Owl Creek Asset Management, L.P.: investment adviser

In connection with providing investment management services to its clients, Owl Creek has been appointed as investment manager with discretionary trading authority. Additional detailed information about Owl Creek is provided below, including information about Owl Creek's advisory services, investment approach, personnel, affiliations and brokerage practices. The Investment Manager serves as the investment manager to six investment partnerships organized under the laws of the State of Delaware: Owl Creek I, L.P. ("Owl Creek I"), Owl Creek II, L.P. ("Owl Creek II"), Owl Creek Credit Opportunities Fund, L.P. (the “Credit Domestic Fund,”), the Owl Creek Special Situations Fund, L.P, (the “OCSS Fund”), the Owl Creek Credit Solutions Fund, L.P. (the “OC Solutions Fund”), and the Owl Creek Aviation Opportunities Fund, L.P. (the “Owl Creek Aviation Fund”, and collectively with Owl Creek I, Owl Creek II, Credit Domestic Fund, OCSS Fund and the OC Solutions Fund, the "U.S. Funds"). Owl Creek Advisors, a limited liability company organized under the laws of the State of Delaware (“OCA”) affiliated with the Investment Manager, serves as the general partner of Owl Creek I, Owl Creek II, and the OCSS Fund. Owl Creek Credit Opportunities Advisors, LLC, a limited liability company organized under the laws of the State of Delaware (“OCCOA”) affiliated with the Investment Manager, serves as the general partner of the OC Solutions Fund. Owl Creek Aviation GP, LLC, a limited liability company organized under the laws of the State of Delaware affiliated with the Investment Manager, serves as the general partner of the serves as the general partner of the Owl Creek Aviation Fund (“OCAGP” together with OCA and OCCOA, the "General Partner"). OCA is the managing member of both OCCOA and OCAGP. Interests in Owl Creek I, (collectively the “3(c)(1) Funds”) are offered on a private placement basis, and in reliance on Section 3(c)(1) of the Investment Company Act of 1940, as amended (the "Company Act"), to persons who generally are "accredited investors" as defined under the Securities Act of 1933, as amended (the "Securities Act"), and subject to certain other conditions, which are set forth in the offering documents for the applicable 3(c)(1) Funds. The interests in Owl Creek II, Credit Domestic Fund, the OCSS Fund, the OC Solutions Fund, and the Owl Creek Aviation Fund are offered on a private placement basis, and in reliance on Section 3(c)(7) of the Company Act, to persons who generally are "accredited investors" as defined under the Securities Act and "qualified purchasers" as defined under the Company Act, and who are subject to certain other conditions, which are set forth in the offering documents for the applicable Funds. The Investment Manager is also the investment manager to the following investment funds organized under the laws of the Cayman Islands: Owl Creek Overseas Fund, Ltd. ("Owl Creek Overseas"), Owl Creek Credit Opportunities Fund, Ltd. (“Credit Offshore Fund,” and together with Owl Creek Overseas, the "Offshore Funds"). The Offshore Funds together with the U.S. Funds, the Credit Intermediate Fund (as defined below) and the Master Funds (as defined below) are each referred to as a “Fund” and collectively, as the "Funds". Shares in the Offshore Funds are generally offered to persons (x) who are not "U.S. Persons," as defined under Regulation S of the Securities Act, or who are tax-exempt U.S. Persons (or entities substantially comprised of tax-exempt U.S. Persons) on a private placement basis, and (y) who are subject to certain other conditions, which are fully set forth in the offering documents for the Offshore Funds.

To effect their respective investment objectives, Owl Creek Overseas invests its assets in Owl Creek Overseas Master Fund, Ltd. ("Owl Creek Overseas Master Fund"), and the Domestic Credit Fund invests its assets in Owl Creek Credit Opportunities Master Fund, L.P. (the “Owl Creek Credit Master Fund”) and the Offshore Credit Fund invests its assets in Owl Creek Credit Opportunities Intermediate Fund, L.P. (the “Credit Intermediate Fund”), a Cayman Islands limited partnership, which in turn invests in the Owl Creek Credit Master Fund (Owl Creek Overseas Master Fund, and Owl Creek Credit Master Fund, each, a "Master Fund" and collectively, the "Master Funds"). Each of the Master Funds is a Cayman Islands exempted company, except Owl Creek Credit Master Fund which is organized as a Cayman Islands limited partnership. The Investment Manager also serves as the investment manager to each Master Fund and the Intermediate Fund. Owl Creek Advisors serves as the management company to Owl Creek Overseas Master Fund and in that capacity has the overall responsibility for the investment strategy of such Master Fund, subject to the policies and control of the board of directors of such Master Fund. In such capacity, Owl Creek Advisors is referred to herein as the "Manager." Owl Creek Advisors also serves as the general partner of the Owl Creek Credit Master Fund and the Intermediate Fund. The Investment Manager may advise managed accounts and other Clients in the future. Owl Creek I, Owl Creek II, Owl Creek Overseas, and Owl Creek Overseas Master Fund, are referred to herein as the "Flagship Funds." The Domestic Credit Fund, Offshore Credit Fund, Credit Intermediate Fund, and Owl Creek Credit Master Fund are referred to herein as the “Credit Funds.” The Flagship Funds, Credit Funds, the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund are collectively referred to herein as the “Clients” (and each such Fund shall be referred to as a “Client”). OCSS is presently not seeking additional investment as its full capital has been drawn and certain investments realized. The OC Solutions Fund is seeking additional capital, and the Owl Creek Aviation Fund is closed to additional investors. Owl Creek has full discretionary authority with respect to investment decisions on behalf of each Client. Owl Creek’s advice with respect to each Client is tailored according to each Client’s investment objectives, guidelines, and requirements as set forth in each Client’s respective offering memoranda, investment management agreement, sub-advisory agreements, or investment guidelines, as the case may be. Owl Creek does not participate in any Wrap Fee Programs. New Classes/Side Letter Agreements Owl Creek and the Funds may establish new classes of shares/interests and has issued other classes of shares/interests to, and may and has entered into "side letter" agreements with, certain investors which terms differ from the shares/interests generally offered to investors with respect to, among other things, the Incentive Allocation (as defined below) and Management Fee (as defined below), redemption and withdrawal rights (including more frequent redemption or withdrawal dates), informational rights and other rights. Owl Creek and/or a Fund may establish new classes of shares/interests or enter into "side letter" arrangements without providing prior notice to, or receiving consent from, existing investors. The terms of such classes and "side letters" will be determined by Owl Creek and/or such Fund in their sole discretion. Ownership and AUM

Owl Creek was founded in 2001 and is primarily owned by Jeffrey Altman (“Altman”). As of December 31, 2025, Owl Creek managed approximately $1.66 billion (including all withdrawals and redemptions effective as of such date) on a discretionary basis, on behalf of 11 clients. Assets under management (“AUM”) 1 reflect net assets invested by external investors and our related parties in our Funds, plus any unfunded commitments. “Regulatory Assets Under Management” as of the same date was $2.46 billion (including withdrawals effective as of such date). Regulatory Assets Under Management (as defined by the SEC, “Reg. AUM”) reflect the Balance Sheet value of Gross Assets plus any unfunded commitments. Gross exposure (being the market value of long and short positions) may exceed Regulatory Assets under Management. Unfunded commitments included in AUM and Reg. AUM were $92 million at December 31, 2025.

The OCSS Fund is not currently being offered to investors, but the management fee terms applicable in respect of the existing investors in the OCSS Fund are set forth in that Fund’s limited partnership agreement. The OC Solutions Fund is currently being offered to investors and generally pays Owl Creek at the beginning of each quarter a Management Fee equal to 0.3125% (1.25% annualized) of a limited partner's invested capital for such quarter (prorated for partial periods and subject to change in the event of certain dispositions and write-downs). The Owl Creek Aviation Fund is not currently being offered to investors and generally pays Owl Creek at the beginning of each quarter a Management Fee equal to 0.175% (0.70% annualized) of a limited partner's invested capital for such quarter (prorated for partial periods and subject to change in the event of certain dispositions and write-downs). With respect to all of the U.S. Funds, a pro rata portion of any Management Fee paid in advance will be repaid by Owl Creek to the relevant Fund and distributed to any limited partner that is permitted to withdraw prior to the end of a quarter. For the purpose of calculating the Management Fee, a limited partner's capital account shall include the fair value, as determined by Owl Creek, of certain investments which Owl Creek believes either lack a readily assessable market value or should be held until the resolution of a special event or circumstance ("Special Investments") in which such limited partner has an interest. For the Flagship Funds and the Credit Funds if, after giving effect to a withdrawal, a capital account would be completely withdrawn from a U.S. Fund except for its interest in one or more Special

We are using a definition here consistent with “Net assets under management” per the Form PF Glossary of Terms

Investments, the General Partner may determine to reserve or hold back a portion of the proceeds with respect to such withdrawal that is required, in its reasonable discretion, to pay for the Management Fees expected to be earned over the life of the Special Investments in which such capital account has an interest (the "Management Fee Reserve"). The Management Fee Reserve is not segregated from the applicable Fund’s assets and does not earn interest. Any remaining amount of the Management Fee Reserve will be distributed to the holder of such capital account together with the withdrawal proceeds upon the realization of such Special Investments. If the Management Fee Reserve is insufficient, the relevant U.S. Fund will bill the holder of such capital account quarterly for Management Fees attributable to the Special Investments in which such capital account has an interest. If the full amount of an invoice is not paid by the date provided on such invoice, the General Partner may, in its sole discretion, reduce the amount of any proceeds paid with respect to such Special Investments by an amount equal to the unpaid invoice, together with interest thereon at a market rate, as determined by the General Partner. Owl Creek may, in its discretion, elect to reduce or waive the Management Fee with respect to any limited partner of the U.S. Funds. Owl Creek typically waives the Management Fee with respect to Owl Creek affiliates. Management fees are deducted from investors' accounts. U.S. Funds—Incentive Allocation The General Partner is generally entitled to an amount (the "Incentive Allocation") equal to 20% of the net capital appreciation of each U.S. Fund (excluding the OCOPP Funds’, the OC Solutions and the Owl Creek Aviation Fund Incentive Allocation – as described below). Except as provided below with respect to Special Investments, net capital appreciation includes both realized gains and losses and unrealized gains and losses of securities held in each U.S. Fund's portfolio. Generally, any net capital depreciation in a fiscal year allocated to any limited partner is carried forward so that no Incentive Allocation is borne by such limited partner unless the losses have been recouped, subject to certain adjustments. A portion of each applicable U.S. Fund's assets may be invested in Special Investments that may be maintained in special situation sub-accounts, in which case they are generally not subject to any Incentive Allocations until a gain is realized (or deemed realized). Such Special Investments generally are subject to the Management Fees described above and will be carried at fair value, as determined by the General Partner, for the period that they are maintained in such special sub-accounts. The Incentive Allocation in respect of the OC Solutions Fund will generally be equal to 15% of net profits after an 8% hurdle is achieved and investor capital is returned. The Incentive Allocation in respect of the Owl Creek Aviation Fund will generally be equal to 10% of net profits after a 6% hurdle is achieved and investor capital is returned. The General Partner may, in its discretion, elect to reduce or waive the Incentive Allocation with respect to any limited partner of the U.S. Funds, including, but not limited to, any affiliate of the General Partner. The General Partner reserves the right to waive or impose different fees or allocations or otherwise modify the fee or allocation arrangements of an existing investor in a U.S. Fund with the consent of such investor. In addition, each U.S. Fund reserves the right to impose different fees or allocations on future investors. In exchange for increased fees or allocations, such investors may receive more frequent withdrawal dates and less notice required upon withdrawal than other investors in such Fund. Owl Creek has provided certain investors in the U.S. Funds other significant rights, such as

reduced fees, more frequent liquidity terms, access to information and capacity rights, which are not offered generally to other investors in the U.S. Funds. See "New Classes/Side Letter Agreements" in Item 4. Offshore Funds—Management Fees With respect to Owl Creek Overseas, the Fund generally pays Owl Creek a Management Fee, payable quarterly (prorated for partial periods), in advance, equal to 0.375% (1.5% annualized) for Owl Creek Overseas of the NAV of each series of shares as of the beginning of the quarter prior to any accrual for Incentive Allocation. With respect to the Offshore Credit Fund, the Credit Offshore Fund generally pays Owl Creek a Management Fee, payable quarterly (prorated for partial periods), in advance, equal to 0.375% (1.5% annualized) of the NAV of each series of shares of the Fund as of the beginning of the quarter. With respect to all of the Offshore Funds, a pro rata portion of any Management Fee paid in advance will be repaid by Owl Creek to the relevant Fund and distributed to any shareholder that is permitted to redeem prior to the end of a quarter. Owl Creek may designate an investment made by Owl Creek Overseas and / or the Offshore Credit Fund as a Special Investment, in which case, a pro rata portion of each series of shares will be automatically exchanged by way of redemption and issuance of a new class of shares (generally Class C Shares). In calculating the Management Fees paid, these shares are valued at fair value. If, after giving effect to a redemption, a shareholder only owns shares relating to Special Investments, the relevant Fund may determine to reserve or hold back a portion of the proceeds with respect to such redemption in order to establish a Management Fee Reserve to pay for the Management Fees expected to be earned over the life of such Special Investments. The Management Fee Reserve is not segregated from the applicable Fund’s assets and does not earn interest. Any remaining amount of the Management Fee Reserve will be distributed to the Fund, and in turn, to the shareholder together with the redemption proceeds upon the realization of such Special Investments. If the Management Fee Reserve is insufficient, the relevant Offshore Fund will bill the shareholder quarterly for Management Fees attributable to the Special Investments attributable to such shareholder. If the full amount of an invoice is not paid by the date provided on such invoice, such Offshore Fund may, in its sole discretion, reduce the amount of any proceeds paid with respect to such Special Investments by an amount equal to the unpaid invoice, together with interest thereon at a market rate, as determined by such Offshore Fund. In the sole discretion of Owl Creek, the Management Fee may be reduced or waived with respect to any shareholder of the Offshore Funds. Owl Creek typically waives the Management Fee with respect to Owl Creek affiliates. Management fees are deducted from investors' accounts. Offshore Funds—Incentive Allocation Generally, at the end of the fiscal year of each of the Offshore Funds an Incentive Allocation equal to 20% of the net realized and unrealized appreciation (taking into account gains and losses with respect to realized or deemed realized Special Investments allocated during such year) in the NAV of each series of shares of the relevant Master Fund corresponding to a series of shares of the

corresponding Offshore Fund during each fiscal year (after adjustments for any redemption of shares in such series and accruals for the Incentive Allocation made with respect to redemptions made during such year (if any) and after taking into account the Management Fee and any net expenses that are charged at the Offshore Fund level and are not otherwise reflected in such Master Fund's NAV) will be reallocated from the NAV of such Master Fund series to the NAV of the Class M Shares of such Offshore Fund (which are held by the Manager); provided, however, that an Incentive Allocation will only be made with respect to the net realized and unrealized appreciation in the NAV of a series of shares of such Master Fund in excess of its Prior High Net Asset Value. The "Prior High Net Asset Value" of a series of shares of a Master Fund is the NAV of that series immediately following, and after reduction for, the most recent calculation of the Incentive Allocation with respect to such series (or if no Incentive Allocation has yet been determined with respect to such series, the NAV of the series immediately following its initial offering). The Prior High Net Asset Value of a series will be adjusted for redemptions (including redemptions of any shares of a series exchanged for Class C Shares) and distributions (excluding any distributions relating to the Management Fee) and for expenses charged at the corresponding Offshore Fund level (with respect to Owl Creek Overseas Master Fund only) made subsequent to the date on which the last Incentive Allocation with respect to such series was determined. Special Investments, represented by Class C Shares, generally are not subject to Incentive Allocation until a gain is realized (or deemed realized). With respect to the Offshore Credit Fund, at the end of each fiscal year of the Intermediate Fund (December 31), the General Partner will generally allocate to the General Partner an Incentive Allocation equal to 20% of the net realized and unrealized appreciation (taking into account gains and losses realized or deemed realized by Owl Creek with respect to Special Investments) allocated to the Intermediate Fund capital account corresponding to each series of shares of the Offshore Credit Fund (each, a “Series Capital Account”) for such fiscal year (after adjustments for any redemption of shares in such series and accruals for the Incentive Allocation made with respect to redemptions made during such year (if any) and after taking into account the Management Fee and any net expenses that are incurred at the Offshore Credit Fund level that are not otherwise reflected in the Intermediate Fund’s net asset value). The Intermediate Fund maintains a memorandum loss recovery account (a “Loss Recovery Account”), sometimes called a “high water mark,” for each Series Capital Account. For each fiscal year, each Loss Recovery Account is debited with the aggregate net capital depreciation, if any, allocated to such Series Capital Account for such fiscal year (taking into account gains and losses realized or deemed realized from Special Investments, Special Investment Income and expenses of the Offshore Credit Fund) and credited, but not beyond zero, with the aggregate net capital appreciation, if any, allocated to such Series Capital Account for such fiscal year (taking into account gains and losses realized or deemed realized from Special Investments, Special Investment Income and Feeder Expenses). The General Partner will not be allocated any Incentive Allocation with respect to a Series Capital Account until such Series Capital Account has recovered any negative balance in its Loss Recovery Account. The amount which must be recovered will be adjusted for withdrawals of capital. The aggregate incentive allocation allocated to Owl Creek (“Incentive Allocation”) is deducted from investors' series of shares.

In the sole discretion of Owl Creek or the Manager (as applicable), the Incentive Allocation may be reduced or waived with respect to any shareholder of Owl Creek Overseas, or the Offshore Credit Fund, including, but not limited to, any affiliate of Owl Creek. Owl Creek and the Manager reserve the right to waive or impose different fees or allocations or otherwise modify the fee or allocation arrangements of an existing investor in an Offshore Fund with the consent of such investor. In addition, Owl Creek and the Manager reserve the right to impose different fees or allocations on future investors in the Offshore Funds. In exchange for increased fees or allocations, such investors may receive more frequent redemption dates and less notice required upon redemption than other investors in such Fund. Owl Creek has provided certain investors in the Offshore Funds other significant rights, such as reduced fees, enhanced liquidity, and access to information and capacity rights, which are not offered generally to other investors in the Offshore Funds. See "New Classes/Side Letter Agreements" in Item 4. Owl Creek and its personnel may invest in the Funds and neither Owl Creek nor its personnel are subject to the Incentive Allocation or Management Fees. The Flagship Funds have entered into agreements with certain investors whereby such investors have agreed to be subject to a redemption fee, which will be retained by the relevant Master Fund for the benefit of the non-redeeming Master Fund shares, in the event such investors redeem on certain dates. Expenses As fully described in each Fund's offering documents, each Fund bears expenses related to its operations, which may include, without limitation, investment related expenses, whether or not such investments are consummated, such as brokerage commissions (see the Brokerage Practices section below for more information), research expenses, interest on margin accounts and other indebtedness, borrowing charges on securities sold short, custodial fees, bank service fees, withholding and transfer fees, taxes, clearing and settlement charges, professional fees (including, without limitation, expenses of attorneys, consultants and experts) relating to investments, fees and other expenses related to the purchase, sale or transmittal of Fund investments, expenses related to risk management and reporting provided by third-parties, investment, expenses associated with regulatory filings related to the applicable Funds and their portfolios (including, without limitation, Section 13(D) and Section 13(G) filings and Section 16 reporting and filings), insurance costs incurred with the Funds’ business (including, without limitation, acquiring and maintaining D&O and E&O insurance for the Funds, the Board of Directors of the Offshore Funds, and Owl Creek and their respective affiliates), travel expenses related to investments (including the costs of travel, lodging and meals), legal, accounting, valuation and pricing, audit and tax preparation expenses, fees of one or more third party administrators, Management Fees, fees and expenses relating to software tools, programs and other technology utilized in managing the Funds, including operations, risk management and trading related software (such as trade order management software), corporate licensing fees, organizational and offering expenses, costs related to errors and omissions of directors and officers insurance, and other similar expenses related to such Fund and any extraordinary expenses as the General Partner (for the U.S. Funds) or the Board of Directors (for the Offshore Funds) determines their sole discretion. Brokerage and research expenses of a Fund may be paid for through the use of "soft dollars" (see the Brokerage Practices section below for

more information). The Firm has implemented policies and procedures to seek to ensure that investment-related and research expenses attributable to one or more Clients or their investments are allocated in a fair and equitable manner. Since certain investment and research expenses may benefit these account as well as the Funds, the Firm’s policy is to bear a portion of such expenses to the extent they apply to such account’s investments. From time to time, the Funds may invest in unaffiliated registered mutual funds and/or exchangetraded funds, which charge management fees and expenses, as described in such fund's prospectus. Owl Creek generally bears its own normal and recurring operating expenses incurred in connection with the investment and other management services that it provides to Clients, including office space and utilities, telephone, secretarial, clerical and other personnel services and salaries. For those expenses which are “mixed use” — meaning incurred for the benefit of both the Funds and the Firm — Owl Creek bears the portion of expenses which are not Fund expenses under each Fund’s applicable offering memorandum and governing agreements. Owl Creek and its personnel can be expected to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of its Clients that will neither be subject to an offset against Management Fees or other compensation payable by the Clients nor will otherwise be shared with Clients or their investors. For example, airline travel or hotel stays incurred as an investment expense may result in cash rebates, “miles”, credit card “points”, or credits in loyalty or status programs, and such benefits and/or amounts will, whether or not de minimis or difficult to value, inure exclusively to the Firm and/or such personnel (and not to Clients or investors) even though the cost of the underlying service may be borne by the Clients. At the discretion of the General Partner (for the U.S. Funds) or the Board of Directors (for the Offshore Funds), any investment expense relating specifically to a Special Investment shall be charged against the capital accounts or shares of the investors participating in such Special Investment in proportion to their respective participating percentage interests therein. In the event an investor has withdrawn its investment and continues to have an interest in any Special Investment(s), the General Partner (for the U.S. Funds) or the Board of Directors (for the Offshore Funds) may determine to hold back a portion of the proceeds with respect to such withdrawal or redemption, as applicable, that is required, in its reasonable discretion, to pay for the expenses expected to be incurred over the life of such Special Investment(s). Upon the realization or deemed realization of all such Special Investments, any unapplied holdback amounts will be distributed to such investor. The Firm has implemented policies and procedures to seek to ensure that investment-related and research expenses attributable to one or more clients or their investments are allocated in a fair and equitable manner consistent with its fiduciary duties to its clients. The Firm generally considers the facts and circumstances associated with each investment and research expense in determining how to allocate an expense among applicable clients and the Firm, if applicable.

Performance-based compensation arrangements may also create an incentive for an investment adviser to recommend investment opportunities that may be riskier or more speculative given the adviser’s potentially greater participation in upside performance than would be the case in fixed asset-based fee arrangements. However, Owl Creek has adopted investment allocation policies designed to ensure that investments are suitable for Clients and all Clients are treated fairly and equitably and to prevent these conflicts of interest from influencing the allocation of investment opportunities among Clients. The Flagship Funds, Credit Funds, the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund are subject to both forms of compensation. The side-by-side management of these types of funds may create a potential conflict, as more compensation may be payable in respect of accounts subject to both fixed fees and performance-based compensation arrangements. However, Owl Creek has adopted investment allocation policies and procedures designed to allocate investment opportunities among Clients (including the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund, where consistent with their investment objectives and guidelines) to ensure that investments are allocated in a fair and equitable basis over time among all suitable Clients, regardless of the fee and compensation arrangements.

Additional investments in the Funds by existing investors generally must be in the minimum amount of $100,000. Investors in the Funds are persons who generally are (x) "accredited investors" as defined under the Securities Act or (y) not U.S. Persons (as defined under Regulation S of the Securities Act). In addition, investors in Owl Creek II, Owl Creek Overseas, the Domestic Credit Fund Offshore Credit Fund, OCSS Fund, OC Solutions Fund and the Owl Creek Aviation Fund who are U.S. Persons (as defined under Regulation S of the Securities Act) must generally be "qualified purchasers" as defined under the Investment Company Act or have an exemption under that Act making them eligible to invest.

Owl Creek may offer any advisory services, engage in any investment strategy, and make any investment, including any not described in this Brochure, that Owl Creek considers appropriate, subject to each Client's investment objectives and guidelines. The investment strategies Owl Creek 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. Investment Strategies and Methods of Analysis The investment objective of the Flagship Funds is to seek above average returns through an opportunistic event-driven value strategy. Owl Creek generally employs an investment strategy for the Flagship Funds, which includes, among other strategies, (i) event-driven investing, (ii) fundamental, value driven long/short equities, and (iii) long/short credit incorporating long distressed investments. Owl Creek analyzes each potential investment using a “bottom-up” analysis. The conclusions reached from this “bottom-up” approach are used to purchase or sell short a variety of financial instruments including, but not limited to, listed and unlisted common stocks, preferred stocks, convertible securities, American Depository Receipts, SPACS, public and private debt issues (including bank loans and trade claims), rights, warrants, put and call options, swaps, forward contracts, when-issued securities and other derivatives, including futures contracts. In addition to investing directly, the Funds may invest indirectly from time to time through special purpose vehicles. Owl Creek may use leverage in connection with the Clients' investment program. Generally, leverage is utilized as determined by Owl Creek, subject to applicable investment guidelines and legal and regulatory limitations. Owl Creek may invest a portion of the Clients' assets in registered investment companies, including, but not limited to, exchange-traded funds and closed-end funds, subject to Company Act limitations and applicable investment guidelines. Advisers to such funds charge a management fee and performance compensation in addition to fees charged by Owl Creek. The investment objective of the Credit Funds is to generate positive absolute returns, while minimizing the risk of loss of principal. The Credit Funds seek to achieve this investment objective through opportunistic investments across the credit spectrum. Owl Creek generally employs a fundamental, value investment approach in selecting investments on behalf of the Credit Funds. Owl Creek generally utilizes a fundamental, “bottom-up” investment process. The Credit Funds focus on various credit-related investment strategies, including distressed, eventdriven and long-short investment strategies. The Credit Funds seek to exploit the mispricing of securities and other instruments via both long and short positions. The Credit Funds invest primarily in bank debt, including revolving credit facilities, bridge financings, debtor-in-possession financings, corporate bonds, including high-yield debt, receivables and trade claims, sovereign debt, and credit default swaps and other credit-related derivatives. The Credit Funds may also invest in aviation leasing opportunities, futures and forward contracts, options, and convertible securities, preferred stock and equities of private and public issuers, SPACS, litigation financings, as well as asset-backed securities, mortgages, loans, and real estate and real-estate related securities.

A material portion of the Credit Funds’ portfolio is comprised of illiquid investments that are not designated as Special Investments and are classified as Level 3 assets (i.e., assets whose fair value is determined using significant unobservable inputs). Of these, many relate to aviation-related leasing opportunities in aircraft engine leasing to a broad range of international airlines and limited U.S. airlines. Other Level 3 assets may also include litigation claims, certain private investments that arose from historic restructurings (but incorporate a broad range of debt or equity instruments listed above), or other Credit Fund investments. A large proportion of Level 3 assets are subject to periodic external independent third party valuations. The investment program of the OCSS Fund is to invest in investments that are also made by the Flagship Funds and/or Credit Funds if Owl Creek determines, in its sole discretion, that (a) such other funds have acquired, in the aggregate, an allocation of such investments that is appropriate for such other funds at such time and (b) such investments can be acquired at attractive prices relative to Owl Creek’s assessment of the applicable investment’s potential for long-term appreciation prior to the end of the OCSS Fund’s investment period, provided that Owl Creek may also determine, in its discretion, to allocate investments to other Clients, to the extent that it determines in its sole discretion, that such other Clients have additional capacity for such investments. The investment objective of the OC Solutions Fund is to create value by employing a global, valueoriented approach to event-driven and opportunistic credit investments with a focus on distressed opportunities, event-driven credit, litigation, liquidations, and hard-asset leasing opportunities. The investment objective of the OC Solutions Fund may have some overlap with other funds managed by Owl Creek, in particular the Credit Funds. The Owl Creek Aviation Fund seeks to generate attractive risk-adjusted returns through the acquisition and leasing of commercial aviation engines and related hard assets. The Fund focuses primarily on acquiring engines that are already on lease, or can be promptly leased, to creditworthy counterparties. Such counterparties are usually international airlines. The strategy emphasizes engines with remaining greentime, enabling the Fund to generate recurring contractual lease payments and maintenance reserve income while targeting asset disposition prior to major maintenance events. Investments may be structured through special purpose vehicles and may utilize asset-level leverage, subscription facilities, and other financing arrangements. The investment objective of the Owl Creek Aviation Fund has overlap with other funds managed by Owl Creek, in particular the Credit Funds and the OC Solutions Fund. Event Driven Transactions: Across both distressed debt and equities, both long and short, Owl Creek will pursue opportunities that are event driven in nature. It is the belief of Owl Creek that mispriced securities are most abundant in situations where a company or industry is undergoing a large, material change. Furthermore, securities which have a risk/reward profile which is dependent on the outcome of a certain situation will have some lesser amount of overall market exposure as a result, which we consider important to generate above average returns. Some examples of event driven situations include restructurings, mergers, asset injections, recapitalizations, rights offerings, divestitures and spin-offs, post-bankruptcy equities, litigation plays, potential changes in laws and regulations, and situations where an activist investor is trying to unlock value buried in a company. Owl Creek may also play an activist role if in doing so it believes it will help a particular security realize its full

value, but this will be a secondary alternative as the primary objective is to be a passive long-term investor. Long/Short Equities: Owl Creek typically takes positions in equity securities of companies that Owl Creek has identified as undervalued (long equity positions) and overvalued (short equity positions). Owl Creek generally will purchase equity securities of companies with strong long-term fundamentals when the securities can be purchased at a discount to the perceived present value of a future stream of cash flows to the stockholder, or which in other ways represent assets with an attractive risk/reward profile. As Owl Creek focuses on the long-term cash generating potential of companies, it will seek to take advantage of price volatility caused by shorter-term concerns, such as temporarily disappointing financial performance, and purchase equity securities at attractive levels. Alternatively, Owl Creek usually will short equity securities of overvalued companies when an identifiable catalyst exists for eliminating the spread between price and fair value. Research, Analysis, Sources of Information: To determine whether a specific investment meets the Clients' investment guidelines, the Investment Manager typically performs extensive financial analysis of the company's underlying business fundamentals. The Investment Manager does research which may include making a determination of the company's competitive position, financial needs, liquidity, industry prospects as well as a liquidation value analysis. The Investment Manager may do an analysis of the company's financial statements, including a comparative analysis of margins and changes in balance sheet items in comparison with the company's competitors. The analysis of both equity and debt may include discounted cash flow analysis and centers on absolute (not relative) value. The Investment Manager also considers low cash flow multiples with solid long-term fundamentals. The Investment Manager looks for drivers or catalysts that will serve to close the value gap within the investment time horizon, which will usually be within a range of nine to twenty-four months. Owl Creek utilizes many sources of information in its analyses of investments. These sources include, but are not limited to, financial filings; business, economic, financial and other publications; trade journals; third-party data services; outside research; and one-on-one conversations with company management teams, suppliers, customers, end users and sector specialists, as well as lawyers, lobbyists and academic specialists. In addition, Owl Creek may employ third-party consultants, other investment managers and other third parties to provide it with fundamental and technical research, including, but not limited to, information regarding various markets, industries, assets and companies. Risk of Loss The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Funds. These risk factors include only those risks Owl Creek believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by Owl Creek. All investing involves a risk of loss that clients should be prepared to bear. The investment strategies offered by Owl Creek could lose money over short or long periods of time. Identifying undervalued securities and other assets is difficult, and there are no assurances that Owl Creek's

investment strategies will succeed. Furthermore, Clients may be forced to hold such investments for a substantial period of time (e.g., Special Investments in the case of certain Funds) before realizing any anticipated value. Owl Creek cannot give any guarantee that it will achieve a Client’s investment objectives or that any Client will receive a return of its investment. Investors should ultimately refer to the Funds’ respective offering documents for which Owl Creek provides sub-advisory services for detailed risk disclosures that specifically address risks of each Client's investment strategies, methods of analysis, and/or particular types of securities recommended. Below is a summary of potentially material risks for each significant Owl Creek investment strategy used, the methods of analysis used, and/or the particular type of security recommended. Please note that Owl Creek's use of the term "investor" in this section may refer to either a limited partner in a U.S. Fund or a shareholder in an Offshore Fund.

Risk of Loss. No guarantee or representation is made that the Funds’ investment programs, including the investment objective, diversification strategies or risk monitoring goals, will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will not be incurred. Past investment results of the Investment Manager (or investments otherwise made by the investment professionals of the Investment Manager) are not necessarily indicative of their future performance.

General Investment and Trading Risks - Clients invest in equity securities and other financial instruments using investment techniques with significant risk characteristics. The Clients’ investment programs utilize such investment techniques as short sales, leverage, options, swaps and other derivatives investments, including futures contracts, which practices can, in certain circumstances, maximize the adverse impact to which the Clients may be subject.

Dependence on Key Individuals. The success of the Funds depends upon the ability of Mr. Altman and Mr. Daniel Krueger to develop and implement investment strategies that achieve the Partnership's investment objectives. If Mr. Altman and/or Mr. Krueger were to become unable to participate in the management of the Funds, the consequences to the Funds would be material and adverse.

Misconduct or Errors of Personnel of the Investment Manager and of Third-Party Service Providers. Each of the Funds relies on personnel of the Investment Manager and its affiliates, counterparties and other service providers. Accordingly, risks associated with errors by such personnel are inherent in the business and operations of such Fund. Misconduct by such personnel could cause significant losses to a Fund and may include binding a Fund to transactions that are not properly authorized, that present unacceptable risks or that conceal unsuccessful investment activities (which may result in unknown and unmanaged risks or losses). Losses could also result from misconduct by such personnel, including, for example, failing to recognize trades and misappropriating assets. In addition, such personnel may improperly use or disclose confidential information.

Leverage and Financing Risk - The Investment Manager uses leverage in connection with the Clients' investment programs. Accordingly, Clients may pledge their securities in order

to borrow additional funds for investment purposes. Clients may also leverage their investment return with options, commodity futures contracts, short sales, swaps, forwards and other derivative instruments. The amount of borrowings which Clients may have outstanding at any time may be substantial in relation to their capital. While leverage presents opportunities for increasing Clients' total returns, it has the effect of potentially increasing losses as well. Accordingly, any event which adversely affects the value of an investment by the Clients would be magnified to the extent Clients are leveraged. The cumulative effect of the use of leverage by Clients in a market that moves adversely to the Clients' investments could result in a substantial loss to the Clients which would be greater than if the Clients were not leveraged. In the futures and forward markets, margin deposits are typically low relative to the value of the futures contracts purchased or sold. Such low margin deposits are indicative of the fact that any futures or forward contract trading is typically accompanied by a high degree of leverage. Low-margin deposits mean that a relatively small price movement in a contract may result in immediate and substantial losses to the investor. In general, the use of short-term margin borrowings results in certain additional risks to the Clients. For example, should the securities pledged to brokers to secure the Clients' margin accounts decline in value, the Clients could be subject to a "margin call," pursuant to which the Clients must either deposit additional funds or securities with the broker, or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. In the event of a sudden drop in the value of the Clients' assets, the Clients might not be able to liquidate assets quickly enough to satisfy their margin requirements. Due to an increase in margin requirements or other changes in the terms of financing relationships, there can be no assurance that the Clients will be able to maintain adequate financing arrangements or avoid having to close out positions at losses which if held would have been profitable.

Cybersecurity Risk - As part of its business, Owl Creek processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Funds and personally identifiable information of Owl Creek’s Clients. Similarly, service providers of Owl Creek may process, store and transmit such information. Owl Creek has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches and has retained an external technology consultant to assist in maintaining its procedures and systems. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. For example, advances in computer capabilities, new discoveries in the field of cryptography or other developments could result in a compromise or breach of the algorithms that the Investment Manager and its service providers use to protect data, including transaction data and investor data. Hardware or software acquired from third parties may contain defects in design or manufacturing or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Investment Manager may be susceptible to compromise, leading to a breach of the Investment Manager's network. Owl Creek’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services provided by Owl Creek to the limited partners or shareholders may also be susceptible to compromise. Breach of Owl Creek’s

information systems may cause information relating to the transactions of Clients and personally identifiable information to be lost or improperly accessed, used or disclosed, or the operations of Owl Creek may be compromised or disabled. As cybersecurity threats are inherently difficult to predict and can take many forms, insurance coverage may not be available for losses associated with cyber-attacks or information security breaches, or where available, such losses may exceed insurance limits. Although certain of the Owl Creek’s and the Funds’ insurance policies may in theory cover certain aspects of cyber incidents, such as cyber incidents driven by employee misconduct, there can be no assurance that any of their existing insurance policies will actually cover any losses associated with any cyberattacks or information security breaches, and where available, such losses may exceed insurance limits. Cybercrime against the Funds or its service providers could result in the Fund improperly issuing or losing funds. In recent years, a variety of U.S. and global firms, including financial services businesses and their service providers, have experienced significant distributed denial-of-service attacks, some of which involved sophisticated and targeted attacks intended to disable or degrade service, or sabotage systems. Other potential attacks have attempted to obtain unauthorized access to confidential information or destroy data, often through the introduction of computer viruses or malware, ransomware, cyber-attacks and other means. Such security attacks can originate from a wide variety of sources, including persons who are involved with organized crime or who may be linked to terrorist organizations, hacktivists or national governments. Those same parties may also attempt to fraudulently induce employees, customers or other users of our systems to disclose sensitive information in order to gain access to the data of Owl Creek and its clients. Owl Creek employs an external technology and cybersecurity consultant for all the Firm’s and the Funds’ IT needs. The service providers of Owl Creek, including this external technology consultant, are subject to the same electronic information security threats as Owl Creek. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of the Funds and personally identifiable information of the shareholders may be lost or improperly accessed, used or disclosed, or the ability of a service provider to operate may be compromised or disabled. Cyberattacks could also affect Owl Creek’s ability to communicate with its service providers and its ability to process and account for transactions.

Counterparty Fraud. Of paramount concern in investments is the possibility of material misrepresentation or omission on the part of a counterparty. Such inaccuracy or incompleteness may adversely affect the valuation of the collateral underlying an investment. The Investment Manager relies upon the accuracy and completeness of representations made by counterparties to the extent reasonable but cannot guarantee such accuracy or completeness. Under certain circumstances, payments to the Partnership may be reclaimed if any such payment or distribution is later determined to have been a fraudulent conveyance or a preferential payment.

Artificial Intelligence and Machine Learning Risks. - The emergence of recent technological developments in generative artificial intelligence such as ChatGPT and similar large language models and chatbots (collectively, "Generative AI") can pose risks to the Investment Manager and the Funds’ investments. The Investment Manager may begin to use Generative AI in various processes, including potentially in connection with its investment research process. The Investment Manager is likely to be further exposed to the risks of Generative AI through third parties (including the Investment Manager's or the Partnership's service providers or counterparties) that use Generative AI, and the Investment Manager may not always be aware of such use. The Investment Manager cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Furthermore, due to the rapidly evolving nature of Generative AI and its widespread potential uses, the Investment Manager expects that its policies and procedures will continue to evolve in response to any unique challenges. Generative AI is often highly reliant on the collection and analysis of large amounts of data, and in many instances it may not be possible or practicable to incorporate all potentially relevant data into the data set that Generative AI utilizes or to evaluate the source and the reliability of the data being analyzed. Further, the outputs of Generative AI may be inaccurate or unreliable and are also susceptible to errors in such outputs' subsequent analysis. Additionally, the use of Generative AI may involve (i) cybersecurity risks (including the increased likelihood that the Investment Manager, the Partnership or the underlying issuers in which they are invested become a victim of cybercrime), (ii) threats to proprietary and confidential information, (iii) intellectual property violations, (iv) access to, or disclosure of, personal information in violation of applicable data protection laws and (v) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats and/or violations could have adverse impacts on the Investment Manager, the Funds and Funds’ investments. Generative AI continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments.

Illiquid Investments (securities) - Certain of the Funds may invest in securities and other instruments which are subject to legal or other restrictions on transfer or for which limited or no liquid markets exist. Certain securities may be illiquid because, for example, they are subject to legal or other restrictions on transfer or there is no liquid market for such securities. Valuation of such securities may be difficult or uncertain because there may be limited information available about the issuers of such securities. The market prices, if any, for such securities tend to be volatile and may not be readily ascertainable, and the Funds may not be able to sell them when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. The sale of restricted and illiquid securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. The Funds may not be able to readily dispose of such illiquid investments and, in some cases, may be contractually prohibited from disposing of such investments for a specified period of time. As a result, the Funds may be required to hold such securities despite adverse price movements. Even those markets which the Investment Manager expects to be liquid can experience periods, possibly extended

periods, of illiquidity. Occasions have arisen in the past where previously liquid investments have rapidly become illiquid.

Liquidity (certain non-security investments). - Certain of the Funds currently invest a significant portion of their assets in financial assets (including in aircraft engine leasing assets) that do not freely trade or that trade infrequently with no broker-dealer making a market in such financial assets. Notwithstanding the above, the Funds are not required to designate any particular illiquid investment as a Special Investment (where applicable), and certain illiquid investments of the Funds (including aircraft engine leasing assets) have not been designated as Special Investments. In such cases, the illiquid investments are carried on the books of the Funds at values determined by the General Partner, or by an independent valuation agent selected by the General Partner. There is no guarantee that such value (or the value determined with respect to any other particular asset or liability of a Fund) will represent the value that will be realized by the Fund on the eventual disposition of the related investment or that would, in fact, be realized upon an immediate disposition of the investment If and when a Fund holds these assets in its general portfolio (instead of side pocketing such investments as Special Investments), new Limited Partners in the Fund and additional capital contributions to the Fund will dilute existing Limited Partners' exposure to such assets. To the extent that withdrawals are financed through the sale of the Fund's more liquid investments, such withdrawals would render the Fund’s portfolio, and the remaining Limited Partners' interest therein, comparatively more concentrated and less liquid.

Special Investments - The Flagship Funds and Credit Funds may invest in, or designate previous investments as, Special Investments, which are assets or securities which the Investment Manager believes either lack liquidity or a readily assessable market value or should be held until the resolution of a special event or circumstance. In addition, investors may be restricted in their ability to redeem any portion of their capital in an investment designed as a Special Investment, while such investment is so designated. Special Investments are illiquid and difficult to value and may require a significant amount of time prior to disposition. Sales of Special Investments may not be possible (whether due to market, regulatory, legal or other restrictions) and, if possible, may be made at substantial discounts from costs. Additional information about Special Investments is available in the Fees and Compensation section above.

Hedging - The success of the hedging strategy of a Client will be subject to the Investment Manager's ability to correctly assess the degree of correlation between the performance of the instruments used in the hedging strategy and the performance of the investments in the portfolio being hedged. Since the characteristics of many securities change as markets change or time passes, the success of a Client's hedging strategy will also be subject to the Investment Manager's ability to continually recalculate, readjust and execute hedges in an efficient and timely manner. While a Client may enter into hedging transactions to seek to reduce risk, such transactions may result in a poorer overall performance for a Client than if it had not engaged in any such hedging transactions. For a variety of reasons, the Investment Manager may not seek to establish a perfect correlation between such hedging instruments

and the portfolio holdings being hedged. Such imperfect correlation may prevent a Client from achieving the intended hedge or expose a Client to risk of loss. The successful utilization of hedging and risk management transactions requires skills complementary to those needed in the selection of a Client's portfolio holdings. Subject to a Client’s applicable investment guidelines, the Investment Manager may not hedge or elect not to fully hedge certain risks in its discretion.

Short Selling - Short selling involves selling securities which are not owned and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling allows the investor to profit from declines in market prices to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. The extent to which a Client engages in short sales depends upon the Investment Manager's investment strategy and opportunities, and the Client’s investment guidelines. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying security could theoretically increase without limit, thus increasing the cost to a Client of buying those securities to cover the short position. There can be no assurance that a Client will be able to maintain the ability to borrow securities sold short. In such cases, a Client can be "bought in" (i.e., forced to repurchase securities in the open market to return to the lender). There also can be no assurance that the securities necessary to cover a short position will be available for purchase at or near prices quoted in the market. Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss.

Forward Trading - Forward contracts and options thereon, unlike futures contracts, are not traded on exchanges and are not standardized; rather, banks and dealers act as principals in these markets, negotiating each transaction on an individual basis, although this is expected to change. Currently, forward and "cash" trading is substantially unregulated; there is no limitation on daily price movements and speculative position limits are not applicable. The principals who deal in the forward markets are not required to continue to make markets in the currencies or commodities they trade, and these markets can experience periods of illiquidity, sometimes of significant duration. There have been periods during which certain participants in these markets have refused to quote prices for certain currencies or commodities or have quoted prices with an unusually widespread between the price at which they were prepared to buy and that at which they were prepared to sell. Disruptions can occur in any market traded by a Client due to unusually high trading volume, political intervention or other factors. The imposition of controls by governmental authorities might also limit such forward (and futures) trading to less than that which the Investment Manager would otherwise recommend, to the possible detriment of a Client. Market illiquidity or disruption could result in major losses to a Client.

Swap Agreements - A Client may enter into swap agreements. Swap agreements are individually negotiated and can be structured to include exposure to a variety of different types of investments or market factors. Depending on their structure, swap agreements may increase or decrease a Fund's exposure to long-term or short-term interest rates (in the United States or abroad), non-U.S. currency values, corporate borrowing rates, or other factors such

as security prices, baskets of equity securities or inflation rates. Swap agreements can take many different forms and are known by a variety of names. A Client is not limited to any particular form of swap agreement if consistent with a Client's investment objective and policies. Swap agreements tend to shift a Client's investment exposure from one type of investment to another. For example, if a Client agrees to exchange payments in dollars for payments in non-U.S. currency, the swap agreement would tend to decrease a Client's exposure to U.S. interest rates and increase its exposure to non-U.S. currency and interest rates. Depending on how they are used, swap agreements may increase or decrease the overall volatility of a Client's portfolio. The most significant factor in the performance of swap agreements is the change in the specific interest rate, currency, individual equity values or other factors that determine the amounts of payments due to and from a Fund. If a swap agreement calls for payments by a Client, a Client must be prepared to make such payments when due. In addition, if a counterparty's creditworthiness declines, the value of swap agreements with such counterparty can be expected to decline, potentially resulting in losses by a Client.

Other Derivative Instruments - A Client may take advantage of opportunities with respect to certain other derivative instruments that are not presently contemplated for use or that are currently not available, but that may be developed, to the extent such opportunities are both consistent with the investment objective of a Client and legally permissible. Special risks may apply to instruments that are invested in by a Client in the future that cannot be determined at this time or until such instruments are developed or invested in by a Client. 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.

Regulation in the Derivatives Industry. There are many rules related to derivatives that may negatively impact our Clients, such as requirements related to recordkeeping, reporting, portfolio reconciliation, central clearing, minimum margin for uncleared over-the-counter ("OTC") instruments and mandatory trading on electronic facilities, and other transaction-level obligations. Parties that act as dealers in swaps, are also subject to extensive business conduct standards, additional "know your counterparty" obligations, documentation standards and capital requirements. All of these requirements add costs to the legal, operational and compliance obligations of Owl Creek and its Clients and increase the amount of time that Owl Creek spends on non-investment-related activities. Requirements such as these also raise the costs of entering into derivative transactions, and these increased costs will likely be passed on to Clients. These rules are operationally and technologically burdensome. These compliance obligations require employee training and use of technology, and there are operational risks borne by Clients in implementing procedures to comply with many of these additional obligations. These regulations may also result in Clients forgoing the use of certain trading counterparties (such as broker-dealers and futures commission merchants ("FCMs")), as the use of other parties may be more efficient for Clients from a regulatory perspective. However, this could

limit Clients' trading activities, create losses, preclude them from engaging in certain transactions or prevent them from trading at optimal rates and terms. Many of these requirements were implemented under legislation intended to reform the U.S. financial regulatory system, the EU Regulation on OTC Derivatives, Central Counterparties and Trade Repositories (known as the European Market Infrastructure Regulation, or "EMIR") and similar regulations globally. In the United States, the regulatory responsibility for derivatives is divided between the SEC and the CFTC, a distinction that does not exist in any other jurisdiction. The SEC has regulatory authority over "security-based swaps" and the CFTC has regulatory authority over "swaps". EMIR is being implemented in phases through the adoption of delegated acts by the European Commission. As a result of the SEC and CFTC bifurcation and the different pace at which the SEC, the CFTC, the European Commission and other international regulators have promulgated necessary regulations, different transactions are subject to different levels of regulation. The following describes derivatives regulations that may have the most significant impact on our Clients: Reporting. Most swap transactions have become subject to anonymous "real time reporting" requirements, meaning that information relating to transactions entered into by Clients will become visible to the market in ways that may impair their ability to enter into additional transactions at comparable prices or could enable competitors to "front run" or replicate their strategies. Central Clearing. To mitigate counterparty risk and systemic risk in general, various U.S. and international regulatory initiatives, including EMIR, are underway to require certain derivatives to be cleared through central clearinghouses. In the United States, clearing mandates affect certain interest rate and credit default swaps. The CFTC and the SEC may introduce clearing requirements for additional classes of derivatives in the future. EMIR also requires OTC derivatives contracts meeting specific criteria to be cleared through central counterparties. While such clearing requirements may be beneficial for certain Clients in many respects (for instance, they may reduce the counterparty risk to the dealers to which a Client would be exposed under non-cleared derivatives), Clients could be exposed to new risks, such as the risk that an increasing percentage of derivatives will be required to be standardized and/or cleared through central clearinghouses, and, as a result, Clients may not be able to hedge risks or express an investment view as well as they would have been able to had they used customizable derivatives available in the over-the-counter markets. Clients may have to split its derivatives portfolio between centrally cleared and over-the-counter derivatives, which may result in operational inefficiencies and an inability to offset risk between centrally cleared and over-the-counter positions, and which could lead to increased costs. Another risk is that Clients may be subject to more onerous and more frequent (daily or even intraday) margin calls from both FCMs and the clearinghouse. Virtually all margin models utilized by the clearinghouses are dynamic, meaning that unlike traditional bilateral swap contracts where the amount of initial margin posted on the contract is typically static throughout the life of the contract, the amount of the initial

margin that is required to be posted in respect of a cleared contract will fluctuate, sometimes significantly, throughout the life of the contract. The dynamic nature of the margin models utilized by the clearinghouses and the fact that the margin models might be changed at any time may subject Clients to an unexpected increase in collateral obligations by clearinghouses during a volatile market environment, which could have a detrimental effect on Clients. Clearinghouses also limit collateral that they will accept to cash, U.S. treasuries and, in some cases, other highly rated sovereign and private debt instruments, which may require Clients to borrow eligible securities from a dealer to meet margin calls and raise the costs of cleared trades. In addition, clearinghouses may not allow Clients to portfolio-margin its positions, which may increase costs. Although standardized clearing for derivatives is intended to reduce counterparty risk (for instance, it may reduce the counterparty risk to the dealers to which a Client would have been exposed under OTC derivatives), it does not eliminate risk. Derivatives clearing may also lead to concentration of counterparty risk, namely in the clearinghouse and FCMs, subjecting Clients to the risk that the assets of the FCM are insufficient to satisfy all of the FCM's payment obligations, leading to a payment default. The failure of a clearinghouse or FCM could have a significant impact on the financial system. Even if a clearinghouse does not fail, large losses could force significant capital calls on FCMs during a financial crisis, which could lead FCMs to default and thus worsen the crisis. Swap Execution Facilities. In addition to the central clearing requirement, certain swap transactions are required to trade on regulated electronic platforms such as swap execution facilities ("SEFs"), which require the Funds to become subject to regulation by these venues and subject them to the jurisdiction of the CFTC. CFTC rules governing the operations of SEFs continue to evolve; and the SEC has recently adopted final rules related to security-based SEFs. It is not clear whether these trading venues will benefit or impede liquidity, or how they will fare in times of market stress. Trading on these trading venues may increase the pricing discrepancy between assets and their hedges as products may not be able to be executed simultaneously, therefore increasing basis risk. It may also become relatively expensive to obtain tailored swap products to hedge particular risks in portfolios due to higher collateral requirements on bilateral transactions as a result of these regulations. Margin Requirements for Non-Cleared Swaps. Rules issued by U.S., EU and other regulators globally (the "Margin Rules") impose various margin requirements on all swaps that are not centrally cleared, including the establishment of minimum amounts of initial margin that must be posted, and, in some cases, the mandatory segregation of initial margin with a third-party custodian. Although the Margin Rules are intended to increase the stability of the derivatives market, the overall amount of margin that Clients will be required to post to swap counterparties may increase by a material amount, and as a result Clients may not be able to deploy capital as effectively. Additionally, to the extent a Client is required to segregate initial margin with a thirdparty custodian, additional costs will be incurred.

Credit Default Swaps. Credit default swaps can be used to implement the Investment Manager's view that a particular credit, or group of credits, will experience credit improvement or deterioration. In the case of expected credit improvement, the applicable Client(s) may sell credit default protection in which it receives a premium to take on the risk. In such an instance, the obligation to make payments upon the occurrence of a credit event creates leveraged exposure to the credit risk of the referenced entity. Clients may also buy credit default protection with respect to a referenced entity if, in the Investment Manager's judgment, there is a high likelihood of credit deterioration. In such instance, the Client(s) will pay a premium regardless of whether there is a credit event.

Call and Put Options. There are risks associated with the sale and purchase of call options and put options. Under a conventional cash-settled option, the purchaser of the option pays a premium in exchange for the right to receive upon exercise of the option (i) in the case of a call option, the excess, if any, of the reference price or value of the underlier (as determined pursuant to the terms of the option) above the option's strike price or (ii) in the case of a put option, the excess, if any, of the option's strike price above the reference price or value of the underlier (as so determined). Under a conventional physically-settled option structure, the purchaser of a call option has the right to purchase a specified quantity of the underlier at the strike price, and the purchaser of a put option has the right to sell a specified quantity of the underlier at the strike price. A purchaser of an option may suffer a total loss of premium (plus transaction costs) if that option expires without being exercised. An option's time value (i.e., the component of the option's value that exceeds the in-the-money amount) tends to diminish over time. Even though an option may be in-the-money to the purchaser at various times prior to its expiration date, the purchaser's ability to realize the value of an option depends on when and how the option may be exercised. For example, the terms of the transaction may provide for the option to be exercised automatically if it is in-the-money on the expiration date. Conversely, the terms may require timely delivery of a notice of exercise, and exercise may be subject to other conditions (such as the occurrence or non-occurrence of certain events) and timing requirements, including the "style" of the option. Uncovered option writing (i.e., selling an option when the seller does not own a like quantity of an offsetting position in the underlier) exposes the seller to potentially significant loss. The potential loss of uncovered call writing is unlimited. The seller of an uncovered call may incur large losses if the reference price or value of the underlier increases above the exercise price by more than the amount of any premiums earned. As with writing uncovered calls, the risk of writing uncovered put options is substantial. The seller of an uncovered put option bears a risk of loss if the reference price or value of the underlier declines below the exercise price by more than the amount of any premiums earned. Such loss could be substantial if there is a significant decline in the value of the underlier. The Firm may engage in option spread trading that may incorporate both writing and buying options and incorporating the risks described above. Although spreads may result in lower price per given exposure, these spreads may also result in less hedging or a reduced return on a purchased option because of losses on a written option, especially when there are dramatic changes in price.

Frequent option trading may increase explicit and implicit trading costs for the applicable funds. Commissions are often higher for options than equities, bid/offer spreads may be wider for options, and liquidity may be less than the underlying issuer’s common stock. The practice of rolling up or rolling down strikes to manage exposures, also increases trading cost as it involves crossing the bid/offer spread multiple times. An important input in option pricing are implied volatility of the underlying instrument and markets in general. Investors in certain Owl Creek funds are exposed to the underlying price risk of changes in the volatility of specific options and implied volatilities overall.

Futures Contracts - Each Client may trade in futures contracts (and options on futures). Futures positions may be illiquid because, for example, most U.S. commodity exchanges limit fluctuations in certain futures contract prices during a single day by regulations referred to as "daily price fluctuation limits" or "daily limits." Under such daily limits, during a single trading day no trades may be executed at prices beyond the daily limits. Once the price of a contract for a particular future has increased or decreased by an amount equal to the daily limit, positions in the future can neither be taken nor liquidated unless traders are willing to effect trades at or within the limit. Futures contract prices on various commodities or financial instruments occasionally have moved the daily limit for several consecutive days with little or no trading. Similar occurrences could prevent a Client from promptly liquidating unfavorable positions and subject a Client to substantial losses. In addition, a Client may not be able to execute futures contract trades at favorable prices if trading volume in such contracts is low. It is also possible that an exchange or a regulator (such as the SEC or the U.S. Commodity Futures Trading Commission (the "CFTC")) may suspend trading in a particular contract, order immediate liquidation and settlement of a particular contract or order that trading in a particular contract be conducted for liquidation only. In addition, the CFTC and various exchanges impose speculative position limits on the number of positions that may be held in particular commodities. Trading in commodity futures contracts and options are highly specialized activities that may entail greater than ordinary investment or trading risks. Furthermore, low margin or premiums normally required in such trading may provide a large amount of leverage, and a relatively small change in the price of a security or contract can produce a disproportionately larger profit or loss.

Counterparty Default - The stability and liquidity of financing agreements, swap transactions, forward transactions and other over-the-counter derivative transactions depend in large part on the creditworthiness of the parties to the transaction. The Clients monitor on an on-going basis the creditworthiness of firms with which it has such arrangements. If there is a default by the counterparty to such a transaction, the Clients will under most normal circumstances have contractual remedies pursuant to the agreements related to the transaction. However, exercising such contractual rights may involve delays or costs which could result in the net asset value of the Clients being less than if the Clients had not entered into the transaction. Furthermore, there is a risk that any of such counterparties could become insolvent and/or the subject of insolvency proceedings. If one or more of a Client's counterparties were to become insolvent or the subject of insolvency proceedings in the United States (either under the Securities Investor Protection Act or the United States Bankruptcy Code), there exists the risk that the recovery of a Client's securities and other assets from such prime broker or broker-dealer will be delayed or be of a value less than the

value of the securities or assets originally entrusted to such prime broker or broker-dealer. Collateral that a Client posts to its counterparties that is not segregated with a third-party custodian may not have the benefit of customer-protected “segregation” of such funds. In the event that a counterparty was to become insolvent, the applicable Client(s) may become subject to the risk that it may not receive the return of its collateral or that the collateral may take some time to return. In addition, a Client may use counterparties located in jurisdictions outside the United States. Such local counterparties are subject to laws and regulations in non-U.S. jurisdictions that are designed to protect their customers in the event of their insolvency. However, the practical effect of these laws and their application to a Client's assets are subject to substantial limitations and uncertainties. Because of the large number of entities and jurisdictions involved and the range of possible factual scenarios involving the insolvency of a counterparty, it is impossible to generalize about the effect of their insolvency on a Client and its assets. Investors should assume that the insolvency of any counterparty would result in a loss to a Client, which could be material.

Non-U.S. Investments - Investments in non-U.S. issuers (including non-U.S. governments) and investments denominated or whose prices are quoted in non-U.S. currencies pose, to the extent not hedged, currency exchange risks (including blockage, devaluation and nonexchangeability) as well as a range of other potential risks which could include, expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, other income or gross sale or disposition proceeds, limitations on the removal of funds or other assets of the Clients, political or social instability, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding investments of non-U.S. issuers and non-U.S. issuers may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those of U.S. issuers. Transaction costs of investing in non-U.S. investment markets are generally higher than in the U.S. There is generally less government supervision and regulation of exchanges, brokers and issuers than there is in the U.S. The Clients might have greater difficulty taking appropriate legal action in non-U.S. courts. Non-U.S. markets also have different clearance and settlement procedures which in some markets have at times failed to keep pace with the volume of transactions, thereby creating substantial delays and settlement failures that could adversely affect Client performance.

Risks of Event Driven Investing - Event driven investing requires the investment manager to make predictions about (i) the likelihood that an event will occur and (ii) the impact such event will have on the value of a company's securities. If the event fails to occur or it does not have the effect foreseen, losses can result. For example, the adoption of new business strategies or completion of asset dispositions or debt reduction programs by a company may not be valued as highly by the market as the Investment Manager had anticipated, resulting in losses. In addition, a company may announce a plan of restructuring which promises to enhance value and fail to implement it, resulting in losses to investors. In liquidations and other forms of corporate reorganization, the risk exists that the reorganization either will be unsuccessful, will be delayed or will result in a distribution of cash or a new security, the value of which will be less than the purchase price to the Clients of the security in respect

of which such distribution was made. The consummation of mergers and tender and exchange offers can be prevented or delayed by a variety of factors, including: (i) opposition of the management or stockholders of the target company, which will often result in litigation to enjoin the proposed transaction; (ii) intervention of a federal or state regulatory agency; (iii) efforts by the target company to pursue a "defensive" strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) in the case of a merger, failure to obtain the necessary stockholder approvals; (v) market conditions resulting in material changes in securities prices; (vi) compliance with any applicable U.S. federal or state securities laws; and (vii) inability to obtain adequate financing. Because of the inherently speculative nature of event driven investing, the results of the Clients’ operations may be expected to fluctuate from period to period. Accordingly, investors should understand that the results of a particular period will not necessarily be indicative of results that may be expected in future periods.

Investments in Undervalued Equity Securities - One of the objectives of the Clients is to invest in the equity securities of undervalued companies. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of risk and can result in substantial losses. In addition, the Clients may be required to hold such securities for a substantial period of time before realizing their anticipated value. During this period, a portion of the Clients’ funds would be committed to the securities purchased, thus possibly preventing the Clients from investing in other opportunities.

Risks Associated with Debt Securities Generally. The Funds may invest in private and government debt securities and instruments. The Funds 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.

Risks Associated with Investments in Distressed Securities. The Clients may invest in securities of companies that are experiencing significant financial or business difficulties, including companies involved in bankruptcy or other reorganization and liquidation proceedings. Although such investments may result in significant returns to a Client, they involve a substantial degree of risk. Any one or all of the issuers of the securities in which a Client may invest may be unsuccessful or not show any return for a considerable period of time. 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 the Investment Manager will correctly evaluate the value of the assets collateralizing a Client's investments in loans or the prospects for a successful reorganization or similar action. In any reorganization or

liquidation proceeding relating to a company in which a Client invests, the Client may lose its entire investment, may be required to accept cash or securities with a value less than the Client's original investment and/or may be required to accept payment over an extended period of time. Under such circumstances, the returns generated from the Client's investments may not compensate the investors of the Client adequately for the risks assumed. Troubled company and other asset-based investments require active monitoring and may, at times, require participation in business strategy or reorganization proceedings by the Investment Manager. To the extent that the Investment Manager becomes involved in such proceedings, a Client may have a more active participation in the affairs of the issuer than that assumed generally by an investor. In addition, involvement by the Investment Manager in an issuer's reorganization proceedings could result in the imposition of restrictions limiting a Client's ability to liquidate their position in the issuer. The Funds may invest in bonds or other fixed income securities, including, without limitation, "higher yielding" (and, therefore, higher risk) debt securities, when the Investment Manager believes that such securities offer opportunities for capital growth. Such securities may be below "investment grade" and face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer's inability to meet timely interest and principal payments. The market values of certain of these lower rated debt securities tend to reflect individual corporate developments to a greater extent than do higher rated securities, which react primarily to fluctuations in the general level of interest rates. It is likely that a major economic recession could have a materially adverse impact on the value of such securities. In addition, adverse publicity and investor perceptions, whether or not based on fundamental analysis, may also decrease the value and liquidity of securities rated below investment grade.

Risks Associated with Bankruptcy Cases. The Funds may invest in bankruptcy claims, which are amounts owed to creditors of companies that are debtors in pending bankruptcy cases. Bankruptcy claims typically are illiquid, generally do not pay interest and there can be no guarantee that the debtor will ever be able to satisfy the obligation on the bankruptcy claim. Because bankruptcy claims are frequently unsecured, holders of such claims may have a lower priority in terms of payment than certain other creditors in a bankruptcy case. Many of the events within a bankruptcy case are adversarial and often beyond the control of the creditors. While creditors generally are afforded an opportunity to object to significant actions, there can be no assurance that a bankruptcy court would not approve actions which may be contrary to the interests of the Funds. Furthermore, there are instances where creditors and equity holders lose their ranking and priority as such when they take over management and functional operating control of a debtor. In those cases where the Funds, by virtue of such action, are found to exercise "domination and control" of a debtor, the Funds may lose their priority if the debtor can demonstrate that its business was adversely impacted or other creditors and equity holders were harmed by the Funds. Generally, the duration of a bankruptcy case can only be roughly estimated. Unless the Funds' claim in such case is secured by assets having a value in excess of such claim, no

interest will be permitted to accrue and, therefore, the Funds' return on investment can be adversely affected by the passage of time during which the plan of reorganization of the debtor is being negotiated, approved by the creditors, and confirmed by the bankruptcy court. The risk of delay is particularly acute when a creditor holds unsecured debt or when the collateral value underlying secured debt does not equal the amount of the secured claim. It should also be noted that reorganizations outside of bankruptcy are also subject to unpredictable and potentially lengthy delays. The administrative costs in connection with a bankruptcy proceeding are frequently high and will be paid out of the debtor's estate prior to any return to creditors (other than out of assets or proceeds hereof, which are subject to valid and enforceable liens and other security interests) and equity holders. In addition, certain claims that have priority by law over the claims of certain creditors (for example, claims for taxes) may be quite high. The Investment Manager, on behalf of the Funds, may elect to serve on creditors' committees or other groups to ensure preservation or enhancement of the Funds' position as a creditor. A member of any such committee or group may owe certain obligations generally to all parties similarly situated that the committee represents. If the Investment Manager concludes that its obligations owed to the other parties as a committee or group member conflict with its duties owed to the Funds, it will resign from that committee or group, and the Funds may not realize the benefits, if any, of participation on the committee or group. In addition, and also as discussed above, if the Funds are represented on a committee or group, they may be restricted or prohibited under applicable law from disposing of their investments in such company while they continue to be represented on such committee or group. The Funds may purchase creditor claims subsequent to the commencement of a bankruptcy case. Under judicial decisions, it is possible that such purchase may be disallowed by the bankruptcy court if the court determines that the purchaser has taken unfair advantage of an unsophisticated seller, which may result in the rescission of the transaction (presumably at the original purchase price) or forfeiture by the purchaser.

Sovereign Debt - Sovereign debt instruments, which are debt obligations issued or guaranteed by a governmental entity, are subject to the risk that the governmental entity may delay or fail to pay interest or repay principal on debt that it has issued or guaranteed, due to, for example, cash flow problems, insufficient foreign currency reserves, political considerations, relationships with other lenders such as commercial banks, the relative size of the governmental entity’s debt position in relation to the economy or the failure to put in place economic reforms required by the International Monetary Fund or other multilateral agencies. If a governmental entity defaults, it may ask for more time to pay or for further loans, or it may ask for forgiveness of interest or principal on its existing debt. Furthermore, a governmental entity may be unwilling to renegotiate the terms of its sovereign debt. There may be no established legal process for bondholders (such as the Funds) to enforce their rights against a governmental entity that does not fulfill its obligations, nor are there bankruptcy proceedings through which all or part of the sovereign debt that a governmental entity has not may be collected.

Aviation Leasing. Owl Creek may invest in aviation-related leasing strategies that involve the leasing of aircraft engines, airframes, or other aviation components. The aircraft leasing business is subject to numerous risk factors, many of which are beyond the control of the Investment Manager. The aviation sales and lease markets are highly competitive and there can be no assurance that this competition will not impede Owl Creek’s ability to make profitable investments in the aviation leasing market. Owl Creek generally makes aviation leasing investments with third-party servicers and co-investors. Such arrangements present risks including that a servicer or co-investor becomes financially distressed or develops business interests or goals that conflict with Owl Creek's interests and goals in respect of its investments and are further articulated in the next risk factor below. In addition, Owl Creek is subject to aviation industry risks such as decreases in passenger or air cargo demand, increases in fuel costs, changes to government regulation, increases in interest rates, changes to tariffs, oversupply, effects of airworthiness directives and operating restrictions, technological advances in airframe and/or engine technology, or requirements for certain licenses and approvals, as well as general economic, market condition, currency, or supply chain risks, among other factors. Lease-specific risks that Owl Creek faces as the lessor may include exposure to: lessee credit risk; off-lease engine residual values; faster than anticipated depreciation of the asset; unanticipated or earlier than expected return of leased assets; poor maintenance, operating history and documentary records of the aircraft, engine, or component; aircraft age or engine remaining cycles; operator demand for specific assets; the availability of spare parts; supply of comparable assets; renegotiation of an existing leases on less favorable terms; insufficient maintenance reserves (where applicable); underinsured loss of use of leased assets; and premature return under applicable leases. There can be no assurance that Owl Creek will be capable of, or successful at, preserving the value of its assets, generating positive investment returns, or effectively managing its risks in the aviation leasing business.

Risks Relating to Investment Arrangements with Counterparties such as Third- Party Servicers. Certain of the Funds have entered, and in the future will enter, into joint venture or similar contractual arrangements with third parties in connection with the acquisition, ownership or operation of investments, particular in circumstances where the Investment Manager determines that such arrangements are the only, or an advantageous, way to exercise certain investment opportunities. In particular, certain of the Funds have entered, and will in the future enter, into agreements with aviation leasing companies that source, structure and service aircraft leases and related transactions, pursuant to which such Funds supply the required investment capital, while the counterparty undertakes the servicing duties. The performance of these investments will be highly dependent on the operating counterparty’s ability in accordance with the Investment Manager’s expectations and contractual requirements. Moreover, in the context of facilitating investments in certain specialty asset classes, including aircraft engine leasing opportunities, the Funds will invest through vehicles that are controlled by operating companies that are not affiliated with the Investment Manager. The Funds’ rights will depend on the specific structure and the

counterparty relationships that are established. For example, the Investment Manager will typically retain investment discretion over the particular engines and lessees, but the Funds’ control and oversight rights over the operating company will be the subject of negotiation and will vary from deal to deal. Any failure by an operating counterparty to perform its obligations could materially adversely affect the value and returns of the Partnership’s investments. Investments through structures that are not wholly controlled by the Funds involve risks not otherwise present in investments where a greater degree of control can be exerted, including the possibility that an operating counterparty may (i) have economic or business interests that are inconsistent with, or competitive to, those of the Funds, (ii) have financial difficulties or become bankrupt, (iii) take actions contrary to the Funds’ objectives or instructions, (iv) be unable or unwilling to meet its obligations under the applicable transaction agreements, or (v) take actions without the Funds’ consent. Any such occurrences may adversely affect the value of the Funds’ investment and the ability of the Funds to achieve their investment objective

Alternative Investment Fund Managers Directive. The Alternative Investment Fund Managers Directive (the "AIFM Directive") regulates: (i) alternative investment fund managers (each, an "AIFM") based in the European Economic Area (the "EEA"); (ii) the management of any alternative investment fund ("AIF") established in the EEA (irrespective of where an AIF's AIFM is based); and (iii) the marketing of any AIF, such as the Fund, to professional investors in the EEA. Under the AIFM Directive, certain conditions must be met to permit the marketing of a Fund’s shares to any potential and existing investors in the EEA. The ability of the Fund or the Investment Manager to offer shares in the EEA will depend on the relevant EEA state permitting the marketing of non-EEA domiciled funds under the national private placement regimes implementing the AIFM Directive and the ability of the Fund and the Investment Manager to comply with such national private placement regimes, where available. Compliance with the requirements of such regimes may increase the costs of the administration of the Fund significantly, including the costs of regulatory reporting, custody and prime brokerage services provided to the Fund. As such, a Fund's ability to market the Shares to EEA investors may be limited. As described in Part 1 in the EEA, the Credit Offshore Fund presently complies with the local private placement regimes in Denmark, Finland and the Netherlands; and Owl Creek Overseas complies with the local private placement regime in the Netherlands. The UK, although it is no longer part of the EEA has an equivalent directive, “UK AIFMD”. UK AIFMD regulates (i) – (iii) above for AIFM and AIFs based in the UK or AIFs marketed in the UK. There are also local conditions under the UK private placement regime that must be complied with when marketing of a Fund’s shares to any potential and existing investors. Owl Creek Overseas and Credit Offshore Fund presently comply with the UK private placement regime and relevant parts of UK AIFMD.

Identity of Beneficial Ownership and Withholding on Certain Payments. In order to avoid a U.S. withholding tax of 30% on certain payments (including payments of gross proceeds) made with respect to certain actual and deemed U.S. investments, the Offshore Funds have registered with the U.S. Internal Revenue Service (the "Service") and generally will be

required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including debtholders and equity-holders). The Cayman Islands has signed a Model 1B (non-reciprocal) inter-governmental agreement with the United States (the "U.S. IGA") to give effect to the foregoing withholding and reporting rules. So long as the Funds comply with the U.S. IGA and the Cayman Islands enabling legislation, they will not be subject to the related U.S. withholding tax. A non-U.S. investor in the Offshore Funds will generally be required to provide information which identifies its direct and indirect U.S. ownership. Under the U.S. IGA, any such information provided to the applicable Fund and certain financial information related to such investor's investment in such Fund will be shared with the Cayman Islands Tax Information Authority or its delegate (the "Cayman TIA"). The Cayman TIA will exchange the information reported to it with the Service annually on an automatic basis. A non-U.S. investor that is a "foreign financial institution" within the meaning of Section 1471(d)(4) of the Internal Revenue Code of 1986, as amended (the "IRC"), will generally be required to timely register with the Service and agree to identify, and report information with respect to, certain of its own direct and indirect U.S. account holders (including debtholders and equity-holders). A non-U.S. investor who fails to provide such information to the Fund or timely register and agree to identify, and report information with respect to, such account holders (as applicable) may be subject to the 30% withholding tax with respect to its share of any such payments attributable to actual and deemed U.S. investments of the Fund, and the Board of Directors may take any action in relation to an investor's shares or redemption proceeds to ensure that such withholding is economically borne by the relevant investor whose failure to provide the necessary information or comply with such requirements gave rise to the withholding. Investors should consult their own tax advisers regarding the possible implications of these rules on their investments in the Fund.

Delayed Schedules K-1. A Fund may be unable to provide final Schedules K-1 to an investor for any given fiscal year until after April 15 of the following year. The Investment Manager will endeavor to provide investors with estimates of the taxable income or loss allocated to their investment in Funds on or before such date, but final Schedules K-1 may not be available until completion of a Fund’s annual audit. Investors may be required to obtain extensions of the filing date for their income tax returns at the Federal, state and local levels.

U.S. Partnership Tax Audit Risk. Under current law, the Offshore Funds that are treated as a partnership for U.S. tax purposes, may be required to file a tax return with the Service. If the tax returns are audited by the Service, the U.S. tax treatment of such Offshore Fund's or a U.S. Fund’s, as applicable, income and deductions generally is determined at the Fund level and U.S. tax deficiencies arising from the audit, if any, are paid by the Fund (and in the case of the Offshore Funds, to the extent of any income that is, or is treated as, effectively connected with a trade or business in the United States or otherwise subject to withholding or other tax in the United States) and the other members of the Fund who were partners for U.S. tax purposes in the year subject to the audit. Under the general rule imposed under new legislation, an audit adjustment of a Fund's U.S. tax return filed or required to be filed for any tax year beginning after 2017 (a "Prior Year")

could result in a tax liability (including interest and penalties) imposed on the Fund for the year during which the adjustment is determined (the "Current Year"). The tax liability generally is determined by using the highest tax rates under the Internal Revenue Code applicable to U.S. taxpayers, in which case the Fund and any other Current Year partners of the Fund would bear the audit tax liability at significantly higher rates (including interest and penalties) arising from audit adjustments and in amounts that are unrelated to their Prior Year economic interests in the Fund partnership items that were adjusted. Under the new legislation, the Fund may be able to use a lower tax rate to compute the tax liability by taking into account the fact that the Fund is generally not expected to be subject to U.S. tax on most, if not all, of its share of the Fund's income. However, the details of how this rule will be implemented are not yet known, and there can be no guarantee that a Fund would be able to use a lower tax rate to calculate the tax liability for any particular Prior Year under audit. To mitigate the potential adverse consequences of the general rule, a Fund may be able to elect with the Service to pass through such audit adjustments for any year to its members who participated in the Fund for the Prior Year, in which case the Fund and each Prior Year participating member (and not the Fund) generally would be responsible for the payment of any tax deficiency, determined after including their share of the adjustments on their tax returns for the Current Year and calculated, in the case of an Offshore Fund, using the tax rates generally applicable to non-U.S. entities. The Fund may also be able to mitigate such adverse consequences by, after the audit adjustments are made, filing an amended U.S. tax return for the Prior Year and paying tax, if any, on its share of the items adjusted on audit. However, the extent to which the Fund will be able to mitigate the operation of the general rule under either of these alternatives is highly uncertain and may depend upon future regulatory guidance and amendments to the legislation. Concentration of Investments. The Flagship Funds, the Credit Funds, the OCSS, the OC Solutions Funds and the Owl Creek Aviation Fund hold, and at times may hold, individually or collectively certain concentrated investments or substantial allocation to certain issuers, investment themes, strategies, industries (collectively “Concentrated Investments”). Such Concentrated Investments may be disclosed to existing investors through regular investment reporting and communication, and to prospective investors during their investment due diligence process. The Concentrated Investment(s) may subject the relevant fund to more concentrated issuer specific, event, or industry risks. In certain cases, the relevant issuer may publicly disclose such risks. The Concentrated Investment(s) may subject the performance of the relevant Fund(s) or specific Fund class(es) to more rapid change in the value than would be the case if the applicable fund was more diversified / less concentrated. There can be no assurance that specific Concentrated Investment(s) will have successful performance returns. The Credit Funds have exposure to aviation related leasing with the largest concentration comprised of indirect investments in aircraft engine leasing to a broad range of international airlines. Aviation leasing macro factor risks (described elsewhere in this document) may subject the Credit Funds performance to more concentrated industry risk. The Owl Creek Aviation Fund is not diversified with respect to its investment in a portfolio of aircraft engine leases, originated from and managed by a single servicer counterparty,

with strong portfolio concentration in a certain engine model popular on narrow body planes. The Fund’s future performance will be driven by the leasing demand for this engine model. The Fund is exposed to a concentrated single aviation industry risk that may be greater than a portfolio with exposure to multiple industries. This lack of diversity could expose the Fund to losses disproportionate to market movements in general. Some of the concentration risk is mitigated by being exposed to a broad portfolio of lessees across multiple geographic jurisdictions. There can be no assurance that the Fund investments will have successful performance returns.

Co-Investments. The Investment Manager and/or its affiliates may, from time to time, offer one or more investors in the Funds and/or other third-party investors the opportunity to coinvest with one or more of the Funds in particular investments (including investments held by the Funds where there is excess capacity). The Investment Manager and its affiliates are not obligated to arrange co-investment opportunities, no investor in the Funds will be obligated to participate in such an opportunity, and the Investment Manager may offer coinvestment opportunities only to certain of the persons referenced above in its sole discretion. The Investment Manager and its affiliates have sole discretion as to the amount (if any) of a co-investment opportunity that will be allocated to a particular investor and may allocate co-investment opportunities instead to investors in certain Funds or Accounts or to third parties. Investors that choose to participate in an offered co-investment opportunity will generally be required to notify the Investment Manager within the applicable time period required by the Investment Manager of the intent to participate in such co-investment opportunity. If the Investment Manager determines that an investment opportunity is too large for a Fund, the Investment Manager and its affiliates may, but will not be obligated to, make proprietary investments therein. The Investment Manager or its affiliates may receive fees and/or allocations from co-investors, which may differ as among co-investors and also may differ from the fees and/or allocations borne by the Funds. Other terms and rights applicable to such co-investors (including without limitation, withdrawal or redemption rights, information rights and the terms related to the particular structure of any coinvestment vehicle) may also differ from the terms and rights applicable to investors in the Funds as well as among co-investors.

Sanctions. Our operations are or may become subject to economic sanctions laws and regulations of various jurisdictions. At any given time, whether under applicable law, by contractual commitment or as a voluntary risk management measure, Owl Creek may be required, or elect, to comply with various sanctions programs, including the Specially Designated Nationals and Blocked Persons List and Sectoral Sanctions programs administered by OFAC, the sanctions regimes administered by subsidiary organs of the United Nations Security Council, the Sanctions Orders of the Cayman Islands (including as extended to the Cayman Islands by Order of the government of the United Kingdom from time to time), and the restrictive measures adopted by the European Union. Some sanctions that may apply to Owl Creek prohibit or restrict dealings with particular identified persons. Other potentially applicable sanctions programs broadly prohibit or restrict dealings in certain countries or territories or with individuals and entities located in such countries or territories. In addition to such current sanctions, additional sanctions may be imposed in the future. Such sanctions may be imposed with little or no advance warning or "safe harbor"

for compliance and may be ambiguous, including as to the scope of financial activities that regulators may ultimately deem to be covered by the sanctions. Sanctions may negatively impact Owl Creek’s ability to effectively implement its investment strategy and have a material adverse impact on Owl Creek's investment program. Investors in the Funds may be subject to sanctions causing the Funds to have to take actions, and incur expenses, required to comply with such sanctions. Sanctions may adversely affect Owl Creek in various ways, including by preventing or inhibiting Owl Creek or its Funds from making certain investments, forcing the divestment from investments previously made, and leading to substantial reductions in the revenues, profits and value of companies in which the Funds have invested. In addition, if Owl Creek or any Fund were to violate or be deemed in violation of any such sanction, such entity could face significant legal and monetary penalties. Depending on the scope and duration of a particular sanctions program, compliance by the Owl Creek may result in a material adverse effect on the Funds and its investments.

Assumption of Catastrophe Risks. There is a risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes and other natural disasters; war, terrorism and other armed conflicts; cyberterrorism; major or prolonged power outages or network interruptions; and public health crises, including infectious disease outbreaks, epidemics and pandemics. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which a Fund invests (or has a material negative impact on the operations of the Owl Creek or the service providers), the risks of loss can be substantial and could have a material adverse effect on a Fund and its investments. Furthermore, any such event may also adversely impact one or more individual shareholders' financial condition, which could result in substantial redemption requests by such shareholders as a result of their individual liquidity situations and irrespective of a Fund's performance.

Such transactions may be affected by direct purchases and sales of securities (and other instruments) by/from one Fund from/to another Fund or by increasing or decreasing a Fund's participation in securities that are held through special purpose vehicles in which two or more of the Funds are members. Owl Creek effects these transactions at a predetermined time, generally after the close of the market on the last business day of each month, pursuant to a formula that generally will result in each Fund holding substantially similar securities relative to each Fund's respective net asset value. With respect to publicly traded securities, Owl Creek effects these transactions based on the then current independent market price as of the applicable month end (although effected at month end, final valuations for equity securities are not finalized until the first business day of the following month, and the valuation of credit instruments is generally not finalized until approximately the fourth day of the following month). All cross transactions are affected at prices determined in accordance with the valuation procedures established by Owl Creek for all Funds. With respect to bank debt and similar securities held through special purpose vehicles, Owl Creek adjusts ownership participation through relative participating percentages. Neither Owl Creek nor any related party receives any compensation in connection with these rebalancing transactions. These cross transactions generally will be made without brokerage commissions being charged; except to the extent local market regulations require that transactions be affected on a security or a commodity market, as presently occurs with US Futures, US equity options and Hong Kong equities. (Owl Creek and its affiliates do not receive any commissions or compensation in respect of such transactions). A majority of securities owned by the Flagship Funds are currently being rebalanced. There may be a percentage of investments that Owl Creek does not rebalance due to, among other things, regulatory, business or tax considerations. Owl Creek may also affect cross transactions for non-rebalancing purposes in accordance with applicable law and the policies set forth herein. By executing a partnership agreement or subscription agreement, as applicable, each limited partner of a U.S. Fund and shareholder of an Offshore Fund has authorized the General Partner or Investment Manager, as applicable, on behalf of such limited partner or shareholder, to select one or more persons, who will not be affiliated with the General Partner or Investment Manager, to serve on a committee or as an independent representative, the purpose of which will be to consider and, on behalf of investors, approve or disapprove, to the extent required by applicable law,

principal transactions and certain other related party transactions (the “Independent Representative”). The General Partner and Investment Manager have appointed Mayflower Management Services (Bermuda) Limited to serve as the Independent Representative for the Funds. A principal or employee of Owl Creek or a related person may, from time to time, serve as a director with respect to companies, the securities of which are purchased on behalf of the Clients. In the event Owl Creek or a related person (i) obtains material non-public information in such capacity with respect to any such company or (ii) is subject to trading restrictions pursuant to the internal policies of Owl Creek, Owl Creek may be prohibited from engaging in transactions with respect to the securities or instruments of such company, which prohibition may have an adverse effect on the Clients. Additional Considerations From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of Owl Creek, its affiliates and its personnel (each an “Advisory Affiliate” and, collectively, the “Advisory Affiliates”). Owl Creek has established policies and procedures to monitor and resolve conflicts and will endeavor to resolve conflicts with respect to investment opportunities in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. In addition, Owl Creek may give advice or take action with respect to the investments of one or more Clients that may not be given or taken with respect to other Clients with similar investment programs, objectives, and strategies. Accordingly, although the Clients have similar strategies, they may not hold the same securities or instruments or achieve the same performance. These activities also may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more Clients. The Advisory Affiliates may also have ongoing relationships with companies whose securities are in or are being considered for the Clients. Owl Creek recognizes that conflicts may arise under such circumstances and will endeavor to treat all Clients fairly and equitably. Code of Ethics Owl Creek strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. In seeking to meet these standards, Owl Creek has adopted a Code of Ethics (the “Code”). The Code incorporates the following general principles that all employees are expected to uphold: employees must at all times place the interests of clients first; all personal securities transactions must be conducted in a manner consistent with the Code and any actual or potential conflicts of interest or any abuse of an employee’s position of trust and responsibility must be avoided; employees must not take any inappropriate advantage of their positions; information concerning the identity of securities and financial circumstances of the Clients, including the Clients’ investors, must be kept confidential; and independence in the investment decision-making process must be maintained at all times. The Code also places restrictions on personal trades by employees, including disclosing their personal securities holdings and transactions to Owl Creek on a periodic basis. Owl Creek generally prohibits purchases or short selling by employees of individual securities or purchases of IPOs. However, employees may be permitted to sell securities held in their personal accounts, purchase

securities to cover short positions held in their personal accounts, and engage in certain other transactions, in each case, where appropriate, with appropriate prior electronic or written approval. Employees are permitted to purchase and sell uncovered securities (including index funds, treasury securities and certain exchange-traded funds). Some clients may invest in the same or similar instruments. The Code includes restrictions designed to supervise the giving or receiving of gifts and entertainment, and employees’ outside business activities. The Code also includes restrictions on certain political contributions and related solicitation activities. Investors may request to review a copy of the Code by contacting Owl Creek at the address or telephone number listed on the first page of this document. The Altman Family Foundation The Altman Family Foundation (formerly known as The Jeffrey A. Altman Foundation, Inc., the “Foundation”), a charitable foundation for which Jeffrey Altman has investment authority, may purchase or sell the same securities as the Clients; however, Owl Creek has established a policy, as reflected in the Compliance Manual, whereby investment opportunities are generally first allocated to the Clients. Owl Creek may occasionally place trades on behalf of the Foundation or suggest an execution counterparty to the Foundation’s broker, it may perform incidental advisory services such as coordinating proxy votes. Accordingly, the Foundation may be deemed to be a client of Owl Creek. However, neither Mr. Altman nor Owl Creek receives any compensation in respect of the Foundation and Owl Creek does not provide investment recommendations to the Foundation. The Foundation is not included in client counts and Regulatory Asset Under Management as described on page 6 in the “Ownership and AUM” section of Item 5 of ADV Part 1. The Foundation is included in responses to 5C and 5D (n). Restrictions Due to Insider Information Owl Creek also maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information. Owl Creek’s personnel are required to certify their compliance with the Code, including the Insider Trading Policies, on a periodic basis. Owl Creek’s Insider Trading Policies prohibit Owl Creek and its personnel from trading for the Clients or themselves, or recommend trading, in securities of a company while in possession of material, non-public information (“Inside Information”) about the company, and from disclosing such information to any person not entitled to receive it. Because of its various activities, Owl Creek may have access to Inside Information or be restricted from effecting transactions in certain investments that might otherwise have been initiated. Owl Creek has designed and implemented policies and procedures reasonably designed to shield its investment professionals in most cases from access to Inside Information so that investment decisions may be made on the basis of public information only. Among other things, such policies seek to control and monitor the flow of Inside Information to and within Owl Creek, as well as prevent trading based on Inside Information. Accordingly, Owl Creek may not have access to Inside Information that other market participants or counterparties are eligible to receive. Notwithstanding such policies and procedures, there may be certain cases where Owl Creek either may receive Inside Information due to its various activities on behalf of itself or the Clients or may be restricted in acting for the Clients, resulting in limited liquidity or using such information for the

benefit of certain clients in specific securities. Owl Creek seeks to minimize those cases whenever possible, consistent with applicable law and its Insider Trading Policies, but there can be no assurance that such efforts will be successful and that such restrictions will not occur.

Owl Creek need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Accordingly, if Owl Creek determines in good faith that the commissions charged by a broker are reasonable in relation to the value of the brokerage and research products or services provided by such broker, the Clients may pay commissions to such broker in an amount greater than the amount another broker might charge. Soft Dollar Usage Owl Creek intends that the use of commissions or “soft dollars” to pay for “research” or “brokerage” products or services will come within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended. Generally, eligible research and brokerage products and services provided by broker-dealers may include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities, market data, market research related to securities (including pre-trade and post-trade analytics, software and other products that depend on market information to generate market research, including research on optimal execution venues and trading strategies) and other products and services providing lawful and appropriate assistance to Owl Creek in the performance of its investment decision-making responsibilities. Eligible brokerage products and services under Section 28(e) also may include communication systems related to the execution, clearing and settlement of securities transactions (i.e., connectivity services to broker-dealers and other relevant parties such as custodians, including dedicated lines and message services used to transmit orders), trading software used to route orders to market centers and software used to transmit orders. Consistent with Section 28(e), Owl Creek will make a good faith determination that client commissions paid to a broker are reasonable in relation to the value of the products or services provided by such broker. Also, consistent with Section 28(e), research and brokerage products or services obtained with "soft dollars" generated by one or more Clients may be used by Owl Creek to service one or more other Clients, including Clients that may not have paid for the soft dollar benefits. Owl Creek does not seek to allocate soft dollar benefits to Clients in proportion to the soft dollar credits the Clients generate. Where a product or service obtained with soft dollars provides both research and nonresearch assistance to Owl Creek (i.e., a "mixed use" item), Owl Creek will make a reasonable allocation of the cost which may be paid for with soft dollars. In making good faith allocations of

costs between administrative benefits and research and brokerage services, a conflict of interest may exist by reason of Owl Creek's allocation of the costs of such benefits and services between those that primarily benefit Owl Creek and those that primarily benefit the Clients. The portion of these services that was utilized for non-research or brokerage within Section 28(e) (e.g., compliance, operational and accounting functions) was borne by Owl Creek, and not the Clients. Although at present the Firm does not pay for any mixed-use items with soft dollars, the Firm may elect to do so again in the future. When Owl Creek uses client brokerage commissions (or markups or markdowns) to obtain research or other products or services, Owl Creek receives a benefit because it does not have to produce or pay for such products or services. Owl Creek may consider its receipt of such research or other products or services, as well as other factors, in determining what broker-dealer to select or recommend. All proposed soft dollar research agreements must be approved by the Compliance Officer, General Counsel, one of the Co-Chief Operating Officers or the Firm’s Brokerage Committee. Certain designated Owl Creek employees, subject to oversight from the Compliance Officer, General Counsel, and the Co-Chief Operating Officers, and/or the Brokerage Committee, in the case of commission sharing arrangements (“CSAs”), review soft dollar products and services periodically to: (1) determine compliance with Section 28(e); (2) confirm soft dollar balances; (3) ensure soft dollar bills are appropriately paid and; (4) as applicable, conduct a mixed-use analysis. The Firm’s Brokerage Committee periodically reviews the Firm's overall soft dollar activities. Owl Creek intends to maintain reasonable documentary evidence to substantiate its soft dollar compliance processes. CSAs are a form of soft dollar arrangement which allow the use of all or a portion of commissions from an executing broker to a third party who has supplied execution services and/or research to an investment manager. The Firm participates in CSAs to pay for research in a manner intended to come within the Section 28(e) safe harbor. Such arrangements are reviewed and approved by the Brokerage Committee periodically as described above. At least annually, Owl Creek considers the amount and nature of research and research services provided by broker-dealers, as well as the extent to which such services are relied upon, and attempts to allocate a portion of the brokerage business of its clients on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation but can (and often does) exceed the suggested level, because transactions are allocated on the basis of all of the considerations described above. In no case will Owl Creek make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. The soft dollar disclosures in this section are a brief summary of the procedures followed by Owl Creek in determining how to direct Client transactions to a particular broker-dealer in return for soft dollar benefits received and are not intended to be a full description of such procedures.

MiFID II provisions relating to research and inducements may cause certain European brokers or counterparties to no longer offer the Firm and its clients bundled research as part of their overall execution service. In such cases the applicable advisory clients may pay for such research with hard dollars as described in the expenses section of item 5. Additional Brokerage Considerations From time to time, brokers (including prime brokers such as Goldman, Sachs & Co., and Morgan Stanley & Co.) may assist the Funds in raising additional funds from investors, and representatives of Owl Creek may speak at conferences and programs sponsored by such brokers for investors interested in investing in hedge funds. Through such "capital introduction" events, prospective investors in the Funds would have the opportunity to meet with representatives of Owl Creek. Currently, neither Owl Creek nor the Clients compensate any broker for organizing such events or for any investments ultimately made by prospective investors attending such events, nor do they anticipate doing so in the future. Clients may accept subscriptions from investors who also provide services to the Clients, including brokers and their affiliates. Relationships such as the ones described above could be viewed as creating a conflict of interest that potentially could affect Owl Creek's ability to seek best execution. While our relationship with brokers may influence Owl Creek in deciding whether to use such broker in connection with brokerage, financing and other activities of the Clients, Owl Creek will not commit to allocate a particular amount of brokerage to a broker in any such situation. Furthermore, Owl Creek conducts periodic best execution reviews in an effort to identify and mitigate compliance risks associated with brokerage relationships, and to determine that Owl Creek is obtaining best execution for clients' accounts. Trade Allocation and Aggregation Policies and Procedures Owl Creek will generally execute transactions for Clients the Firm manages on an aggregated basis when Owl Creek believes that to do so will allow it to seek best execution and to negotiate more favorable commission rates or other transaction costs that might have otherwise been paid had such orders been placed independently. Instances in which client orders will not be aggregated include, but are not limited to, the following:

Clients directing Owl Creek to use certain broker/dealers, in which case such orders shall be separately effected; Traders and/or portfolio managers determining that the aggregation is not appropriate because of market conditions; Situations where portfolio managers must effect the transactions at different prices, making aggregation unfeasible; and A determination by the portfolio managers not to aggregate orders because of tax, legal, regulatory or administrative reasons. Administrative reasons may include counterparty or unaffiliated investment adviser approvals.

When aggregating orders, all Clients will be treated in a fair and equitable manner. Owl Creek will not aggregate orders unless aggregation is consistent with its duty to obtain best execution. Each Client that participates in an aggregated order will participate equitably, with transaction costs shared pro rata based on each Client's participation in the transaction. It is the policy of Owl Creek to allocate investment opportunities for the Clients fairly and equitably, to the extent possible, over

a period of time. Owl Creek, however, will have no obligation to purchase, sell or exchange any security or financial instrument for one Client which Owl Creek may purchase, sell or exchange for another Client if Owl Creek believes in good faith at the time the investment decision is made that such transaction or investment would be unsuitable, impractical or undesirable for a particular Client. Participation in specific investment opportunities may be appropriate for one or more Clients. Participation in such opportunities will be allocated on a fair and equitable basis, taking into account such factors as the relative amounts of capital available for new investments, (investor) eligibility, regulatory and legal requirements, tax considerations, risk considerations, investment guidelines, and the investment programs and portfolio positions of the Clients for which participation is appropriate, among other relevant factors. Orders may be combined for all such Clients, and if any order is not filled at the same price, they may be allocated on an average price basis. Similarly, if an order on behalf of more than one Client cannot be fully executed under prevailing market conditions (e.g., partial fills), the order may be allocated among the different Clients on a basis which Owl Creek considers fair and equitable. Although the Clients may pursue investment objectives that are similar, the portfolios of the Clients may differ as a result of purchases and withdrawals being made at different times and in different amounts, inflows and outflows of capital, as well as because of different tax and regulatory considerations, including investment restrictions. Owl Creek may give advice and recommend securities to certain Clients which may differ from advice given to, or securities recommended or bought for, other Clients. It is possible, for example, that particular Clients may have a long position in (or be a buyer of) a security in which one or more of the other Clients have a short position (or are sellers). Trade Errors Pursuant to the exculpation and indemnification provisions in the management agreements, Owl Creek, the General Partner or their respective affiliates or personnel will generally not be liable to the Funds for any error of judgment or for any action or inaction, absent willful misconduct, gross negligence or bad faith, and the Funds will generally be required to indemnify such persons against any losses they may incur by reason of any error of judgment, or any act or omission related to the Funds, absent willful misconduct, gross negligence or bad faith. As a result of these provisions, the Funds (and not Owl Creek, the General Partner or their respective affiliates or personnel) will be responsible for any losses resulting from trading errors and similar human errors, absent gross negligence, willful misconduct or bad faith. Trading errors might include, for example, keystroke errors that occur when entering trades into an electronic trading system or typographical or drafting errors related to derivatives contracts or similar agreements. Given the large volume of transactions executed by Owl Creek on behalf of the Funds, investors should assume that trading errors (and similar errors) will occur and that the Funds will be responsible for any resulting losses, even if such losses result from the negligence (but not gross negligence) of Owl Creek's personnel. Gains caused by trade errors (or similar errors) will typically be credited to the affected Funds.

In addition, Owl Creek issues investors written audited financial statements at least annually for the Funds in which they invest, generally within 90 days (but no later than the 120 days prescribed by the Custody Rule) after the end of period to which the audit relates. Owl Creek also issues investors in the U.S. Funds tax reports with respect to their investments in the relevant Funds.

Unless otherwise expressly disclosed to an investor, any fees paid to such placement agents that are paid by a Fund will offset the Management Fee or Incentive Allocation otherwise payable or allocable to Owl Creek. If a subscriber is introduced to the Funds through a placement agent, the arrangement, if any, with such placement agent will be disclosed to the subscriber.

into account the following factors: (i) the impact on the value of the investments; (ii) the anticipated associated costs and benefits; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. The Firm may also assist the Foundation with voting its proxies. In limited circumstances, Owl Creek may abstain or affirmatively decide not to vote a proxy where Owl Creek believes it is in the best interest of the Clients, considering such factors as costs and legal restrictions. When applicable, Owl Creek will generally refrain from moving securities out of margin accounts for the express purpose of ensuring the ability to vote, unless Owl Creek determines that it would be in the best interests of the Clients to do so. Not actively segregating securities could potentially result in a loss of the ability to vote shares, if they are re-hypothecated or otherwise unregistered to vote as of record date. The Clients generally do not have the ability to direct voting for a particular situation. Owl Creek's Proxy Policies include procedures to identify and address conflicts or potential conflicts that could arise between Owl Creek's own interests and those of the Clients. In order to avoid the perception of a potential conflict of interest, to the extent record date holdings of the Foundation (or Jeff Altman personal accounts) and the Firm’s advisory clients overlap, the Foundation (or Jeff Altman personal accounts) will generally vote in a manner consistent with the advisory clients. To the extent Jeffrey Altman wishes to vote a proxy on behalf of the Foundation (or himself) in a manner inconsistent with the above, the Foundation’s fiduciaries (or Jeff Altman if applicable) will inform the Firm's Compliance Officer or General Counsel, who will be required to evaluate and approve the decision. In the event that a material conflict of interest is found between Owl Creek and the Clients in voting proxies, Owl Creek will follow requirements in its Proxy Policies to ensure the proxy is voted in the best interests of the Clients. Owl Creek utilizes Glass, Lewis & Co. to assist in the coordination, voting, and record-keeping of proxies. Investors may request a copy of the Proxy Policies and the proxy voting record by contacting Owl Creek at the address or telephone number listed on the first page of this document. Class Action Lawsuits From time to time, Owl Creek may receive notices or initiate claims regarding class action lawsuits involving securities that are or were held by the Clients. Owl Creek reserves the right to serve as the lead plaintiff in class action matters. Owl Creek may refrain from submitting proofs of claim where it believes that either the recovery amounts are likely to be negligible or it cannot be assured of confidential treatment of the data submitted in connection with the proof of claim. Owl Creek uses the services of a third-party class action processor that works on a contingency basis to submit class action claims on behalf of certain clients.