Polus Capital Management Limited: investment adviser

(“PCMUS”), which is an investment adviser with its principal place of business in New York, NY and is a wholly owned subsidiary of PCMGL. Polus provides PCMUS a supervisory person, a senior advisor for the leveraged credit team, some members of the investment committee, and back-office support. PCMUS provides Polus marketing and analyst support (one marketer and one analyst). The delegated activities are structured in such a way as to mitigate any conflicts of interest and do not lead to any detriment of either of the firms. Polus manages both segregated mandates as well as pooled investment vehicles qualifying for an exclusion from the definition of an investment company under Section 3(c)7 of the Investment Company Act of 1940 (“Private Funds”). These Private Funds include issuers of collateralized loan obligation securities and to special purpose vehicles entering into warehouse, repurchase or other credit facilities to finance the preliminary accumulation and “ramp-up” of loans comprising all or a portion of the initial pool of collateral for any such issuer (each a “CLO”). Polus’ clients (“Clients”) refer to both segregated mandates and Private Funds. As at 31 January 2026, Mediobanca S.p.A., a listed Italian investment bank, holds approximately 65.78% of PCMGL. The remaining 34.22% is owned by the management and staff of PCMGL with STAR holding a minority stake. Mediobanca S.p.A. is part of the Banca Monte dei Paschi di Siena S.p.A. group. Polus is authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom. Polus’s principal place of business is located in London, United Kingdom. This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Clients are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective investors in and beneficial owners of the Clients, including requirements that they be “accredited investors” as defined in Regulation D, “qualified purchasers” as defined in the Investment Company Act, or non-“U.S. Persons” as defined in Regulation S. Persons reviewing this Brochure should not construe this as an offer to sell or a

solicitation of an offer to buy the securities of any of the Clients described herein. Any such offer or solicitation will be made only by means of the Client’s offering documents.

Advisory Services Polus provides asset management and investment advisory services to Clients. Polus’ focus, based on its highly specialized credit markets capability, is in the sectors of leveraged finance, opportunistic credit (special situations and distressed) and structured credit more generally. The asset management services provided by Polus involve the discretionary management of the asset portfolios for the Client, including the selection of assets to be acquired and assets to be disposed of, monitoring the assets in the portfolio and arranging any currency and interest rate hedging which Polus considers to be necessary. Polus also provides non-discretionary structuring and advisory services relating to asset portfolios in the form of segregated mandates. The non-discretionary advisory services provided by Polus are usually of a longer-term nature involving monitoring and advising on a portfolio of assets. In portfolio management and advisory engagements, including both those with discretionary and non-discretionary investment authority, Polus will review portfolio assets on a regular basis and make decisions or recommendations, as applicable, for future portfolio actions with respect to individual securities (or the portfolio as a whole) based on an analysis of current market values and trends, fundamental value, security specifics, technical flows and any other factors relevant to expected performance. The descriptions set forth in this Brochure of specific advisory services that Polus offers to its Clients, and investment strategies pursued and investments made by Polus on behalf of its Clients, should not be understood to limit in any way Polus’ investment activities. Polus may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that Polus considers appropriate, subject to each Client’s investment objectives and guidelines. The investment strategies Polus pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. Mandates for segregated mandates are individually negotiated and as part of those negotiations the needs of the Client will be addressed and the Client will be able to include any restrictions the Client wishes to impose, including restrictions on investing in certain securities or types of securities. Our investment decisions and advice with respect to each Private Fund will be subject to each Private Fund’s investment objectives and guidelines, as set forth in its respective offering documents. Polus does not issue any publications or reports on a subscription basis or for a fee or participate in any wrap fee programs. As at 31 December 2025, Polus managed assets on a discretionary basis of approximately U.S.$5,309,200,000 and on a non-discretionary basis of approximately U.S.$10,100,000.

The advisory fees charged to Private Funds (and certain other segregated mandate Clients required to be reported under Part 1A) generally include two elements, a base fee which is typically paid monthly or quarterly by reference to the value of the assets under management and a performance or incentive fee or carried interest which represents a percentage of any excess returns achieved over prescribed hurdle levels. A performance fee may be paid annually and an incentive fee or carried interest may be payable at conclusion of the discretionary mandate. For certain Private Funds, fees are invoiced on a monthly or quarterly basis in arrear, based on the net asset value at the end of each month or quarter, as the case may be. For CLOs, the management fees will be accrued and paid on the interest payment dates of the relevant CLO, in arrear based on fees outlined in each Client’s governing documents. The payments are made by the Trustee as part of the interest payment date waterfall payments. Other Fees and Expenses In addition to the payment of advisory fees, Clients may pay other fees and expenses reasonably attributable to its establishment and operation. This includes but is not limited to trading and execution costs, research fees, custodian fees, prime brokerage fees, fees of the administrator, directors’ fees, asset pricing or rating services fees, software provider fees, programming and data entry services fees directly related to the management of a portfolio, taxes, regulatory and governmental charges, costs and expenses in connection with compliance with any applicable risk retention regime, legal expenses and out of pocket expenses incurred by the Directors or the Firm in connection with the business of the Private Funds and regulatory fees, including Form PF, Form D, Form 13F and Form 13H. Investors should refer to the Private Fund offering documents for a full description of fees and expenses. Full details of actual fees and expenses incurred are also included in the Private Funds’ audited financial statements, which are distributed to all investors annually. See Item 9 below for a discussion of Polus’s brokerage practices. Prepayment of Fees Polus does not require its Clients to pay fees in advance. No Compensation for Sale of Securities or Other Investment Products

Polus does not accept direct compensation for the sale of securities or other investment products. One of the supervised persons of Polus, Mr. Randy S. Griffith Jr. (CRD #: 7429122) is entitled to receive compensation from the Adviser or PCMUS for his responsibilities described in more detail in, and in accordance with the agreements between Polus, PCMUS and Foreside Fund Services, LLC (“Foreside”). Mr. Griffith is employed by PCMUS but he is fully seconded to Polus, and his role and responsibilities are provided only to Polus. Therefore, he is a supervised person of Polus. Such fees are generally determined by reference to various factors including Polus’ relative role in sourcing the business or introduction or participating in the execution of the mandate and will be established on an arm’s length basis and described in more detail in agreements between the Adviser and PCMUS. Mr. Griffith is a registered representative of Foreside, a registered brokerdealer with the SEC in the U.S. The broker-dealer is not a current Client of, or investor in a Private Fund advised by Polus. Polus does not use the subject broker-dealer to effect trades or investments for the Clients. Please see “Item 10: Other Financial Industry Activities and Affiliations” and “Item 14: Client Referrals and Other Compensation” of this brochure for more detailed description of potential conflicts of interest and Polus’s client referral arrangements.

For example, under discretionary asset management transactions, Polus may receive fees based, in part, on a performance or incentive fee which represents a percentage of any excess returns achieved over prescribed hurdle levels, while at the same time providing portfolio advisory services to other Clients in which fees are fixed or calculated solely as a percentage of assets. In such circumstances, Polus or its supervised persons will have an incentive to favor accounts for which Polus receives a performance-based fee over accounts for which Polus receives a fixed fee or a fee calculated solely as a percentage of assets. These conflicts are addressed by the adoption by Polus of an allocation policy which requires Polus to allocate orders fairly and not give unfair preference to any Client, independent of the fee structure.

In managing or advising on specific assets or portfolios, Polus carries out extensive analysis relating to an individual position, groups of positions or the aggregate portfolio. At an individual position level, Polus carries out fundamental credit research as to the quality or strength of the cash flows of the creditor to which the position relates. In the case of a corporate asset this will include the prospects of the company, a view of the sector in which the company operates, the sensitivity of the earnings of the company to external factors and any other factors that may affect the company’s ability to service its debts on a timely basis. In the case of structured credit or asset backed securities the underlying exposure will be to a pool of collateral (for example loans) and the fundamental research will relate to the performance of that collateral pool under certain base case and stressed assumptions. Polus is committed to adopting and implementing responsible investment principles in a manner that is consistent with its fiduciary responsibilities to its clients. In furtherance of this Polus has adopted a Responsible Investment policy, which sets out its approach to the management of sustainability and governance issues, including the principles which it aspires to. The policy is supported by a set of procedures which have been implemented to integrate these principles into Polus’ activities. PCMGL is a signatory to the UN-supported Principles for Responsible Investment (PRI). The PRI is a global, collaborative network of investors established in 2006 in recognition of the increasing relevance of environmental, social and governance issues within the investment process. Material, Significant or Unusual Risks

The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Clients advised by Polus. These risk factors include only those risks Polus believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. Not all possible risks are described below, and risks described below may not be applicable to all Clients. Investors in the Clients should refer to their offering documents for more complete information on investment strategies employed and the corresponding risks associated with such investment strategies. General Market Risks The success of a Client’s 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 Client’s investments), trade barriers, currency exchange controls, national and international political circumstances (including wars, terrorist acts or security operations) and public health crises (such as pandemics and epidemics). These factors may affect the level and volatility of investments’ prices and the liquidity of a Client’s investments. Volatility or illiquidity could impair a Client’s profitability or result in losses. A Client may maintain substantial trading positions that can be adversely affected by the level of volatility in the financial markets — the larger the positions, the greater the potential for loss. The economies of countries in which a Client may invest may differ in such respects as growth of gross domestic product, rate of inflation, currency depreciation, asset reinvestment, resource selfsufficiency and balance of payments position. Further, certain economies are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. The economies of certain countries may be based, predominantly, on only a few industries and may be vulnerable to changes in trade conditions and may have higher levels of debt or inflation. Risks Related to Certain Financial Instruments Polus does not recommend a particular type of investment instrument to the Clients, but rather, Polus recommends and invests in multiple investment instruments. Given the broad discretion Polus has in managing its Clients, any one or more of the risks listed in the previous section may be incurred by its Clients. However, because it may be useful in understanding Polus’ investment program, set forth below is a non-exclusive list of certain risks related to securities and other instruments that may be utilized: Equity Securities Generally. The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, a Client may suffer losses if it invests in equity instruments of issuers whose performance diverges from its investment manager’s expectations or if equity markets generally move in a single direction and a Client has not hedged against such a general move. A Client also may be exposed to risks that issuers will not fulfil contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common

stock upon conversions of convertible securities and registering restricted securities for public resale. Debt Securities Generally. Clients may invest in private debt securities and other similar instruments. Clients may invest in debt instruments that are unrated, and whether or not rated, the debt instruments may have speculative characteristics. The issuers of such instruments, including sovereign issuers, may face significant ongoing uncertainties and exposure to adverse conditions that may undermine the issuer’s ability to make timely payment of interest and principal. Such instruments are regarded as predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal in accordance with the terms of the obligations and involve major risk exposure to adverse conditions. Clients may invest in bonds or other fixed income securities, including without limitation “higher yielding” (including non-investment grade) debt securities. Such securities are generally not exchange traded and, as a result, these financial instruments trade in the over-the-counter marketplace, which is less transparent and has wider bid/ask spreads than the exchange-traded marketplace. In addition, Clients may invest in bonds of issuers that do not have publicly-traded equity securities, making it more difficult to hedge the risks associated with such investments. Also, the market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. High yield securities face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer’s inability to meet timely interest and principal payments. Derivative Instruments Generally. Certain swaps, options and other derivative instruments may be subject to various types of risks, including market risk, liquidity risk, the risk of non-performance by the counterparty (including risks relating to the financial soundness and creditworthiness of the counterparty), legal risk and operations risk. Currencies and Currency-Related Instruments. A principal risk in trading currencies is the rapid fluctuation in the market prices of currency contracts. Prices of currency contracts traded by Clients are affected generally by relative interest rates, which in turn are influenced by a wide variety of complex and difficult to predict factors such as money supply and demand, balance of payments, inflation levels, fiscal policy, and political and economic events. In addition, governments from time to time intervene, directly and by regulation, in these markets, with the specific effect, or intention, of influencing prices which may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. Clients may invest in undervalued currencies. Identifying investment opportunities in undervalued currencies is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. Returns generated from such investments may not adequately compensate for the business and financial risks assumed. In addition, a Client may be required to hold such currencies for a substantial period of time before realizing their anticipated value. During this period, a portion of the Client’s assets would be committed to the currencies purchased, thus possibly preventing the Client from investing in other opportunities. Further, a

Client may finance such purchases with borrowed funds and thus will have to pay interest on such funds during such waiting period. Like the writing of other kinds of options, the writing of an option on a currency constitutes only a partial hedge, up to the amount of the premium received. A Client could be required, with respect to any option it has written, to purchase or sell currencies at disadvantageous exchange rates, thereby incurring losses. The purchase of an option on a currency may constitute an effective hedge against fluctuation in exchange rate, although in the event of rate movements adverse to the Client’s position, the Client could forfeit the entire amount of the premium plus related transaction costs. Stressed and Distressed Obligations. Clients may invest in obligations of issuers in weak financial condition, experiencing poor operating results, having substantial capital needs or negative net worth, facing special competitive or product obsolescence problems, including companies involved in bankruptcy or other reorganization and liquidation proceedings. These obligations are likely to be particularly risky investments although they also may offer the potential for correspondingly high returns. Among the risks inherent in investments in troubled entities is the fact that it frequently may be difficult to obtain information as to the true condition of such issuers. Such investments also may be adversely affected by laws relating to, among other things, fraudulent transfers and other voidable transfers or payments, lender liability and the bankruptcy court’s power to disallow, reduce, subordinate, recharacterize debt as equity or disenfranchise particular claims. Such companies’ obligations may be considered speculative, and the ability of such companies to pay their debts on schedule could be affected by adverse interest rate movements, changes in the general economic climate, economic factors affecting a particular industry or specific developments within such companies. In addition, there is no minimum credit standard that is a prerequisite to a Client’s investments in any financial instrument, and a significant portion of the obligations in which a Client invests may be less than investment grade. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial difficulties is unusually high. There is no assurance that value of the assets, if any, collateralizing a Client’s investments will be sufficient or that prospects for a successful reorganization or similar action will become available. In any reorganization or liquidation proceeding relating to a company in which a Client invests, a Client may lose its entire investment, may be required to accept cash or securities with a value less than its original investment and/or may be required to accept payment over an extended period of time. Occasionally, a Client may need to make a follow-up investment in an existing troubled position only in an attempt to protect the value of its initial investment. In addition, under certain circumstances, payments and distributions may be disgorged if any such payment is later determined to have been a fraudulent conveyance or a preferential payment. In liquidation (both in and out of bankruptcy) and other forms of corporate reorganization, there exists the risk that the reorganization either will be unsuccessful (due to, for example, failure to obtain requisite approvals), will be delayed (for example, until various liabilities, actual or contingent, have been satisfied) or will result in a distribution of cash or a new security the value of

which will be less than the purchase price to a Client of the security in respect to which such distribution was made. Repurchase and Reverse Repurchase Agreements. The use of repurchase and reverse repurchase agreements by a Client involves certain risks. For example, if the seller of securities to a Client under a reverse repurchase agreement defaults on its obligation to repurchase the underlying securities, as a result of its bankruptcy or otherwise, a Client will seek to dispose of such securities, which action could involve costs or delays. If the seller becomes insolvent and subject to liquidation or reorganization under applicable bankruptcy or other laws, a Client’s ability to dispose of the underlying securities may be restricted. It is possible, in a bankruptcy or liquidation scenario, that a Client may not be able to substantiate its interest in the underlying securities. Finally, if a seller defaults on its obligation to repurchase securities under a reverse repurchase agreement, a Client may suffer a loss to the extent that it is forced to liquidate its position in the market, and proceeds from the sale of the underlying securities are less than the repurchase price agreed to by the defaulting seller. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. CLO Specific Risks: CLOs invest primarily in sub-investment grade credit in the form of broadly syndicated senior secured leveraged loans, as well as floating rate and fixed notes. Investing in a CLO involves risk of loss that an investor in a CLO should be prepared to bear. CLO securities are offered to investors pursuant to disclosure documents that contain detailed information about the risks of investing in the particular CLO, including, among others, the risks relating to the CLO securities and structure, as well as those relating to the underlying assets held by such CLO. With respect to each CLO, certain investment risks mentioned in this brochure are qualified in their entirety by the CLO’s governing documents. Investors should carefully review the governing documents for a CLO before investing in such CLO and evaluate the information and risks disclosed therein with their legal, tax and accounting advisors. As part of the ordinary management of its portfolio, a CLO will typically generate cash from asset repayments and sales and reinvest those proceeds in substitute assets, subject to compliance with its governing documents. The earnings with respect to such substitute assets will depend on the quality of reinvestment opportunities available at the time. The need to satisfy each CLO’s investment guidelines and identify acceptable assets could require the Adviser to purchase substitute assets at a lower yield than those initially acquired or require that the sale proceeds be maintained temporarily in cash or cash equivalents, either of which might reduce the yield that the CLO is able to achieve. The investment guidelines and other CLO terms could incentivize the Adviser to buy riskier assets than it otherwise would, which could result in additional losses. Polus strategies focus primarily on investing in credit instruments that expose investors either directly or indirectly to the risk of loan defaults from underlying borrowers. Such defaults can also precipitate a broader failure of these businesses, and while loan providers may benefit from certain remedies and security, these may not be sufficient to fully recover the loan. A borrower’s capacity to make such payments can be influenced by a wide range of factors including economic conditions, industry trends and management expertise. Polus has very limited (if any) influence over the

management of such businesses and is unlikely to accurately predict the level of default and losses experienced among such investments. Recent global events have led to more cautious investor behaviour and a general slowdown in new issuance in the CLO market, including of the type of subordinated junior debt and equity interests that are expected to form a substantial part of a CLO’s investment portfolio. To the extent a CLO manager’s strategy relies upon investment in the primary markets, a continuation or recurrence of such conditions could impede the CLO from achieving its investment objective. The leveraged lending market generally and the success of CLO vehicles’ investment activities in particular involve a significant degree of risk, and performance of CLO vehicles' investments will be affected by numerous factors that are not predictable or within the control of the manager. Such factors include a wide range of general economic and market conditions, political, competitive, and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. Furthermore, depending upon the investment strategies employed and market conditions, CLO vehicles may be adversely affected by unforeseen events involving such matters as changes in interest rates, changes in applicable laws or regulations, redemptions of securities, acquisition proposals, or difficult national and international political and socioeconomic circumstances. Changes in economic conditions, including, for example, interest rates, inflation rates, employment conditions, competition, technological developments, political and diplomatic events and trends, and tax laws can affect substantially and adversely the business and prospects of a Private Fund. None of these conditions is within the control of the CLO and no assurances can be given that the CLO will anticipate these developments. Polus’ strategies typically aim to exploit dislocations in the market value of assets. This often involves acquiring assets deemed undervalued, with the expectation of a longer-term recovery. However, market values can be influenced by a range of factors beyond Polus’ control, and a continued dislocation may persist. Asset values can also be volatile, and price volatility has increased notably in recent years. A materially adverse price move could force certain actions as defined within a trading strategy (such as “stop losses”) or the terms of third-party leverage. This could include a liquidation of collateral during turbulent market conditions, often at a significant discount to what we may consider representative long-term value. Legal Risk Many of the laws that govern private and foreign investment, equity securities transactions and other contractual relationships in certain countries, particularly in developing countries, are new and largely untested. As a result, Clients may be subject to a number of unusual risks, including inadequate investor protection, contradictory legislation, incomplete, unclear and changing laws, ignorance or breaches of regulations on the part of other market participants, lack of established or effective avenues for legal redress, lack of standard practices and confidentiality customs characteristic of developed markets and lack of enforcement of existing regulations. Furthermore, it may be difficult to obtain and enforce a judgment in certain countries in which assets of a Client are invested. There can be no assurance that this difficulty in protecting and enforcing rights will not have a material adverse effect on Clients and their operations.

Counterparty Risk Some institutions (including brokerage firms and banks) with which Clients will do business or to which securities will be entrusted for custodial and/or prime brokerage purposes, may encounter financial difficulties, fail or otherwise become unable to meet their obligations. In light of market turmoil, such financial institutions’ financial condition (as well as that of a Client) may be adversely affected and they may become subject to legal, regulatory, reputational and other unforeseen risks that could have a material adverse effect on the activities and operations of a Client. In the event of a bankruptcy or insolvency of such a counterparty, a Private Fund or segregated mandate could experience delays in liquidating an investment and significant losses, including the loss of that portion of a Client’s portfolio held by such a counterparty, which may arise as a result of a decline in the value of an investment during the period in which a Client seeks to enforce its rights, the inability to realize any gains on an investment during such period and significant fees and expenses incurred in enforcing its rights. A Client is subject to the risk that such counterparties may or may not have access to finance and/or assets at the relevant time and may fail to comply with their obligations under the relevant arrangements. Cybersecurity Risk Cybersecurity 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. Cyber-attacks and breaches of cybersecurity may lead to disruption of the operations of a Client, its general partner, investment manager, investments and service providers, and to loss of data and possible regulatory sanction. In particular, if unauthorized parties gain access to the investment manager’s or a service provider’s information and technology systems, they may be able to steal, publish, delete or modify private and sensitive information. In addition, a Client’s investment manager and administrator may communicate with prospective and/or existing investors via password-protected websites, email, fax and/or phone. The confidentiality, security and integrity of electronic communications cannot be guaranteed. Polus has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security.

Griffith (CRD #: 7429122) is a registered representative of Foreside, a registered broker-dealer with the SEC in the U.S. Mr. Griffith is fully seconded to Polus, and his role and responsibilities are provided to Polus in accordance with the agreements between the Adviser, PCMUS, and Foreside. Therefore, he is deemed a supervised person of Polus. Please see “Item 5: Fees and Compensation” for more detailed description of fee arrangement and potential conflicts of interest. d) Neither Polus, nor any of its officers or employees, is registered, or has an application pending to register, as a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. In all of these arrangements, Polus does not believe that its relationship with PCMUS will create any material conflicts of interest with Clients. All arrangements between Polus and PCMUS will be arm’s length agreements subject to market terms, and both Polus and PCMUS have policies in place to identify and mitigate or resolve any potential conflicts of interest with Clients. Certain Polus affiliates act as a general partner, managing member or in a similar position for Polus’ Private Funds. A full list of general partners can be found in Polus’ Form ADV Part 1 Section 7.A. The Private Funds do not have independent management and Polus selected the directors for the Private Funds. Although this arrangement gives Polus heightened control and discretion over the Private Funds, Polus seeks to manage any conflicts of interest by adhering to the investment strategy and investment allocation policy discussed in the governing documents of the Private Funds. Polus does not recommend or select other investment advisers for its Clients.

employees are not permitted to participate in or have a financial interest in Client transactions. Employees are subject to disciplinary actions and/or possible sanctions for a failure to comply with Polus’ Code of Ethics. Polus will provide a copy of the Code of Ethics to any Client or prospective Client upon request directed to compliance@poluscapital.com. Securities that Polus or a Related Person Has a Material Financial Interest 1.

Cross Trades

Polus may determine that it would be in the best interests of certain Clients to transfer a security from one Client to another (each such transfer, a “Cross Trade”) for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of the clients, or to reduce transaction costs that may arise in an open market transaction. If Polus decides to engage in a Cross Trade, Polus will determine that the trade is in the best interests of each Client involved in it and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those Clients. Polus generally executes Cross Trades with the assistance of a broker-dealer who executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a Cross Trade between two Clients may occur as an “internal cross”, where Polus instructs the custodian for the Clients to book the transaction at the price determined in accordance with Polus’ valuation policy. If Polus effects an internal cross, Polus will not receive any fee in connection with the completion of the transaction. 2.

Principal Transactions

To the extent that Cross Trades may be viewed as principal transactions due to the ownership interest in a Client by Polus or its personnel, the Investment Adviser will comply with the requirements of Section 206(3) of the Advisers Act, including that any such transactions will be considered on behalf of investors in such a Client and approved or disapproved by (i) an advisory board comprised of representatives of such investors or (ii) a committee consisting of one or more persons selected by Polus (or its affiliate), and any valuation approved by such a committee will be determined by an independent third party that has appropriate experience in providing such valuations.

Portfolio transactions for each Client will be allocated to brokers and dealers on the basis of numerous factors and not necessarily lowest pricing. Brokers and dealers may provide other services that are beneficial to Polus and/or certain of its Clients, but not beneficial to all Clients. Subject to best execution, in selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services, Polus may consider, among other things, the following: a) the credit rating and credit standing of the broker/counterparty; b) the broker/counterparty’s facilities, reliability and financial responsibility; c) the ability of the broker/counterparty to offer speedy and efficient execution in a broad range of securities and products; d) the provision by the brokers/counterparty of capital introduction, talent introduction, marketing assistance, consulting with respect to technology, operations and equipment, commitment of capital, access to company management and access to deal flow; e) transparency in pricing and whether the pricing offered is competitive by reference to other market participants; and f)

the credit lines, collateral and other transaction terms offered by the broker/counterparty.

Accordingly, the commission rates (or dealer markups and markdowns) charged to Clients by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers who may not offer such services. Polus need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Polus nor its Clients separately compensate any broker or dealer for any of these other services. Polus maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Polus does not engage in soft dollar arrangements and does not select brokers which charge higher commission and execution costs than obtainable from other brokers, on the basis of research services provided by that broker. Any research which Polus may receive from brokers is paid for directly in accordance with specific contract for services. Polus may re-charge some research cost to its Clients, as outlined in the offering documents. Neither Polus nor any related person receives client referrals from any broker-dealer or third party. Polus does not recommend, request or require that any Client transactions are executed through a particular broker. All Client transactions are executed on the basis of best execution. Polus provides discretionary investment management to certain Clients, including the Private Funds and, as such, it has discretionary authority for broker selection. Order Aggregation Polus may aggregate transactions on behalf of more than one Client when Polus has the opportunity to do so. If so, such transactions will be allocated to all participating Clients in a fair and

equitable manner. Consistent with each participating Client’s offering document or investment management agreement, Polus may aggregate orders for more than one Client to facilitate best execution, including negotiating more favorable prices, obtaining more timely or equitable execution, or reducing overall commission charges. If Polus does not aggregate orders when it has the opportunity to do so, it is possible that the costs to a Client whose order was not aggregated may be greater than if the order had been aggregated because, for example, aggregation would have resulted in a larger transaction size and lower transaction costs as a result. Pro-rata allocation is pursued when the size of the asset being purchased provides for an equal opportunity to all participating Client accounts to share in the asset based on each Client’s assets under management without creating odd-lots for the other Clients, though it will also depend on the size of the position, liquidity, compliance with portfolio tests, leverage, cash availability and cash needs, and whether the Client is new and in a “ramp-up”. Where a trade is allocated in a manner other than as described above, Polus will ensure that the chosen means of allocation is documented prior to completion of the order.

Client accounts are monitored and reviewed by the relevant investment team under the supervision of the Head of European Leveraged Credit and the Chief Investment Officer – Opportunistic Credit, with support from the Portfolio Managers, Traders, Analysts as well as the Risk team. A review of a Client account may also be triggered by any unusual activity or special circumstances. For CLOs, reviews assess overall portfolio strategies, performance and compliance with investment guidelines in the relevant CLO’s governing documents, including any investment restrictions and other tests, such as coverage tests, portfolio profile tests, and/or collateral quality tests. In the Private Funds no investor is given a greater level of transparency than any of the other investors. The reports are required to be provided quarterly or monthly and provide details of the assets included in the portfolio, the performance of the portfolio and other relevant information. The trustee of each CLO provides investors with monthly and/or quarterly written reports as described in the governing documents for each CLO. Polus will also furnish certain reports to the trustees of the CLOs, as required by the governing documents.

Griffith, provides services to Polus as described in more detail and in accordance with the agreements between the Adviser, PCMUS, and Foreside. Please see “Item 5: Fees and Compensation” and “Item 10: Other Financial Industry Activities and Affiliations” of this brochure for more detailed description of fee arrangement and potential conflicts of interest. Polus does not receive any economic benefit or compensation for the provision of investment advice to any non-Clients.

Under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”), Polus is deemed to have custody over certain Private Funds due to Polus or related person acting as a general partner, managing member or in a similar position for Polus’ Private Funds. However, Polus is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to such Private Funds because it complies with the provisions of the so-called “Pooled Vehicle Annual Audit Exception”, which, among other things, requires that such Private Funds be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that such Private Funds distribute their audited financial statements to all investors within 120 days of the end of its fiscal year. As an offshore adviser, Polus is not required to comply with the requirements of the Custody Rule with respect to its non-U.S. domiciled Private Funds. Polus does not have custody over any of its segregated mandate accounts.

In limited circumstances, Polus may refrain from proxy voting where Polus believes that voting would be inappropriate, taking into consideration the cost of proxy voting and the anticipated benefit to Clients. Generally, Clients may not direct Polus’ vote in a particular situation. Conflicts of interest may arise between the interests of Clients on the one hand and Polus or its affiliates on the other hand. If Polus determines that it may have, or be perceived to have, a conflict of interest when proxy voting, Polus will vote in accordance with Polus’ proxy voting policies and procedures. Investors may obtain a copy of Polus’ proxy voting policies and procedures and how proxies were voted on behalf of its Clients on the website, or by submitting a request to the Chief Compliance Officer, whose contact information can be found on the cover page of this brochure.