance Solutions Clients, limit the types and proportions of assets in which they may invest, and require CVC to take actions (or refrain from taking actions) in respect of Insurance Solutions Client mandates that differ materially from those that CVC would take in respect of mandates for its other clients or funds. Insurance Solutions Clients may also invest alongside a Fund or its portfolio companies or in other transactions related (directly or indirectly) to a Fund or its portfolio companies, including where Insurance Solutions Clients may have the ability to otherwise manage or direct the management of their investment in a portfolio company as a result of their non-discretionary arrangements. Where such Insurance Solutions Clients co-invest with a Fund or portfolio companies then the presence of such characteristics of Insurance Solutions Clients as set out above, and also the relationship between CVC and such Insurance Solutions Clients (which is expected to include fees and compensation payable to CVC by such Insurance Solutions Clients which may incentivise a management approach that is not aligned with a Fund), may result in conflicts of interest of how investments are managed. Further, Insurance Solutions Clients may have the ability, subject to the terms of the governing documents of the relevant Fund and applicable law, to not invest or divest at the same time or on the same terms as such Fund or the applicable portfolio companies.

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In addition, certain Insurance Solutions Clients may be strategic investors in a Fund and such characteristics and/or relationship (including the payments of fees and compensation) as set out above may create an incentive for a Fund to be managed in a manner more favorable to Insurance Solutions Clients than would otherwise be the case without the participation of such Insurance Solutions Clients as investors in a Fund. This may include where the fees and compensation payable to CVC in connection therewith (and/or any associated minimum return, risk-return or other requirements) may incentivise deployment in eligible opportunities more strongly than absolute returns (including as a result of capital ratio treatment, tax treatment or other considerations) which may cause CVC to be incentivised to recommend investments for a Fund ) which may be less high yielding or profitable than investments which a Fund would make in the absence of such Insurance Solutions Clients as investors in a Fund. Insurance Solutions Services may include advising on investment management arrangements that involve investments by Insurance Solutions Clients across a variety of asset classes (including investments that may otherwise be appropriate for a Fund). Such arrangements may reduce the allocation of investments to a Fund, and CVC may be incentivised to allocate investments away from a Fund to such Insurance Solutions Clients to the extent the economic arrangements related thereto, or the scale and/or breadth of those Insurance Solutions Client relationships, are more favourable to CVC relative to the terms of a Fund and could result in materially less availability of investment opportunities for a Fund and third-party co-investors and CVC could face conflicts in determining allocation among clients and products. Insurance Solutions Clients may engage in a variety of activities, including participating in transactions related to a Fund and/or its portfolio companies (e.g., as originators, co-originators, counterparties, acting as a warehouse or other source of financing, or otherwise). Transactions in which Insurance Solutions Clients participate may include, without limitation, investments in debt (and, in certain cases, equity or equity-like instruments acquired in connection with such debt) or other securities issued by portfolio companies or other forms of financing to portfolio companies (or intermediate holding vehicles established by a Fund or such portfolio companies). As a result, Insurance Solutions Clients may invest in portfolio companies of a Fund at a different part of the capital stack as a Fund and this may give rise to specific conflicts of interests, in particular due to the relatively increased important to Insurance Solutions Clients of the capital ratio treatment and regulatory compliance relative to certain other types of investors (as described above). Subject to the terms of the governing documents of the relevant Fund and applicable law, transactions between a Fund or its portfolio companies and Insurance Solutions Clients will not require the approval of investors in a Fund or the Fund’s advisory board. This may include where Insurance Solutions Clients acquire investments directly or indirectly from, and sell investments to, a Fund or its portfolio companies. In circumstances where CVC determines in good faith that any conflict of interest is mitigated in whole or in part through various measures that CVC, or the General Partner of the relevant Fund implements, such General Partner is not generally, subject to the governing documents of the relevant Fund and applicable law, required to seek approval of investors in a Fund or the Fund’s Advisory Board. Insurance Solutions Clients could also participate in transactions involving Funds and/or their portfolio companies, provide insurance to such funds, their subsidiaries and related vehicles and/or CVC. CVC may engage Insurance Solutions Clients (including those that are owned, in whole or in part by a CVC entity, or establish pursuant to a joint venture with CVC) to provide certain operational, administrative, ceding, fronting, and other insurance related services for a fee or commission payable by a Fund or its portfolio companies. Such fees or commissions may benefit the Insurance Solutions Clients and, directly or indirectly, CVC, and the fees and commissions attributable to such services, subject to the governing documents of the relevant Fund, will not be offset against or reduce expenses of such Fund, the management fees in respect of such Fund, or otherwise be shared with the Fund or investors in a Fund. Investments and Other Activities in the Insurance Sector Investments in Insurance Solutions Clients, in Insurance Solutions Clients owned, directly or indirectly, in whole or in part, by CVC or one or more CVC Funds and in insurance sidecars or similar vehicles or structures established in connection with Insurance Solutions Clients (“Insurance Sidecars”), involve significant risks and could result in the loss of all or a substantial portion of an investment. Insurance Form ADV 2A | Page 73 of 80

businesses are subject to material underwriting and reserving risk, including the risk that loss reserves prove inadequate. Results can be volatile and materially affected by catastrophes and other large-loss events (including weather- and climate-related events), aggregation/correlation of risks, changes in loss trends (including “social inflation”), and reliance on complex actuarial assumptions and models. Insurance businesses are also subject to extensive regulation and capital requirements, and the value of investments in Insurance Solutions Clients can be materially affected by changes in applicable laws and regulations. In addition, the limited pool of qualified buyers of Insurance Solutions Clients could materially impact the ability of the relevant CVC investment funds (or other products) to exit their investments and/or may materially impact their performance. Insurance Sidecars may acquire portfolios of underwritten risks that are less diversified than traditional, multi-line insurance platforms, and accordingly investment funds (or other products) managed or advised by CVC which invest in Insurance Sidecars may be subject to significant risk of losses should the relevant insured risks occur. Cross Trades and Principal Transactions From time to time, CVC Credit may execute or recommend transactions in which one Client sells securities or other instruments to another Client without the involvement of a broker (a “cross trade”). CVC Credit may also recommend transactions in which one Client that is deemed to be more than 25% owned by CVC Credit or certain affiliated entities (a “principal account”) buys securities or other instruments from, or sells securities or other instruments to, another Client without the involvement of a broker (a “principal transaction”). Cross trades present potential conflicts of interest. For example, one Client could be advantaged to the detriment of another Client in the event that the securities being exchanged are not priced in a manner that reflects their fair value (i.e., if the trade was not executed in the open market). Additionally, there is a potential conflict of interest when a cross trade involves a Client account on one side of the transaction and a principal account, or an account in which CVC Credit receives a higher management fee on the other side of the transaction. To address these potential conflicts, CVC Credit maintains cross trade and principal transaction policies and procedures that are compliant with the requirements of Section 206(3) of the Advisers Act. Any cross trade or principal transaction will be effected in accordance with CVC Credit’s cross trade and principal transaction policies and procedures, which require compliance approval before the transaction may proceed and are designed to ensure that the transaction is in the best interest of each involved Client, is consistent with CVC Credit’s duty to seek best execution, and is executed at a fair price as determined in accordance with the pricing protocols specified in the abovementioned policies and procedures. CVC Credit will maintain documentation of the rationale for each transaction and the determination of pricing. In connection with principal transactions, CVC Credit will also disclose to the relevant Client(s) that the proposed transaction involves a principal account and obtain the necessary consent from the Client or from an independent party authorized by the Client to provide such consent on its behalf prior to the transaction being affected. Capital Stacking CVC Credit Clients may invest in different loan investments or securities issued by the same company. In some circumstances, the interests of Clients that invest in a company may not be aligned with the interests of other Clients that invest in a different loan investment or security issued by the same company, which could create actual or potential conflicts of interest or the appearance of such conflicts. In that regard, certain actions may be taken by CVC Credit on behalf of a Client that are adverse to the interests of other Clients. The interests of Clients investing in different parts of the capital structure of a company are particularly likely to conflict in the case of financial distress of the company, such as through enforcement of credit rights or bankruptcy proceedings. This may result in a loss or substantial dilution of one Client’s investment, while another Client receives a full or partial recovery on its investment. While the possibility of conflicts in such circumstances can never be fully mitigated, prior to making any new investment in a company on behalf of a Client, CVC Credit will consider whether the interests of other Clients invested in the capital structure of the company may impair its ability to act in the best interest of the Client. When CVC Credit is required to take action with respect to a security or loan investment held by a Client, it is typically CVC Credit’s policy to act in the best interest of the holder

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of the investment with respect to which action is being taken, even though such actions may be to the detriment of other Clients invested in the company’s capital structure. Proxy Voting When a corporate action involves a CVC Capital Portfolio Company, the CCO, or their designee, in consultation with the relevant Portfolio Manager determines whether a potential conflict of interest is present. If it is determined that a potential conflict of interest is present, notice of the proxy and the potential conflict is provided to the Conflicts Committee, which may assist in determining how the proxy should be voted. In all cases where a Portfolio Company Proxy is (a) with respect to a debt holding that represents more than 10% of the relevant voting class across all Clients, or (b) reasonably likely, in the view of the Portfolio Manager, to result in the Clients’ positions experiencing a loss of invested capital on the relevant security, approval of the Conflicts Committee is required. CVC Credit also considers whether a proxy or corporate action which does not involve a CVC Capital Portfolio Company raises any conflicts of interest prior to voting the proxy. For equity proxies, CVC Credit’s CCO, or a member of CVC Credit’s compliance team, reviews each proxy with the relevant Portfolio Manager(s) as part of the conflicts assessment prior to voting, and refers any proxies raising potential conflicts of interest to the Conflicts Committee, which reviews and potentially may recommend as to how the proxy should be voted. For corporate actions, the Portfolio Manager, together with CVC Credit’s operations team assesses whether an action presents potential conflicts and notifies CVC Credit’s compliance team of any potential concerns. CVC Credit’s compliance team refers any proxies determined to raise potential conflicts of interest to the Conflicts Committee, which reviews and potentially recommends how CVC Credit should act on the corporate action. Investment Allocation In an effort to mitigate conflicts of interest related to side-by-side management of Client accounts with different fee structures, CVC Credit has established an investment allocation policy, which applies to all Clients and which seeks to allocate investments among Clients in a fair and equitable manner over time. By this method, CVC Credit undertakes to ensure that all Clients receive appropriate and individualized treatment based on the needs of a given Client at a given time. This policy is designed to ensure that, in allocating investment opportunities, no Client may or will be favored over another based on the Client’s identity or affiliation, account performance, fee structure, or similar attributes not related to investment factors or restrictions. Each of CVC Credit’s portfolio managers has responsibility for designated Clients and is responsible for determining that Client’s appropriate participation in the allocation by considering any relevant investment criteria. Such criteria include, without limitation, investment objectives, available capital, the timing of capital inflows and outflows, applicable concentration limits, portfolio diversification, availability of alternative investments and the overall risk profile of a Client. Board Membership In furtherance of CVC Credit’s advisory business, CVC Credit personnel may serve on the boards of directors or on creditor committees of companies whose instruments are held by certain Clients. Serving in this capacity may give rise to conflicts to the extent that such personnel’s fiduciary duties to a company as a director may conflict with the interests of a Client. CVC Credit personnel are required to notify Compliance before accepting any such position, as discussed in Item 11 below. Additionally, CVC Credit evaluates any potential conflicts of interest that may arise in connection with such board service on an ongoing basis and in consultation with Compliance as appropriate. Investment in CVC Capital Funds As discussed above, CVC Funding, a broker-dealer and wholly-owned subsidiary of CVC Credit, acts as distributor and/or placement agent for private funds managed by CVC Credit, CVC Capital, and CVC Secondary Partners. From time to time, underlying investors in Clients of CVC Credit may be solicited to invest in private funds managed by CVC Capital or CVC Secondary Partners, and clients of CVC Capital and CVC Secondary Partners may be solicited to invest in private funds managed by CVC Credit. CVC Funding receives compensation from CVC Credit in connection with such solicitation activities. In addition, from time to time, CVC Credit may pay compensation under a shared services Form ADV 2A | Page 75 of 80

agreement or through other means to personnel of CVC Capital to provide certain investor relations services to Clients of CVC Credit that are invested in CVC Capital products, and to investment personnel of CVC Capital for introducing or facilitating the completion of deals. As noted above, CVC maintains information barriers to prevent inadvertent dissemination of material, non-public information across the firm, except as expressly provided for in the information barrier procedures and subject to appropriate procedural oversight. To help identify unknown conflicts of interest, CVC Credit personnel are encouraged to discuss any perceived risks or concerns about CVC Credit’s business practices with their direct supervisor or members of CVC Credit’s Legal and Compliance teams.

11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CVC Credit is subject to CVC’s Global Code of Ethics (the “Code”). The Code expresses CVC’s operating principles of integrity, honesty and the fiduciary duties owed to Clients. The Code sets forth a standard of business conduct that is expected of all CVC directors, officers, partners and employees (“CVC Persons”). CVC Credit has also adopted policies and procedures (“Personal Securities Transaction Policy”) that CVC Persons must follow to prevent activities that may lead to or give the appearance of conflicts of interest, insider trading, and other forms of unethical behavior. All CVC Credit personnel are CVC Persons subject to the Code and the Personal Securities Transaction Policy. The Personal Securities Transaction Policy requires CVC Persons to report accounts in which they, or their immediate family members or other family members living in their household, have a beneficial interest within ten (10) days of joining CVC Credit or within ten (10) days of opening the account if already an employee of CVC Credit. On a quarterly basis, CVC persons must also report securities transactions in accounts in which they, or their immediate family members or other family members living in their household, have a beneficial interest. CVC Persons must also report any newly opened accounts on an ongoing basis. Additionally, CVC Persons must certify annually in writing to their holdings and existing accounts, as well as their compliance with the terms of the Code, the Personal Securities Transaction Policy, and other key policies and procedures. The Code also requires CVC Persons to receive pre-clearance before making certain purchases or sales (investments and redemptions), which includes, but is not limited to securities, IPOs and private investments. CVC Persons are prohibited from executing any personal securities transactions of any kind in any securities on CVC Credit’s restricted list or issuers on which CVC Credit is designated as syndicate level private. CVC Credit’s restricted list contains the names of companies for which CVC Credit has material non-public information, or for which CVC Credit has otherwise determined must be added to the restricted list. The Code and Personal Securities Transaction Policy additionally require CVC Credit’s compliance team to regularly review the trading activity of personnel and to address any issues noted during the review, including determining, with senior personnel, whether to impose sanctions for violations of the Code and Personal Securities Transaction Policy and the extent of imposed sanctions. Under the Code, CVC Persons may not, outside of their activities performed on behalf of CVC Credit, serve as a director of a company (or in a similar position) or as a member of a company’s creditors committee, unless the employee has received approval from CVC Credit’s Chief Compliance Officer. Authorization will be based on a determination that the outside board or committee service would not conflict with the interest of any Client account. In making this assessment, the CCO will typically review not only for direct Client conflicts, but also indirect conflicts such as the possibility that board service would unduly restrict CVC Credit from making investments on behalf of Clients. CVC Credit personnel are also prohibited under the Code from using their position with CVC Credit to obtain an item of value from any person or company that does business with CVC Credit. The benefits of the item of value must be designed to enhance the quality of the service to the client and not impair compliance with CVC Credit’s duty to act honestly, fairly and professionally in accordance with the best interests of clients. CVC Credit personnel are subject to limits on the giving and receipt of gifts, and unsolicited business entertainment is permitted if: a) it is not so frequent or of such high value as to raise a question of impropriety, and b) the person providing the entertainment is present at the event. Form ADV 2A | Page 76 of 80

Gifts or entertainment in excess of established thresholds must be approved by CVC Credit’s CCO, as well as any gifts or entertainment provided to public officials, irrespective of value. A copy of the Code is available to any Client or investor, or potential Client or investor on request to CVC Credit’s CCO.

12. Brokerage Practices CVC Credit is generally granted discretionary authority in its investment advisory contracts with Clients to select broker-dealers in connection with all portfolio transactions. With respect to CLO Clients, discretionary authority to purchase or sell securities or loan investments in Client accounts may be limited by the terms of the applicable indentures and other governing agreements which may impose quality, liquidity, concentration, diversification and other requirements. CVC Credit seeks to trade on behalf of Clients in a manner that is fair and equitable to all Clients and has established a Best Execution Policy that is designed to ensure that CVC Credit exercises diligence and care throughout the trading process. In seeking best execution, the determining factor is not always the lowest possible per security price or commission or fee but whether, in CVC Credit’s view, the transaction represents the best overall execution for CVC Credit’s Clients. In placing orders, CVC Credit seeks to obtain best net results for portfolio transactions that are reasonably available, whilst taking into account all relevant factors, including quality of execution, speed of execution, likelihood of execution and/or settlement, size, complexity and other characteristics of the order, and other execution factors identified in CVC Credit’s Best Execution Policy, all in light of CVC Credit’s overall responsibilities to each Client.

In no instance does CVC Credit seek to obtain research or other soft dollar benefits in exchange for directing Client brokerage to the broker or bank producing such materials. CVC Credit may, from time to time, receive unsolicited market and industry research made generally available by broker-dealers and agent banks for loan syndications to their counterparties.

CVC Credit and its related persons do not receive Client referrals from broker-dealers or third parties that provide order execution on behalf of Client accounts.

CVC Credit does not routinely recommend, request or require Clients to direct CVC Credit to execute transactions through specified broker-dealers.

CVC Credit will provide Clients with its Best Execution Policy upon request. To comply with MiFID II and related regulations, CVC Credit UK in certain instances will also obtain client consent to the Best Execution Policy prior to providing advisory services. In an effort to minimize costs and obtain best execution for Client transactions in marketable securities, CVC Credit may consider it appropriate to aggregate orders for Clients, subject to CVC Credit’s obligations to obtain best execution for Clients and otherwise treat those Client in a fair and equitable manner. Allocations of aggregated Client orders are consistent with CVC Credit’s allocation policies and procedures described above in Item 6 and Item 10. Although CVC Credit personnel endeavour to take the utmost care in implementing investment decisions on behalf of each Client, trade errors do occur and could have a material adverse impact on the performance of any or all Clients. CVC Credit endeavours to detect trade errors quickly and correct and/or mitigate them in an expeditious manner as determined under CVC Credit’s policies in effect from time to time. Not all trade errors are compensable trade errors, but trade errors may be compensable if CVC Credit determines that its actions leading to the trade error did not meet the applicable standard of care for managing the assets of the Client, and the Client suffered a net loss as a result. To the extent an error is caused by a counterparty, such as a broker, CVC Credit will take commercially reasonable steps to attempt to recover any loss associated with such error from such counterparty, but generally will not undertake litigation on behalf of clients unless otherwise agreed. Given the large volume of transactions executed by CVC Credit, investors should assume that trading errors (and similar errors) will occur and that CVC Credit’s investment vehicles may be responsible for any resulting costs or losses unless such errors are due to actions or omissions by CVC Credit for which CVC Credit would be responsible and would not be entitled to indemnification pursuant to the relevant Client Agreements. Where a single error or a series of related errors result in multiple transactions in a client account, gains and losses on these transactions may be netted to determine the net impact of a trade error. Calculating Form ADV 2A | Page 77 of 80

the exact amount owed to the Client involves discretion and CVC Credit will seek to calculate the amount owed in good faith. CVC Credit has adopted a formal trade error policy covering its practices. On a semi-annual basis, CVC Credit’s Brokerage Committee meets to discuss its best execution practices, any identified trade errors or trading issues, review counterparties, review cross trades, and evaluate execution quality as applicable.

13. Review of Accounts CVC Credit has implemented an internal structure which allocates responsibility for the ongoing oversight and review of its Client accounts to the respective CVC Credit investment committees and appropriate Portfolio Managers. CVC Credit reviews CLOs on at least a quarterly basis, focusing primarily on credit analysis of each issuer’s financial performance, a review of each issuer’s capital structure and a review of each issuer’s industry prospects. Managed Accounts are reviewed, no less frequently than quarterly, with the Client by the Portfolio Manager and the Portfolio Manager responsible for the relevant portfolio. Managed Funds are reviewed on an ongoing basis with certain reviews performed daily, weekly and monthly. Such reviews may take into account the Managed Funds investment position exposure, pricing and risk analysis. These reviews are conducted by the Portfolio Manager. On a daily or weekly basis, CVC Credit also reviews certain aspects of each investment including, but not limited to: the operational performance of each investment, including an evaluation of the macroeconomic, credit specific and event-driven factors for each investment; price performance; any related news items related to the investment; and any correspondence from the issuer/management and/or the institution that acts as the administrative agent for the issuer’s financing. These reviews are conducted by the investment and operations teams. The nature and frequency of regular reports provided to Managed Funds and Managed Accounts depends on the terms of the relevant governing documents and any regulatory requirements of jurisdictions where the Managed Funds and Managed Accounts are organized. CVC Credit will typically provide the reports described below and may provide additional types of reports (such as proxy voting summary reports and brokerage reports) as may be agreed upon with Clients. CLO investors receive a monthly trustee report. The Managed Accounts receive reports from CVC Credit Partners and/or the applicable custodian on a daily, monthly and quarterly basis. The custodian for each Managed Account makes available a cash flow report to the Managed Account on a daily basis. This report shows all transactions (debits and credits) affecting the account. CVC Credit Partners also provides the Managed Account with a monthly report summarizing account activity. CVC Credit Partners provides Managed Accounts with a quarterly report that summarizes market and economic activity together with return data and market prices. Investors in Managed Funds may receive a monthly or quarterly capital statement and one-page transparency discussing the performance and positioning of the Managed Fund. Investors in Managed Funds may also receive a quarterly letter summarizing the investments in the Managed Fund. Typically, investors in Managed Funds are provided with written quarterly unaudited financial reports and annual audited financial statements.

14. Client Referrals and Other Compensation CVC Credit does not receive any economic benefit from any party that is not a Client in connection with the provision of investment advice or other advisory services to CVC Credit Clients. CVC Credit Partners uses the services of placement agents to refer investors to Managed Funds for which CVC Credit Partners serves as the investment manager. Pursuant to the placement agent agreements between CVC Credit Partners and third-party placement agents, CVC Credit Partners generally compensates placement agents with a portion of the management fees charged to each Client referred to CVC Credit Partners by the placement agent. Compensation under these arrangements is determined by means of an asset-based fee and/or a fixed retainer fee payable periodically for a certain period of time. All fees associated with these agreements are payable by CVC Credit Partners.

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15. Custody Related persons of CVC Credit serve as general partners to the Managed Funds for which CVC Credit Partners provides investment advisory services. CVC Credit Partners is, therefore, deemed to have custody of Client funds and securities for such Managed Funds. To the extent required under applicable law, all funds and securities owned by Managed Funds are maintained by qualified custodians and are audited by an independent auditor. Investors are provided with a copy of the audit report within 120 days after the end of the Managed Fund’s fiscal year. In certain instances, CVC Credit or an administrator provides account statements to the Client or limited partners of the Managed Fund. Clients, limited partners of Managed Funds, or the independent representatives of such limited partners, should compare account statements received from CVC Credit or an administrator with any account statements received from a qualified custodian.

16. Investment Discretion The applicable indentures for each of the CVC Credit CLOs place restrictions on CVC Credit’s ability to buy and sell loans and securities on behalf of the CVC Credit CLO. Pursuant to the terms of these indentures, CVC Credit has limited discretionary authority over such accounts. CLO indentures generally restrict CVC Credit from selling collateral debt securities unless such loans or securities have experienced specified credit deterioration, ratings downgrades, or events of default. CVC Credit is also permitted by the terms of each CLO indenture to trade a portion of the CLO account on a discretionary basis. Client Agreements for Managed Accounts and Managed Funds set forth the general criteria for the types of loans and securities to be purchased and sold on behalf of the entity, subject to the restrictions as may be specified in such agreements. Further, certain investment management agreements for Managed Accounts may require that CVC Credit Partners provide notice to the Client prior to executing any transaction on behalf of the Client and provide the Client the opportunity to decline the proposed transaction. Notwithstanding the foregoing, CVC Credit Partners is generally granted discretionary investment authority on behalf of Managed Accounts and Managed Funds.

17. Voting Client Securities Although CVC Credit primarily provides investment advice with respect to loans and other debt investments that do not entitle Clients to vote on corporate matters, in certain instances Clients are entitled to vote in connection with amendments or waivers to their rights or in connection with other corporate actions. CVC Credit has adopted and implemented a proxy voting policy (“Proxy Policy”) and will vote all proxies and act on all corporate action notifications that it receives in accordance with such Proxy Policy, unless a Client has reserved such right. The Proxy Policy provides that, where CVC Credit is authorized to vote Client securities, the Firm will seek to vote or exercise rights in the best interest of its Clients, taking into account all relevant factors. In voting proxies and corporate actions, the Firm will act in a manner that it believes will (i) maximize the economic benefits to Clients and (ii) promote sound corporate governance by the issuer. CVC Credit’s Proxy Policy is designed to ensure that if a material conflict of interest is identified in connection with a particular proxy vote, that the vote is not improperly influenced by the conflict. Conflicts of interest will arise from time to time in relation to proxy voting requirements. CVC Credit shall monitor all proxies for any potential conflicts of interest. If a material conflict of interest arises, CVC Credit will determine what is in the best interests of the relevant CVC Credit Client and will seek to take appropriate steps to eliminate any such conflict, in accordance with the Proxy Policy. Existing Clients may obtain a copy of the proxy voting policy and information on how CVC Credit voted Client securities by written request to CVC Credit. CVC Credit generally does not provide proxy or corporate action recommendations to Clients who have not granted CVC Credit voting authority over their securities.

18. Financial Information

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CVC Credit does not require the payment of management fees or other compensation six months or more in advance. There exists no financial condition of which CVC Credit is currently aware that would impair its ability to meet contractual commitments to its Clients.

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