Alpine Associates Management Inc.: investment adviser

("AAS"), an affiliate of Alpine, has approximately 26 employees engaged in various services assisting Alpine in managing Alpine's clients. Mrs. Zoellner is the sole shareholder and director of AAS. Alpine manages the investment portfolios of the Alpine Funds and the accounts of its other clients. Alpine's primary investment strategy is merger arbitrage. Alpine also uses an equity trading strategy that is closely related to merger arbitrage. These investment strategies are described further in Item 8 below under "Methods of Analysis, Investment Strategies and Risk of Loss". Alpine is not limited to these strategies, and there are no material restrictions on the particular types of investing in which Alpine may engage, the strategies it may employ or the securities or instruments in which it may cause its clients to invest. Alpine is the sole investment manager of each of the Alpine Funds and the sole general partner of each of the seven domestic Alpine Funds and therefore has broad investment authority with respect to the management of their accounts. The Alpine Funds and the accounts Alpine manages for its other clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other. Certain clients may not participate in all parts of Alpine's investment strategies. Also, certain clients operate with lower levels of investment exposure in Alpine's strategies than the other clients, and one client operates with long market exposures in its equity trading strategy that are normally expected to be significantly greater than the exposures of the other clients. Since Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other, Alpine does not ordinarily tailor its advisory services to the individual needs of its clients or of investors in the Alpine Funds. For a client that is an individually managed account, Alpine may agree in the investment management agreement with the owner of such account to investment restrictions or guidelines with respect to the types or amounts of securities or other financial instruments that may be traded for such account. Alpine's general objective is to produce superior absolute returns with low volatility in all types of market environments. For one Alpine Fund, Alpine's objective is to produce superior absolute returns while experiencing less downside volatility than the stock market.

In general, Alpine seeks to produce stock market-like returns with substantially less risk and volatility over the long run than is historically associated with equity investments. Alpine works to reduce risk by seeking broad diversification, by devoting substantial ongoing efforts to quantifying the risk of its clients' investments, and by applying risk guidelines and prohibitions to both individual investments and portfolios. Investors and prospective investors in each Alpine Fund should refer to the confidential private placement memorandum, limited partnership agreement and/or other governing documents for such Alpine Fund (the "Governing Documents") for additional information on the investment objectives, risks and investment terms with respect to a particular Alpine Fund. The investment terms available to investors in the different Alpine Funds and Alpine's other clients vary in certain respects. There is no assurance that any of the investment objectives of Alpine's clients will be achieved. Alpine may enter into "side letters" or similar agreements with certain investors in the Alpine Funds granting the investor certain specific rights, benefits or privileges that are not made available to investors in the Alpine Funds generally. Alpine does not participate in any wrap fee programs. Alpine manages all client assets on a discretionary basis. As of January 31, 2026, the amount of assets in the Alpine Funds, the UCITS fund and the individually managed account managed by Alpine on a discretionary basis, determined based on their respective net asset values, was $1,189,528,093. As of January 31, 2026, Alpine provided discretionary investment advisory services to nine private investment funds, one UCITS fund and one individually managed account. Alpine may in the future provide advisory services, either on a discretionary or non-discretionary basis, to other funds or accounts.

In addition, the Alpine Funds (and, indirectly, the investors in the Alpine Funds) also pay Alpine an annual performance allocation or fee based on a percentage of the amount by which the net value of each investor's account as of the end of each calendar year exceeds the net value of the account as of the beginning of the year. The performance allocations or fees for the Alpine Funds may vary. The performance allocation or fee for each investor is subject to a high-water mark loss carryforward. For investors in certain of the Alpine Funds, the performance allocation or fee is also subject to the investor having obtained a threshold level of appreciation in its account for current and prior years.

The management fee is usually deducted directly from the assets of each Alpine Fund as such fee becomes payable, which is generally monthly in arrears. The performance allocation or fee is payable annually in arrears, or upon withdrawal of capital from an Alpine Fund. Upon termination of any client account, all management fees accrued as of the date of termination will be payable. Alpine charges its other clients that are not Alpine Funds fixed monthly management fees at annual rates based on a percentage of net assets under management, generally payable monthly in arrears. The management fees for such other clients vary. In addition, such other clients also pay Alpine an annual performance fee based on a percentage of the amount by which the net value of the client's account as of the end of each calendar year exceeds the net value of the account as of the beginning of the year. The performance fees for such other clients vary. The performance fee for each such client is subject to a high-water mark loss carryforward. Such fees are billed to such other clients as they become payable, which is generally monthly in arrears for the management fee and annually in arrears or upon withdrawal of capital for the performance fee. Upon termination of such a client account, all fees accrued as of the date of termination will be payable. In certain circumstances, the advisory fees payable to Alpine by clients (or, indirectly, by the investors in an Alpine Fund) may be negotiable. Investors and prospective investors in each Alpine Fund should refer to the Governing Documents of the applicable Alpine Fund for additional information on the advisory fees charged by Alpine. Deduction of Fees Alpine is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Alpine Funds at the times and in the amounts described above. For clients that are individually managed accounts, Alpine normally bills such clients for its advisory fees at the times and in the amounts described above. Other Fees and Expenses Alpine, and not the private funds or any of the other entities that Alpine acts as investment manager for (referred to as the “Clients”), is responsible for providing all office personnel, office space and office facilities required for the performance of its services to the Clients (including personnel and facilities provided by Alpine Services), and for paying expenses and other costs related thereto (including fees, expenses and other costs of research, data and pricing services). The Clients (and, indirectly, the investors in the Clients) are responsible for all costs and expenses incurred in connection with their investments, including (without limitation) brokerage commissions; clearing and settlement fees, expenses and costs; fees, interest and other costs in connection with margin accounts and other indebtedness; borrowing charges on securities sold short; custodial fees; bank service fees; fees, expenses and other costs of any outside appraisers, accountants, attorneys or other experts or consultants (including, but not limited to, business advisory, compliance or cyber security consultants and managed service solutions) engaged by the Clients or Alpine; any legal fees, expenses and other costs (including settlement costs) arising in connection with portfolio investments; and any other expenses and costs related to the

purchase, sale or holding of the Clients’ investments (including expenses related to transactions that fail to close). The Clients (and, indirectly, their investors) also pay all of their operating costs, including (without limitation) costs of communication with or meetings of partners and other investors; legal, accounting, auditing and administrative fees, expenses and other costs, including costs of portfolio management, accounting, risk management and other investment-related software and third-party platforms that assist back-office functions such as margin management, bank balance and accrual monitoring; fees and expenses relating to information technology hardware, software or other technology (including costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including reporting obligations), or otherwise manage the Clients and/or their investments, such as Bloomberg terminals, portfolio management systems, risk management systems, investor relations software and/or order management systems; withholding and transfer taxes; insurance costs; costs of preparing any required regulatory filings (including SEC Form PF and Schedules 13D and G, and AIFMD Annex IV); any legal fees, expenses and other costs (including settlement costs) arising in connection with any litigation by or against, or any regulatory investigation instituted against, the Clients or Alpine in connection with the affairs or operations of the Clients; fees, expenses and other costs of the Administrator; and any other expenses or costs related to operating the Clients. Alpine allocates expenses incurred on behalf of the Clients (including expenses related to investments among participating accounts, including some or all of the Clients), in proportion to their participation in the relevant investment, in proportion to their respective net asset values, or in any other manner determined by Alpine to be appropriate. Item 12 below under "Brokerage Practices" describes the factors Alpine considers in selecting or recommending broker-dealers and determining the reasonableness of their compensation. Timing of Payments Advisory fee payments are generally due monthly in arrears, or annually in arrears with respect to performance allocations or fees. Please refer to the Governing Documents of the Alpine Funds for additional information on the timing of advisory fee payments. Transaction-Based Compensation Neither Alpine nor its supervised persons will receive any compensation with respect to the purchase or sale of securities or other investment products by any client (including the Alpine Funds).

Performance-based compensation arrangements received by Alpine or by related persons of Alpine may create an incentive for Alpine to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Side-by-Side Management Situations may occur where Alpine is entitled to receive a higher percentage of the net profits of the account of one client or one investor in a client than the percentage that Alpine receives from another client or investor. In such situations, Alpine may have an incentive to favor, or to allocate certain riskier or more speculative investments to, the client that is subject to the higher percentage or that has investors that are subject to the higher percentage. However, as noted in Item 4 above under "Advisory Business", Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis. Alpine will, as a policy, allocate all investment opportunities among its clients in a manner that it considers fair and equitable to all clients, and no client will be improperly favored over any other client. In general, transactions will be executed, to the extent reasonably practicable, for all of Alpine's clients at substantially the same times and prices. Alpine may also cause particular clients to execute transactions on a stand alone basis in situations where a client's equity capital has increased or decreased and otherwise in circumstances deemed appropriate by Alpine. Among the factors that may be considered by Alpine in allocating trades among client accounts are: investment policies, guidelines or restrictions applicable to each specific client; tax considerations; cash availability; liquidity requirements for payment of redemptions or other purposes; risk tolerances; restrictions under ERISA or other applicable laws or regulations; available credit lines; counterparty arrangements; account size; and hedging objectives and activity.

Minimum Investment Requirements Alpine and its related persons require that each investor in each of the Alpine Funds be an "accredited investor" as defined in Regulation D under the Securities Act of 1933, as amended. In addition, each investor in an Alpine Fund operating under Section 3(c)(1) of the Investment Company Act is required to be a "qualified client" as defined in Rule 2053(d)(1) under the Advisers Act, and each investor in an Alpine Fund operating under Section 3(c)(7) of the Investment Company Act is required to be a "qualified purchaser" as defined in Section 2(a)(51) of the Investment Company Act. Minimum investment amounts in the Alpine Funds are determined from time to time by Alpine. Generally, Alpine will not advise an individually managed account unless it has a net asset value of at least $30,000,000.

Alpine also uses an equity trading strategy that is closely related to merger arbitrage. Merger arbitrage is the purchase of securities of target companies in merger and acquisition (M&A) transactions, such as mergers, cash tender offers, exchange offers and other similar combinations. In an M&A transaction, an acquiring company will seek to purchase a target company. To make this purchase, the acquiring company may offer to pay the shareholders of the target company for their shares, either indirectly in a merger or similar transaction in which the shareholders exchange their shares for the payment being offered by the acquiring company, or directly via a tender offer or exchange offer made by the acquiring company to the target company's shareholders. Alpine's clients acquire target company

securities after an M&A transaction has been announced or otherwise becomes known to the public. It normally takes some period of time, ranging from about a month to a year or longer, for an M&A transaction to be completed. When an M&A transaction is successfully completed, the clients exchange or tender their target company securities. In return, the clients receive the payment offered by the acquirer. This may be cash, securities to be issued by the acquirer, or a combination of cash and such securities, depending on the terms of the transaction. When an acquirer offers a security to be issued by it in exchange for a target company security, the clients may simultaneously take offsetting short positions in the offered security that are covered with the newly issued acquirer securities when they are received. This strategy may also involve purchasing or selling options, swaps and other derivative instruments in order to enhance returns or limit risk. In its merger arbitrage strategy, Alpine mainly focuses on publicly announced transactions with definitive merger agreements. Alpine's clients may also invest in other types of merger and acquisition transactions, including hostile takeover bids and proposals, situations involving multiple competing bidders, buyout proposals from a company's management or a major shareholder, companies being pressured to initiate a merger and acquisition transaction by activist investors, and companies engaging in recapitalizations, self-tenders, spin-offs or other restructurings. Alpine's time-tested approach to merger arbitrage has been successfully applied by our experienced team in more than 5,000 M&A transactions over 49 years. Alpine's proprietary database, combined with fundamental and transaction research, and our long experience investing in M&A situations, enables us to manage our clients' merger arbitrage portfolios based on historical experience. Alpine's equity trading strategy mainly involves the creation of positions in connection with Alpine's merger arbitrage strategy. In a stock-for-stock M&A transaction, merger arbitrage investors will normally purchase shares of the company being acquired and sell short the shares of the acquirer stock they expect to receive upon completion of the transaction. Alpine's clients create open market exposures in the acquirers in stock-forstock mergers by purchasing shares of the companies being acquired and refraining from selling short all or a portion of such acquirer shares. In this way, the clients seek to take advantage of market dislocations caused by mergers and other extraordinary M&A transactions and events, using Alpine's proprietary database that has been generated from more than 49 years of M&A investing and relying on its long experience trading M&A situations and technical and fundamental analysis. Another part of the equity trading strategy involves hedging. From time to time Alpine may broadly hedge its total portfolio, one or more sections of its portfolio and/or the market exposure of its main equity trading strategy by using stock index futures, options or other derivative instruments or through short sales of specific stocks or other securities. Alpine does not intend to maintain a strictly market neutral position and may be either net long or net short at any given time.

From time to time, Alpine may also engage in general equity trading, building on its arbitrage research together with technical and fundamental analysis. The equity trading strategy mainly involves the purchase and sale of actively traded common stocks. In this strategy Alpine may also trade in stock index futures and other derivatives, options, preferred stocks, corporate and government bonds, swaps, other securities and financial instruments and currencies, in connection with hedging or other investment techniques. Material Risks Although investments in an Alpine Fund or another client or in an account managed by Alpine may result in significant returns to investors in the Alpine Funds and the other clients of Alpine, they also involve a substantial degree of risk. Alpine generally only accepts clients, and the Alpine Funds and Alpine's other clients generally only accept investors, that are able to bear the financial risk of Alpine's investment strategies for an indefinite period of time and are able to sustain the loss of all or a significant part of their investment. The investment strategies employed by Alpine on behalf of its clients involve significant risks. Prospective clients and investors in the Alpine Funds or Alpine's other clients should carefully review the risk factors described below (and the risks described in the Governing Documents for the relevant Alpine Fund), and should evaluate the merits and risks of an investment in the context of their overall financial circumstances. The risk factors below are not intended to be exhaustive and should be considered carefully by prospective investors together with the full text of the applicable Governing Document. Investment and Trading Risks in General All investments risk the complete loss of the amount invested. No guarantee or representation is made that any investment program will be successful, and investment results may vary substantially over time. The value of a client's portfolio and the income (if any) derived from it can go down as well as up. Alpine's investment program will utilize investment techniques such as futures, options, derivatives, margin transactions and short sales, which practices can, in certain circumstances, maximize the adverse impact to which Alpine's clients may be subject. Merger Arbitrage Alpine's primary investment strategy is merger arbitrage. This strategy may involve substantial risks. The prices of securities of companies involved in merger arbitrage transactions are often volatile, and market movements are difficult to predict. Unforeseeable events may cause sharp market fluctuations against the positions held by Alpine's clients, sometimes causing substantial losses. The principal risk involved in the merger arbitrage strategy is that mergers and other M&A transactions may not be completed. Successful consummation of an arbitrage transaction

may depend on many factors, such as shareholder approval, the outcome of litigation seeking to enjoin it (including, for example, government action on the grounds of alleged violations of antitrust or other federal or state laws), the approval of regulatory or tax authorities, the availability of financing or the absence of material adverse change in the business or financial condition of the companies involved in it. Any such factor may cause a transaction to be significantly delayed, or result in the transaction not being consummated, in which event substantial losses may be incurred. In particular, hostile offers by one company for securities of another company are frequently met by defensive tactics such as protracted litigation to enjoin the offer based on assertions of violations of federal or state securities laws, antitrust violations, and other grounds. Target companies' managements may also seek defensive merger partners or engage in other extraordinary defensive actions. Prices of securities of companies involved in merger arbitrage combinations are often volatile, and market movements are difficult to predict. Unforeseeable events may cause sharp market fluctuations in the positions held by Alpine's clients, sometimes causing substantial losses. Alpine's clients frequently purchase securities at prices only slightly lower than the price being offered for them in an exchange or tender offer or a merger. This purchase price often represents a substantial premium over the market price of the security prior to the announcement of the proposed transaction. As a result, the profit that Alpine's clients would make if an arbitrage deal is consummated is usually small in relation to the amount they stand to lose if such deal is not completed. In a stock-for-stock M&A transaction, Alpine's clients may sell short the shares of acquirer stock they expect to receive in the transaction or refrain from selling short all or a portion of such shares. When clients sell short such shares, such shares may increase in price and the transaction may not be completed, resulting in a loss for the clients. When clients refrain from selling short such shares, risks exist with respect to the open market exposure of the acquirer's stock expected to be received in the transaction. The clients will be exposed to adverse changes in the price of such shares. If such shares increase in price, the clients may not benefit unless the transaction is completed. The terms of certain stock-for-stock combinations may make it difficult for an arbitrage investor to accurately anticipate the amount of securities to be received. Another variable exists in offers that are made partly for cash and partly for securities, either simultaneously or in a multi-step transaction. The value of the securities offered may differ from the cash portion. An investor accepting such an offer may not be able to accurately predict whether it will receive cash or securities or the amount of cash or securities to be received. Also, merger arbitrage investing typically involves investing in long and short positions in common stocks and other equity instruments. See the discussion below in the following three paragraphs.

Equity Trading Alpine's clients also engage in equity trading. This involves the purchase and sale of common stocks and other securities. Prices of equity securities may be volatile, and market movements are difficult to predict. Securities prices may be affected by a wide range of factors, including factors relating generally to equity and other financial markets and the U.S. and global economies, which may not be related to specific issuers. Prices may also be affected by factors relating to specific companies and industries, such as changes in earning forecasts, or material changes in general business, financial or market conditions, such as a broad decline in stock market prices. Adverse change in any such factor may negatively affect the value of clients' holdings. Alpine's clients may invest in companies with small and mid-cap market capitalizations. Such investments may involve greater risk than investing in larger companies. The stock prices of small and mid-cap companies can rise very quickly and drop dramatically in a short period of time. This volatility results from a number of factors, including reliance by these companies on limited product lines, markets and financial and management resources. These and other factors may make small and mid-cap companies more susceptible to setbacks or downturns. These companies may experience higher rates of bankruptcy or other failures than larger companies and they may be more likely to be negatively affected by changes in management. In addition, the stock of a small or midcap company may be thinly traded. When a client refrains from selling short acquirer shares it expects to receive upon completion of stock-for-stock mergers, it will be exposed to adverse changes in the prices of such shares. If such shares increase in price, the client may not benefit unless the acquirers' mergers are completed. Options Trading Alpine's clients may invest in, or write, options. Options involve a high degree of leverage. The purchaser of a put or call option runs the risk of losing his entire investment in a relatively short period of time if an option expires unexercised. The uncovered writer of a call option is subject to a risk of loss should the price of the underlying security increase, and the uncovered writer of a put option is subject to a risk of loss should the price of the underlying security decrease. Writing uncovered options can result in substantial losses. Non-U.S. Investments Although Alpine expects that its clients will invest primarily in securities of U.S. companies, it also expects to invest in securities issued by non-U.S. issuers, denominated in non-U.S. currencies and/or traded outside of the United States. Such investments require consideration of certain risks typically not associated with investing in U.S. securities or property. Such risks include, among other things, trade balances and imbalances and related economic policies, unfavorable currency exchange rate fluctuations, imposition of exchange control regulation by the United States or non-U.S. governments, U.S. and nonU.S. withholding taxes, limitations on the removal of funds or other assets, policies of

governments with respect to possible nationalization of their industries, political difficulties, including expropriation of assets, confiscatory taxation and economic or political instability in other nations. There may be less publicly available information about certain non-U.S. companies than would be the case for comparable companies in the United States, and certain non-U.S. companies may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those of U.S. companies. Securities markets outside the United States, while growing in volume, have for the most part substantially less volume than U.S. markets, and many securities traded on these non-U.S. markets are less liquid and their prices more volatile than securities of comparable U.S. companies. In addition, settlement of trades in some non-U.S. markets is much slower and more subject to failure than in U.S. markets. There also may be less extensive regulation of the securities markets in particular countries than in the United States. Additional costs could be incurred in connection with international investment activities. Non-U.S. brokerage commissions generally may be higher than in the United States. Expenses also may be incurred on currency exchanges when a client changes investments from one country to another. Increased custodian costs as well as administrative difficulties (such as the applicability of foreign laws to foreign custodians in various circumstances, including bankruptcy, ability to recover lost assets, expropriation, nationalization and record access) may be associated with the maintenance of assets in nonU.S. jurisdictions. Currencies Alpine's clients may invest a portion of their assets in securities or other instruments denominated in currencies other than the U.S. Dollar and in other financial instruments, the price of which is determined with reference to currencies other than the U.S. Dollar. However, all of Alpine's clients value their securities and other assets in U.S. Dollars. To the extent unhedged, the value of such assets will fluctuate with U.S. Dollar exchange rates as well as with price changes of the clients' investments in the various local markets and currencies. Accordingly, the value of such assets may be affected favorably or unfavorably by fluctuations in currency rates. Alpine may (but is not obligated to) seek to hedge the exposure of client portfolios to foreign exchange risks. If attempted, there can be no assurance such hedging will be effective. Forward Currency Contracts Alpine may invest in forward currency contracts, primarily for purposes of hedging against currency fluctuations. There can be no assurance that any such hedging transactions will be effective. Forward currency contracts may not be liquid in all circumstances, so that in volatile markets Alpine may not be able to close out a position by taking another position equal and opposite to such position on a timely basis or without incurring a sizeable loss. Closing transactions with respect to forward currency contracts usually are effected with the currency trader who is a party to the original forward contract and generally require the

consent of such trader. There can be no assurance that Alpine's clients will be able to close out their obligations. There are no limitations on daily price moves in forward contracts. Banks and brokerage firms with whom Alpine's clients may maintain accounts may require the clients to deposit margin with respect to such trading. Banks are not required to continue to make markets in forward contracts. There have been periods during which certain banks have refused to quote prices for such forward contracts or have quoted prices with an unusually wide spread between the price at which the bank is prepared to buy and that at which it is prepared to sell. Trading of forward contracts through banks is not regulated by any U.S. governmental agency. Alpine's clients will be subject to the risk of bank failure and the inability of, or refusal by, a bank to perform with respect to such contracts. Swaps and Derivatives Alpine may cause its clients to enter into or invest in exchange-traded and over-the-counter futures, swaps, "synthetic" or derivative instruments, certain types of options and other customized financial instruments issued by banks, brokerage firms or other financial institutions. A swap is an agreement between an investor and a financial intermediary whereby cash payments periodically are exchanged between the parties based upon changes in the price of an underlying asset (such as an equity security, an index of securities, or another asset or group of assets with a readily determinable value). Swaps and other derivatives are subject to the risk of non-performance by the counterparty, including risks relating to the financial soundness and creditworthiness of the counterparty. Swaps and other forms of derivative instruments are not currently guaranteed by an exchange or clearing house. It may not be possible to dispose of or close out a swap or other derivative position without the consent of the counterparty, and the account may not be able to enter into an offsetting contract in order to be able to cover its risk. Regulatory changes in the U.S. or other jurisdictions may significantly impact the trading of swaps and other derivatives in the future. Depending on their terms, derivatives may involve a high degree of risk relative to their cost. Alpine's clients could experience losses if derivatives do not perform as anticipated, or are not correlated with the performance of other investments which the derivatives are used to hedge, or if the clients are unable to liquidate positions because of an illiquid secondary market. Clients could also suffer losses in the event of a default of the counterparty with which the client enters into a derivative. Competition The securities industry, and particularly merger arbitrage, is extremely competitive. Alpine competes for investment opportunities with other firms that have greater financial resources. Concentration of Investments Alpine's clients may at times hold relatively few investments, or have a large portion of their portfolios held in relatively few positions. The result of such concentration of

investments is that a loss in any such position could materially reduce the value of a client's portfolio. Leverage Alpine ordinarily uses significant leverage in client accounts. In addition, certain investment practices or trading strategies such as investment in financial and commodity futures and in options and other derivative instruments may also involve significant leverage. Leverage can be employed in a variety of ways including direct borrowing, margining, short selling and the use of futures, warrants, options and other derivative products. Generally, leverage is used to increase the overall level of investment in a portfolio. Higher investment levels may offer the potential for higher returns. This may expose an investor to increased risk as leverage can increase an account's market exposure and volatility. The risk of leverage in futures contracts, options, warrants and other derivatives is that small movements in the price of the underlying asset or index can result in large losses or profits. Many derivatives are not traded on any exchange, and no assurance can be given that a liquid market will exist for any particular futures contract or other derivative at any particular time. If assumptions are wrong or if the instruments do not work as anticipated, the relevant portfolio could lose more than if the portfolio had not used such investment techniques. Prime brokers and other financial institutions providing leverage may vary the margin requirements, or amount of leverage, they are willing to make available to Alpine's clients and the interest rates for such leverage at any time. The level of interest rates at which the clients can borrow will affect their operating results. If securities pledged to lenders to secure the clients' margin accounts decline in value, the clients could be subject to a "margin call", pursuant to which they must either deposit additional funds with the lender, or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. If there is a sudden precipitous drop in the value of a client's assets, it may be difficult for that client to sell assets quickly enough to pay off its margin debt. Illiquid Assets From time to time, certain investment positions held by Alpine's clients may occasionally be or become illiquid. A client may invest in "restricted" or non-publicly traded securities or thinly traded securities. It may not be easy to dispose of such non-publicly or thinly traded securities, and in some cases there may be contractual restrictions preventing the disposal of securities for a specified period of time. An exchange or regulatory authority may suspend trading in a particular security or contract, order immediate liquidation and settlement of a particular contract, or order that trading in a particular contract be conducted for liquidation only. Such investments may require a significant amount of time from the date of initial investment before disposition. The ability of a client to withdraw its investment or for an Alpine Fund to pay redemption or withdrawal proceeds may be adversely affected by illiquidity of the underlying assets. If redemptions or withdrawals exceed the amount of cash or other liquid assets immediately available to fund such redemptions or withdrawals, a client may need to liquidate additional

assets, which may in turn limit or otherwise affect investment positions and strategies within its portfolio. Hedging Alpine's investment strategies may employ hedging techniques, directed primarily toward general market risks. If employed, hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments. For a variety of reasons, it may not be possible to establish a sufficiently accurate correlation between hedging instruments and the portfolio holdings being hedged. Such imperfect correlation may prevent a client from achieving the intended hedge or expose the client to risk of loss. In addition to possible losses on the position sought to be hedged, a client could incur losses on the hedging position itself. All hedging strategies necessarily involve costs, which could be significant, whether or not the hedge sought is successful. Some strategies may invest in markets or instruments as to which hedging strategies are limited or unavailable. Hedging instruments may involve costs or risks that may be considered prohibitive in the context of the relevant strategy. Short Selling Alpine may cause its clients to engage in short selling transactions, and may use margin in connection with such transactions. Short selling involves the sale of a security that the seller does not own in the hope of purchasing the same security at a later date at a lower price. A short sale of a security involves the risk of a theoretically unlimited increase in the market price of the security, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no guarantee that securities or other instruments necessary to cover a short position will be available for purchase. Due to regulatory or legislative action taken by regulators or legislatures around the world as a result of volatility in the global financial markets, taking short positions on certain securities has sometimes been restricted. The levels of restriction vary across different jurisdictions and are subject to change in the short to medium term. These restrictions may make it difficult and in some cases impossible for market participants either to continue to implement their investment strategies or to control the risk of their open positions. Counterparty Risks Investments may be subject to the risk of the inability of any counterparty (including any prime broker, derivative counterparty or custodian) to perform with respect to transactions, whether due to insolvency, bankruptcy or other causes. Alpine may maintain trading relationships with counterparties that may include various non-U.S. broker-dealers and financial institutions. In general, Alpine will seek to have its clients maintain relationships with highly rated counterparties. However, these relationships could result in concentration of credit risk. A client portfolio in particular could be exposed to credit risk if counterparties fail to fulfill their obligations or the value

of any collateral provided by a counterparty becomes inadequate. When options or other derivative contracts are purchased over-the-counter, an account bears the risk if the counterparty to that derivative contract will be unable or unwilling to perform its obligations under the contract. Such derivative contracts may also be illiquid and, in such cases, an account may have difficulty closing out its positions. Transaction Costs Certain investment strategies may involve a high level of trading and turnover of the client portfolio's investments, which may be higher than the average for other more traditional portfolios. Accordingly the level of commissions paid and other transaction costs borne by the client may be higher than average. Changes in Regulation Legal, tax and regulatory developments could occur. Securities and futures markets are subject to comprehensive statutes, regulations and margin requirements enforced by the SEC, the Commodity Futures Trading Commission, other U.S. and non-U.S. regulators and self-regulatory organizations and exchanges authorized to take extraordinary actions in the event of market emergencies. The regulation of derivatives transactions and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial actions. The regulatory environment for private funds is evolving, and changes in the regulation of hedge funds and their trading activities may adversely affect the ability of investors to pursue certain investment strategies, the ability to obtain leverage and financing, and the value of certain investments. U.S. and non-U.S. regulators may take additional actions in light of other developments in global financial markets. In September 2008, for example, the SEC and various non-U.S. regulatory bodies imposed temporary bans on short-selling of a variety of stocks, and adopted other regulations that may have the effect of making short-selling more difficult or costly. Similar future actions may adversely affect the markets in which Alpine's clients invest, and may limit or adversely affect the ability of the clients to use short sales, swaps and other derivatives as part of Alpine's investment and hedging strategies. General Economic and Market Conditions The success of investment activities will be affected by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of a portfolio's investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of the prices and the liquidity of a portfolio's investments. In addition, market disruptions caused by unexpected political, military and terrorist events may from time to time cause significant losses for a client portfolio and such events can result in otherwise historically low-risk strategies performing with unprecedented volatility and risk. Financial exchanges may from time to time suspend or limit trading. Such suspensions could render it difficult or impossible to liquidate affected positions of client

accounts and thereby expose them to losses. There is also no assurance that off-exchange markets will remain liquid enough to permit closing out positions for clients. Financial market disruptions may result in extensive and unprecedented government intervention. Such intervention may be implemented on an emergency basis, suddenly and substantially eliminating or restricting the ability of market participants to continue to implement certain strategies or manage the risk of their outstanding positions. These interventions may at times be unclear in scope and application, resulting in confusion and uncertainty, which can be materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. Alpine's clients may incur significant losses in the event of disrupted markets and other extraordinary events in which historical pricing relationships become materially distorted. Prime Broker and Custodian Insolvency A client portfolio may be at risk of a prime broker or other custodian entering into an insolvency proceeding. During such a proceeding (which may last many years), the use of assets held by or on behalf of the prime broker or custodian may be restricted. During such a proceeding, especially outside the United States, a client portfolio may be an unsecured creditor in relation to certain assets, and accordingly may be unable to recover such assets from the insolvent estate of the relevant prime broker or custodian in full or at all. Realization of Profits and Valuation of Investments Certain assets that are not regularly traded on recognized markets may be difficult to value. Changes in circumstances or market conditions may lead to revaluation of certain assets, which may result in material increases or decreases in the value of a client's portfolio. Operational Risks Alpine is responsible for developing, implementing and operating appropriate systems and procedures to execute all investment transactions and monitor and control operational risk on behalf of its clients. Alpine relies on its execution, financial, accounting and other data processing systems to trade, clear and settle all transactions, to evaluate and monitor potential and existing portfolio investments, and to generate risk management and other reports that are critical to oversight of client accounts. Certain of Alpine's operations are dependent upon systems operated by third parties, including JPMorgan Chase Bank N.A. (the administrator for the Alpine Funds), prime brokers, counterparties, electronic exchanges, other execution platforms and their various service providers. Alpine may not be in a position to verify the reliability of such third-party systems or data. Failure of or errors in such systems could result in mistakes or delays in the execution, confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. The increasing reliance on internet-based programs and applications to conduct transactions and store data also creates increased security risks. Targeted cyberattacks, or accidental events, can lead to a breach in computer and data systems and access by unauthorized persons to sensitive transactional or personal information. Data taken in breaches may be used by criminals to commit identity theft, obtain loans or

payments under false identities, and other crimes. Cybersecurity breaches at Alpine or its service providers or counterparties may directly or indirectly affect clients, and could lead to theft, data corruption, interference with business operations, disruption of operational systems, interference with Alpine's or its clients' ability to execute transactions, direct financial loss or reputational damage, or violations of applicable laws related to data and privacy protection and consumer protection. Force Majeure Alpine and its clients may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemics 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, and social instability). Investment advisory activities and Alpine’s operations could be adversely affected by such events outside of Alpine’s control. Alpine, its clients, their service providers and counterparties may incur expenses, delays, or interruption of critical business functions relating to such events outside of their control, which could have adverse impacts on their respective investment advisory businesses. Such adverse impacts could, in turn, adversely affect the performance of clients.

Mrs. Victoria E. Zoellner is the sole shareholder and the Chairman of the Board of Directors of Alpine and is also the sole shareholder and director of AAS. In addition, three of the four directors of Alpine are Alpine employees and most of the senior officers of Alpine are also senior officers of AAS and of certain of the Alpine Funds. See Items 4 and 5 above under "Advisory Business" and "Fees and Compensation" for additional information about the relationships among Alpine and AAS. Employees of Alpine and its affiliates may serve as officers, advisors or in comparable management functions for portfolio companies in which Alpine's clients invest, or provide other services to portfolio companies, and may receive compensation in connection therewith. Employees of Alpine may also from time to time serve on the board of directors or a creditors committee of a portfolio company, or be given access for other reasons to confidential information relating to companies in which Alpine's clients invest. As a result, Alpine's clients may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the debt or securities of such a portfolio company, which prohibition may have an adverse effect on Alpine's clients. Selection or Recommendation of Other Advisers Alpine does not recommend or select other investment advisers for its clients or receive compensation from such advisers in a manner that would create a material conflict of interest. Alpine does not have other business relationships with other advisers that create a material conflict of interest.

It is the expressed policy of Alpine that no person employed by Alpine shall prefer his or her own interest to that of an advisory client. The Code of Ethics contains policies and procedures with respect to personal securities transactions by employees and related accounts that are designed to prevent front-running, scalping, the misuse of inside information and other improper activities. Employees who are involved in Alpine's investment activities or who have access to non-public information regarding Alpine's clients must arrange for all statements and trade confirmations for their personal brokerage accounts to be directly delivered by their brokers to the CCO (or a designee) and must also report all personal transactions to the CCO (or a designee) on at least a quarterly basis. The CCO (or a designee) monitors all transactions by employees in

order to identify any pattern of conduct that may evidence conflicts or potential conflicts with the principles and objectives of the Code of Ethics, or other inappropriate behavior. Alpine requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. Alpine's Code of Ethics also includes the firm's policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline or termination. Alpine will provide a complete copy of its Code of Ethics to any client or prospective client or any investor or prospective investor in an Alpine Fund upon request. To make such a request, please contact Alpine’s CCO at the address or telephone number listed on the first page of this document. Participation or Interest in Client Transactions; Personal Trading Alpine's sole shareholder and certain of its employees and affiliates are investors in some of the Alpine Funds. In certain situations, related persons of Alpine may purchase interests in portfolio investments held by one or more Alpine clients. All such purchases are subject to compliance with Alpine's Code of Ethics as described above. Moreover, from time to time, Alpine may cause an Alpine Fund to engage in "cross trades" via the purchase of a portfolio investment from or sale of a portfolio investment to another Alpine Fund, provided that the sale or purchase is consistent with Alpine's fiduciary obligations to each Alpine Fund.

Alpine considers such factors as price, the ability to effect the transactions, the brokers' or dealers' facilities, reliability and financial responsibility, special execution capabilities, block trading and block positioning capabilities, willingness to execute related or unrelated difficult transactions in the future, efficiency of execution and error resolution, quotation services, the availability of stocks to borrow for short trades, custody, recordkeeping and similar services, and any research or related services provided by such brokers or dealers (including providing access to the managements of portfolio companies). Alpine does not necessarily solicit competitive bids and does not have an obligation to seek the lowest available commission cost. In limited circumstances, Alpine

may cause a higher commission to be paid to a broker or dealer that furnishes research or other services than might be charged by another broker or dealer for effecting the same transaction, provided that Alpine determines in good faith that the amount of commissions charged is reasonable in relation to the value of the brokerage and research or other services provided by such broker or dealer. Research services provided to Alpine by brokers may include written information and analyses concerning specific securities, companies or sectors (whether produced by the broker or a third party); market, financial and economic studies and forecasts (whether produced by the broker or a third party); statistics and pricing services; databases; discussions with research personnel; and other news, technical and telecommunications services utilized by Alpine in the investment management and execution process. Alpine does not generally receive any benefits outside the safe harbor under Section 28(e) of the Securities Exchange Act of 1934, as amended, for the use of commissions or "soft dollars" to obtain "research and execution" services. Research services provided by brokers may be used for the benefit of all clients of Alpine. Clients may pay higher commissions than are obtainable from other brokers as a result of the consideration of research services as a factor in selecting brokers in addition to commission cost and best execution. Alpine's use of client brokerage commissions to obtain research services is a benefit to Alpine because Alpine does not have to produce or pay for such research services. This may result in an incentive for Alpine to select or recommend a broker-dealer based, in part, on the interest of Alpine in receiving such research services, rather than exclusively on the interest of Alpine's clients in receiving most favorable execution. Alpine and its affiliates may have other business arrangements with brokers and dealers used to execute transactions for clients. Various brokerage firms used to execute transactions for Alpine's clients and such firms' affiliates and employees have made investments in the Alpine Funds, referred investors to the Alpine Funds or Alpine's other clients, and referred clients to Alpine, and may in the future make such investments and referrals. Certain of such brokerage firms also provide prime broker and financing and other services to such clients. Although such investments, referrals and services may give rise to potential conflicts of interest, Alpine does not consider such investments, referrals or services to be a material factor influencing its selection of executing brokers or prime brokers for its clients. Brokerage firms and their employees may offer gifts to employees of Alpine, and may invite employees of Alpine to entertainment and social events. It is Alpine's policy that factors such as gifts and entertainment that do not benefit client accounts should not be considered when selecting brokers and counterparties to execute transactions for clients. Brokerage for Client Referrals Subject to Alpine's obligation to seek best execution of all transactions for its clients, Alpine may consider referrals of clients to Alpine and its affiliates or investors to the Alpine Funds or Alpine's other clients in determining its selection of broker-dealers. Alpine may have an incentive to select or recommend a broker-dealer based on its interest in receiving

investor referrals, rather than on its clients' interest in receiving the most favorable execution. Directed Brokerage Alpine does not recommend, request or require that a client direct it to execute transactions through a specified broker-dealer. Alpine does not permit its clients to direct brokerage through a specified broker-dealer. Trade Aggregation Alpine has established allocation and aggregation procedures for the allocation of portfolio investment transactions among its clients. The allocation and aggregation procedures are designed to ensure that each client is treated fairly and that transactions are allocated in a manner that is fair and equitable to each client relative to the other clients, taking into account all relevant facts and circumstances. Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other. Orders to buy or sell the same security for multiple clients are ordinarily placed on an aggregated basis and typically allocated proportionately to each participating client, taking into consideration the size of the order placed, investment restrictions, if any, and any other relevant factors (including the size of each client and the level of each client's investment exposure for such security). Please see Item 6 above under "Performance-Based Fees and Side-by-Side Management" for additional information about how orders for clients may be placed. Each client that participates in an aggregated order will generally participate at the average of all prices at which the order is filled. In certain situations a client may not be in a position to participate in a joint order with Alpine's other clients, for regulatory or other reasons. In such situations, Alpine will ordinarily complete the order for its other clients first, and then execute a substantially equivalent order for the client that is unable to participate jointly. This may disadvantage the client that is unable to participate jointly with respect to the prices at which its order is executed and the quantities of securities and instruments it may be able to buy and sell. Alpine may place orders for its clients in such order and in such other manner as it deems appropriate.

Each review is conducted by one of Alpine's trading personnel, under the supervision of Alpine's Chief Executive Officer. Reports to Clients Investors in the Alpine Funds receive annual audited financial statements. In addition, monthly unaudited account statements are available to investors by email. Account statements are provided by JPMorgan Chase Bank N.A., the administrator for the Alpine Funds. Clients that are not Alpine Funds receive account statements from the custodians or prime brokers having custody of such accounts at such frequencies as the clients and prime brokers may agree.

Alpine and its affiliates may enter into cash compensation arrangements with unaffiliated placement agents or third parties for introducing investors to an Alpine Fund or Alpine's other clients. An investor in an Alpine Fund or other client will not be charged any additional amount or bear any additional charges as a result of an introduction through a placement agent or other unaffiliated third party. As described in Item 12 above under "Brokerage Practices", Alpine may also consider referrals of clients to Alpine and its affiliates and of investors to the Alpine Funds or other clients in determining its selection of broker-dealers for securities transactions. Alpine endeavors at all times to put the interests of its clients first as part of Alpine's fiduciary duty. Nevertheless, the receipt of compensation by placement agents and the potential receipt of brokerage commissions by broker-dealers creates a potential conflict of interest, and may affect the judgment of placement agents and broker-dealers when making referrals to Alpine, the Alpine Funds or Alpine's other clients. Moreover, a potential conflict of interest may arise between the interests of Alpine's clients in obtaining best price and execution and Alpine's interest in receiving future referrals to the Alpine Funds and its other clients. Alpine will address this conflict of interest by seeking to obtain best execution, as discussed in the section titled "Brokerage Practices".

generally accepted accounting principles, to investors no later than 120 days after the end of each fiscal year. Clients that are not Alpine Funds should receive at least quarterly statements from their custodian. Alpine urges clients to carefully review such statements and compare them to any account information provided by Alpine.

Alpine, its affiliates and its personnel will not be liable to any client or investor in such client for: (i) any acts or omissions arising out of, or in connection with, the client, any investment made or held by the client or any governing agreement relating to the client, unless such action or inaction was performed or omitted fraudulently or in bad faith or constituted gross negligence or willful misconduct, or for losses due to such action or inaction, or (ii) the negligence, dishonesty or bad faith of any broker or agent of the client, Alpine or any of their affiliates, provided that such broker or agent was selected, engaged or retained by the client or any of the client's affiliates, or that such broker or agent was selected, engaged or retained by Alpine or any of Alpine's affiliates in good faith. Also, Alpine's clients will generally be required to indemnify Alpine, its affiliates and its personnel against any act or omission related to the clients, absent bad faith, gross negligence or willful misconduct. As a result, any negative or positive results of trading errors (including without limitation, human errors such as keystroke errors that occur when entering trades into an electronic trading system, typographical or drafting errors related to derivatives contracts or other agreements, and other errors in entering or failing to enter orders) generally will be borne by the client, rather than by Alpine or any of its affiliates or personnel, so long as Alpine or such affiliate or person adheres to the foregoing standard of care. Each of Alpine and its affiliates and personnel may consult with counsel and accountants in respect of the client's affairs and be fully protected and justified in any action or inaction that is taken in accordance with the advice or opinion of such counsel and/or accountants, provided that they shall have been selected in good faith. The foregoing provisions will not be construed so as to provide for the exculpation of Alpine or any

affiliate or person for any liability (including liability under Federal securities laws which, under certain circumstances, impose liability even on persons that act in good faith), to the extent (but only to the extent) that such liability may not be waived, modified or limited under applicable law, but will be construed so as to effectuate the foregoing provisions to the fullest extent permitted by law.

Alpine will vote all client proxies in a manner consistent with the general voting guidelines contained in the Proxy Voting Policies and Procedures and that Alpine believes reflects the best interests of its clients, after taking into consideration relevant facts and circumstances. As a result, depending on the client's particular circumstances, Alpine may vote one client's securities differently than it votes those of another client, or may vote differently on various proposals, even though the securities or proposals are similar (or identical). In some instances, Alpine may determine that it is in the client's best interest for Alpine to "abstain" from voting. If a conflict of interest arises in connection with exercising its voting authority, Alpine will determine whether or not such conflict is material. If a material conflict exists, Alpine takes steps to ensure that its voting decision is consistent with the best interests of the client and is not affected by the conflict. Alpine may, at its discretion, seek the advice of the client in voting such security. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar (or identical). Alpine will deliver to each client upon written request a complete copy of its Proxy Voting Policies and Procedures and/or information on how it voted proxies for the applicable client. To make such a request, please contact Alpine’s CCO at the address or telephone number listed on the first page of this document. With respect to class actions, it is Alpine's normal practice to participate in recoveries related to securities and similar class actions and to file related claim forms on behalf of its clients.