Aksia LLC: investment adviser

Item 5: Fees and Compensation A. Advisory Fees and Compensation. Aksia’s fee schedule for its advisory services is omitted because this brochure will be delivered only to qualified purchasers as defined in section 2(a)(51)(A) of the Investment Company Act of 1940. To the extent Aksia and its members, employees and/or affiliates invest (directly or indirectly) in an Investment Management Client (as described in Item 7 below), such persons will not be subject to any management fees or any performance-based fees. B. Payment of Fees. Aksia generally charges its Advisory Clients a flat, fixed fee, although certain Advisory Clients pay an asset-based fee. Aksia generally charges its Investment Management Clients a percentage of assets under management. Some Investment Management Clients also pay performance-based fees. Clients may select the method by which to pay Aksia’s fees. Aksia typically bills Clients for fees incurred on a quarterly basis. C. Other Fees and Expenses. In addition to paying investment management or advisory fees, and, potentially, performance-based fees, Client assets that are invested in pooled investment vehicles will bear their pro rata share of the underlying fund’s operating and other expenses, including, but not limited to, legal expenses, internal and external accounting expenses, audit and tax preparation expenses, and organizational expenses. In addition, during the course of Aksia’s due diligence process on underlying private investment funds, Aksia engages specialized third parties to conduct investigations on key personnel of the funds’ managers. Clients may incur a one-time fee associated with an investigation on a new fund; Aksia does not retain any such fees. Aksia may also charge a Client for expenses related to travel outside of standard industry coverage specifically requested by the Client. Subject to the relevant governing documentation, other expenses that are typically borne indirectly by Investment Management Clients may include, without limitation, all costs and expenses incurred in connection with organizing, forming, operating, maintaining and dissolving entities through or in which investments may be made or held, as well as costs and expenses incurred in connection with the carrying or management of investments and all fees, costs and expenses incurred in connection with the evaluation, acquisition, structuring, monitoring, development, disposition or transfer of investments (whether or not consummated), including the costs and expenses associated with research related to Aksia’s investment management services and software and technology used to create, produce or deliver such research. In addition, Investment Management Clients may bear expenses related to credit facilities or other borrowings, bridge financing, and ratings agencies, as well as costs, fees and expenses related to third party service providers including, but not limited to, legal counsel, regulatory compliance, auditors tax advisors, expert networks, professional consultants, fund administrators, loan administrators, custodians/banks, trustees and valuation agents. Investment Management Clients may bear the costs associated with foreign exchange transactions for hedging purposes. Investment Management Clients may also bear fees, costs and expenses related to insurance premiums paid or payable in connection with the activities of the Aksia Client fund in which they are invested, the general partner and the investment adviser, including errors, omissions, fidelity, general partner liability, directors’ and officers’ liability, cybersecurity and similar coverage. D. Prepayment of Fees. Some Clients pay Aksia’s fees in advance. In the event that the contract is terminated before the end of a billing period, such Clients may obtain a prorated rebate for the pre-paid fee attributable to the period between the termination date and the last day of the billing period.

In particular, Aksia’s procedures relating to the allocation of investment opportunities set forth the process by which Aksia allocates investments among accounts, and Aksia has implemented procedures to document and review such allocations, as described in Item 16. Aksia employs a wide range of investment objectives and strategies for its Clients. These differing objectives and strategies raise potential conflicts of interest. For example, Aksia may evaluate the purchase of an investment opportunity for one Client account while simultaneously evaluating the sale of such opportunity for a different Client. In specific instances, these differing strategies may result in Aksia buying and selling different securities and instruments within an issuer’s capital structure for different Clients. Accordingly, it is possible that one Client may acquire an instrument that is senior in the capital structure of an issuer relative to an instrument for a different Client that is more junior in the capital structure. In certain circumstances, such as if the credit quality of the issuer deteriorates, the Aksia may owe conflicting fiduciary duties to multiple Clients, in that action taken to protect the interest of one set of holders may be detrimental to, or conflict with the interests of, other holders of that issuer’s securities or instruments. When the Aksia causes its Clients to take opposite positions with respect to a particular security or investment, or to invest in securities of an issuer with varying seniority in the issuer’s capital structure, actions taken by the Askia for one set of Clients may disadvantage other sets of Clients. In addition, as part of an investment management solution for a client, Aksia may propose a portfolio that includes an investment in one or more Aksia advised or sub-advised commingled funds. The ability to advise a Client to invest in another Aksia-advised fund causes a conflict of interest, as Aksia may be incentivized to invest in (i) Aksia-advised underlying funds or investments, as opposed to underlying funds or investments sponsored or managed by potential competitors of Aksia; or (ii) certain Aksiaadvised underlying funds or investments over other Aksia-advised funds or investments, including where such funds or investments have differing levels of fees or have different relative capital needs. Any such investment by an Aksia Client would be made on arm’s length terms (or otherwise consented to or approved, e.g., by the Client), subject to Aksia’s fiduciary duties to its Clients.

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies. Aksia provides investment advice and management services to its Clients on a range of private market investment structures, including primary fund investments, secondaries, co-investments, and direct investments (each, an “Investment Opportunity”). Aksia’s method of analysis focuses on due diligence on such Investment Opportunities presented in consistent, opinionated reports. With respect to investments managed by an underlying portfolio manager (“Portfolio Manager”), for primary fund investments, Aksia endeavors to analyze a Portfolio Manager’s strategy, risk management process, quality of investment professionals, operations and infrastructure, regulatory compliance, and ability to produce attractive longterm, risk-adjusted investment results, among other factors. For secondary fund investments, Aksia employs a data-driven approach that includes quantitative and qualitative analysis, focusing on pricing dynamics, historical and projected cash flows, and underlying portfolio quality. With respect to coinvestments and direct investments (each, a “Co-Investment”), Aksia seeks to analyze factors including, but not limited to, the industry/market context for the asset, the co-investment sponsor, historical financial performance and projected returns. B. Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies. While Aksia advises multiple Client accounts that each face different risks depending on the relevant investment strategy, all such investments risk the loss of capital. Aksia’s due diligence process seeks to address and mitigate such risk; however, there is no guarantee or assurance that Aksia’s investment advice or recommendations will be successful. Aksia itself may face the following risks: Effects of Health Crises and Other Catastrophic Events. Health crises, such as pandemic and epidemic diseases, as well as other catastrophic events that interrupt the expected course of events, such as natural disasters, war, political conflicts or civil disturbance, acts of terrorism, power outages, sanctions and other unforeseeable and external events, and the public response to or fear of such diseases or events, have and may in the future have an adverse effect on Clients' investments and Aksia’s operations. For example, any preventative or protective actions that governments may take in respect of such diseases or events may result in periods of business disruption and inability to conduct in person diligence, and reduced or disrupted operations that impact Investment Opportunities. In addition, under such circumstances Aksia’s operations and those of other service providers could be reduced, delayed, or otherwise disrupted. Further, the occurrence and pendency of such diseases or events could adversely affect the economies and financial markets either in specific countries or worldwide. Cybersecurity Risk. The information and technology systems of Aksia and of key service providers to Aksia and its Clients may be vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, and usage errors by their respective professionals. For instance, cyber-attacks may interfere with Aksia’s provision of services, cause the release of confidential information, including private information about Clients, or cause reputational damage. Additionally, cyber-attacks or security breaches (e.g., hacking or the unlawful withdrawal or transfer of funds) affecting any of Aksia’s key service providers may cause significant harm to Aksia and its Clients. Although Aksia has implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for Aksia to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of Aksia or its Client accounts and result in a failure to maintain the security, confidentiality or privacy of sensitive data. Custody Risk. There are risks involved in dealing with the custodians who hold Client cash and securities. There is no guarantee that the custodians that Clients may use from time to time will not become bankrupt or insolvent. While both the U.S. Bankruptcy Code and the Securities Investor Protection Act of 1970

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss seek to protect customer property in the event of a bankruptcy, insolvency, failure, or liquidation of a custodian, there is no certainty that, in the event of a failure of a custodian, the Client would not incur losses due to its assets being unavailable for a period of time, the ultimate receipt of less than full recovery of its assets, or both. Allocation of Investment Opportunities. Aksia may evaluate and recommend investment opportunities suitable for multiple Clients. In instances where Aksia allocates such opportunities, Aksia will do so on a basis that Aksia believes in good faith to be fair and reasonable. Aksia may evaluate opportunities for allocation to a Client using a variety of factors including a Client’s investment objectives, constraints, risk tolerance, program size, investment size range, target return profile, liquidity, and previous interest in the opportunity or in other opportunities or funds sourced from or managed by the same general partner, among other factors. As a result, the participation of Clients in investment opportunities may vary and there may be investments where a Client does not participate or does not participate to the same extent as other Client accounts due to Aksia’s good faith evaluation of some or all of the foregoing factors. Aksia acts as a discretionary investment manager to one or more Registered Investment Companies (each, a “Registered Fund’). Any Co-Investment opportunities in which both a Registered Fund and certain other Aksia Client funds invest must comply with either the exemptive relief Aksia has been granted by the SEC, or with SEC no-action guidance. The participation of a Registered Fund may impact the ability of the Registered Fund or of certain Aksia Client funds to make an investment or a follow-on investment. Valuation of Portfolio Holdings. There are various conflicts of interest associated with the valuation of client assets, in particular, higher valuations of client assets may result in increased fees. In addition, inflated valuations may result in better performance which may assist in marketing for Aksia. Conflicts of interest may be heightened in the case of assets that do not have readily ascertainable market values. To address these conflicts, Aksia has adopted and implemented policies and procedures for the valuation of client investments, including the formation of a valuation committee to oversee the valuations process, and the review of fair-valued investments. Aksia Clients typically invest in private market securities, for which there are not typically readily available market prices. In addition, restrictions on resale or the absence of a liquid secondary market could adversely affect Aksia’s ability to determine the value of such holdings. The sale price of securities that are not readily marketable could be lower or higher than Aksia’s most recent determination of their fair value. Valuation of assets involves uncertainties and the exercise of judgment and discretion. If such valuations should prove to be incorrect, the net asset value of a Client fund could be adversely affected. There can be no assurance that the value of a portfolio holding as reported will ultimately be realized. In addition, subject to compliance with a Client’s particular investment guidelines and restrictions, Aksia may recommend investments that include the following potential risks: Lack of Diversification. Depending on a Client’s investment mandate, the Client’s portfolio may not be diversified among a wide range of types of investments, countries or industry sectors. Accordingly, such Client portfolio may be subject to more rapid change in value than would be the case if Client’s portfolio was more diversified.

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Illiquid Investments. Aksia, and/or the underlying Portfolio Managers with which its Clients invest, may make investments that are not at the time of investment, and may never be, publicly traded. These investments may be difficult to value and sell, or otherwise liquidate, and the risk of such investments is generally much greater than the risk of investing in publicly traded companies. Private investments are not subject to the same disclosure and reporting requirements that are generally applicable to companies with publicly traded securities, nor is the trading of such non-publicly traded securities regulated by any government agency. Accordingly, the protections accorded by such regulation are not available in making such investments. To the extent that there is no liquid trading market for particular investments, such investments may not be able to be liquidated or may not be able to be liquidated at a profit. These markets may be inactive during an economic downturn or a credit crisis and in any event often have lower volumes than publicly traded securities even in normal market conditions. If there is no readily available market for these investments, a Client will be required to carry these investments at fair value as determined in accordance with Aksia’s Valuation Policy. In addition, in certain circumstances governmental or regulatory approvals may be required for the disposal of an investment, or the sale of an illiquid investment may be prohibited by contract or for legal or regulatory reasons. Market Risk. The market value of a Client’s portfolio will move up or down, sometimes rapidly and unpredictably. These fluctuations may cause a portfolio holding to be worth less than the price originally paid for it, or less than it was worth at an earlier time. Market risk may affect a single issuer, industry, sector of the economy or the market as a whole. Global economies and financial markets are increasingly interconnected, which increases the probabilities that conditions in one country or region might adversely impact issuers in a different country or region. Conditions affecting the general economy, including political, social, or economic instability at the local, regional, or global level may also affect the market value of a security. Investing outside the United States may involve greater risks than investing in the United States. These risks include: (i) less publicly available information; (ii) potential lack of uniform accounting, auditing and financial reporting standards; (iii) varying levels of governmental regulation and supervision; and (iv) the difficulty of enforcing legal rights in a non-U.S. jurisdiction and uncertainties as to the status, interpretation and application of laws. The transaction costs of buying and selling non-U.S. securities, including brokerage, tax and custody costs, may be higher than those involved in U.S. transactions. Furthermore, many non-U.S. financial markets, while generally growing in volume, have, for the most part, substantially less volume than U.S. markets, and securities of many non-U.S. companies are historically less liquid and their prices historically more volatile than securities of comparable U.S. companies. The economies of individual non-U.S. countries may also differ favorably or unfavorably from the U.S. economy. Short Selling. Short selling transactions expose a Client to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein the borrower may be compelled, at the most disadvantageous time, to replace the borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. Private Markets Investments. The activity of identifying, completing, and realizing attractive private equity, private credit and real assets investments is highly competitive, difficult and involves a high degree of uncertainty. Private markets investments may require a long-term commitment, with no certainty of return. Certain private markets investments may be in securities that become publicly traded. Such investments may involve economic, political, interest rate and other risks, any of which could result in an adverse change in the market price. The regulatory considerations affecting the ability of Aksia’s clients

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss to achieve their investment objectives are complicated and subject to change. In addition, other legal, tax and regulatory changes could occur that may adversely affect the private markets asset class. Real Estate Investments. Real property investments are subject to varying degrees of risk. The yields available from equity investments in real estate depend in large part on the amount of income generated and expenses incurred. If the investments do not generate revenues sufficient to meet operating expenses, including debt service, tenant improvements, leasing commissions and other capital expenditures, investors may be required to fund or borrow additional amounts to cover fixed costs, and the cash flow of such Client account (and, with respect to a Portfolio Manager, its ability to make distributions to investors) will be adversely affected. All real estate investments are speculative in nature and the possibility of partial or total loss of capital exists. Revenues and the value of properties may be adversely affected by a number of factors, including: the national, state and local economic climate and real estate conditions; uninsured losses or delays from casualties or condemnation (such as hurricanes, floods and earthquakes); increasing operating costs (including real estate taxes and utilities) which may not be passed through to tenants; and acts of God and other factors beyond our control. Inflation Risk. Client accounts may be subject to inflation risk. Inflation risk is the risk that the value of investments or income from investments will be lower in the future as inflation decreases the value of money. As inflation increases, the value of the investments in a client’s account can decline. Investment and Due Diligence Process. Before making investments, Aksia will conduct due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to each investment. When conducting due diligence, Aksia may be required to evaluate important and complex business, financial, tax, accounting and legal issues. When conducting due diligence and making an assessment regarding an investment, Aksia will rely on the resources reasonably available to it, which in some circumstances whether or not known to Aksia at the time, may not be sufficient, accurate, complete or reliable. Due diligence may not reveal or highlight matters that could have a material adverse effect on the value of an investment. In addition, Aksia may rely on third parties, including other investment managers with which its Clients invest, for financial metrics. Such financial metrics may be adjusted or normalized and Aksia is not able to independently verify the accuracy, completeness, or basis of such figures. Adjusted metrics may differ materially from those derived from audited financial statements prepared in accordance with GAAP or IFRS. Based on its due diligence process, Aksia develops various expectations for returns and risk. Past performance is not indicative of future results, and there can be no assurance that Aksia will achieve investment results comparable to those previously achieved. Client assets may be invested in funds sponsored and managed by other investment managers. The performance of such funds can depend on the ability of the relevant investment manager to identify and consummate suitable investments and to dispose of investments at appropriate times. Clients also face the risk of loss associated with the possibility of personnel of an investment manager misappropriating client assets.

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss C. Risks Associated With Types of Securities that are Primarily Recommended (Including Significant, or Unusual Risks). Non-U.S. Securities. Aksia Clients may invest in foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations, which can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. One or more of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. Debt Securities. Debt securities of all types of issuers may have speculative characteristics, regardless of whether they are rated. 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 in accordance with the terms of the obligations. The value of investments in loans may be detrimentally affected to the extent a borrower defaults on its obligations, there is insufficient collateral and/or there are extensive legal and other costs incurred in collecting on a defaulted loan. Aksia Clients may attempt to minimize this risk by maintaining low loan-to-liquidation values with each loan and the collateral underlying the loan. However, there can be no assurance that the value assigned by the Partnership to collateral underlying a loan can be realized upon liquidation, nor can there be any assurance that collateral will retain its value. In addition, some loans will be supported, in whole or in part, by personal guarantees made by the borrower or a relative or guarantees made by a corporation affiliated with the borrower. The amount realizable with respect to a loan may be detrimentally affected if a guarantor fails to meet its obligations under the guarantee. Moreover, the value of collateral supporting loans may fluctuate. In addition, active lending/origination by Aksia Clients may subject them to additional regulation, as well as possible adverse tax consequences to investors therein. Finally, there may be a monetary, as well as a time cost involved in collecting on defaulted loans and, if applicable, taking possession of and subsequently liquidating various types of collateral. Emerging Markets. There are greater risks associated with investments in issuers located in less developed countries than investments in securities of issuers located in the U.S. and other developed markets. Political risk for many developing countries is a significant factor. During certain social and political circumstances, governments may be involved in policies of expropriation, confiscatory taxation, nationalization, intervention in the securities market and trade settlement, and imposition of foreign investment restrictions and exchange controls. In comparison to more developed markets, trading volumes in emerging markets may be lower, which can result in a lack of liquidity and greater price volatility. Equity Securities. The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, an investor may suffer losses if it invests in equity instruments of issuers whose performance diverges from expectations or if equity markets generally move in a single direction and the investment has not been hedged against such a general move. An investment also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. Asset-Backed Securities. Investments in asset-backed securities are subject to interest rate risk and, to a lesser degree, prepayment risk. Asset-backed securities are subject to additional risks in that, unlike mortgage-backed securities, asset-backed securities generally do not have the benefit of a security interest in the related collateral. Each type of asset-backed security also entails unique risks depending

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss on the type of assets involved and the legal structure used. In addition, asset-backed securities are subject to credit risk. There is also the possibility that recoveries on repossessed collateral may not be available to support payments on these securities because of the inability to perfect a security interest in such collateral. Co-Investments. Aksia may establish relationships with the managers or sponsors of private markets funds (“Co-Investment Sponsors”) that present potential co-investment opportunities that may be suitable for Clients. Investments in such co-investment opportunities can be made directly or indirectly, including through participation interests in any underlying investments by an entity managed by the relevant CoInvestment Sponsor, participating in such investments alongside other entities managed by the relevant Co-Investment Sponsor or investing through a co-investment vehicle sponsored by the relevant CoInvestment Sponsor. There can be no guarantee that sufficient opportunities will be presented by CoInvestment Sponsors. In addition, Clients will be subject to restrictions with respect to structuring, ongoing operation and exiting any such investments in light of the Co-Investment Sponsors’ requirements. Subjective decisions made by a Co-Investment Sponsor may cause Clients to incur losses or to miss profitable opportunities on which they would otherwise have capitalized. Commodity Futures and Options. Investments in commodity futures and options face the risk of highly volatile markets, which are influenced by factors such as changing supply and demand relationships, governmental programs and policies, national and international political and economic events and changes in interest rates. In addition, because of the low margin deposits normally required in commodity futures trading, a high degree of leverage may be typical of a pooled investment vehicle engaging in commodity futures trading. As a result, a relatively small price movement in a commodity futures contract may result in substantial losses to such a pooled investment vehicle. Commodity options, like commodity futures contracts, are speculative, and their use involves risk. Specific market movements of the cash commodity or futures contract underlying an option cannot be predicted, and no assurance can be given that a liquid offset market will exist for any particular futures option at any particular time. Derivatives. Investments in swaps, and certain options and other custom derivative or synthetic instruments, are subject to the risk of nonperformance by the counterparty to such instrument, including risks relating to the financial soundness and creditworthiness of the counterparty. In addition, investments in derivative instruments require a high degree of leverage, meaning the overall contract value (and, accordingly, the potential for profits or losses in that value) is much greater than the modest deposit used to buy the position in the derivative contract. Derivative instruments can also be highly volatile. The prices of derivative instruments and the investments underlying the derivative instruments may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Client or a Portfolio Manager. Further, transactions in derivative instruments are not undertaken on recognized exchanges, and will expose the Client’s account to greater risks than regulated exchange transactions that provide greater liquidity and more accurate valuation of securities. Distressed Securities. Investments in unrated or low grade debt securities of distressed companies are subject to greater risk of loss of principal and interest than higher-rated debt securities. Also, securities of distressed companies are generally more likely to become worthless than the securities of more financially stable companies. Distressed securities include those of a company currently in, or expected to be subject to, bankruptcy, restructuring, an operational turn-around or other similar events. There is substantial uncertainty concerning the outcome of transactions involving such issuers. In addition, evaluating credit risk for foreign debt securities involves greater uncertainty because credit rating agencies throughout the world have different standards, making comparison across countries difficult. Fixed-Income and Debt Securities. Investments in fixed-income and debt securities such as bonds, notes and asset-backed securities residential mortgage backed securities, commercial mortgage backed

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss securities, investment grade corporate bonds, non-investment grade corporate bonds, loans, sovereign bonds and U.S. government debt securities and financial instruments that reference the price or interest rate associated with these fixed income securities, subject a Client’s portfolio to the risk that the value of these securities overall will decline because of rising interest rates. Similarly, portfolios that hold such securities are subject to the risk that the portfolio’s income will decline because of falling interest rates. Investments in these types of securities will also be subject to the credit risk created when a debt issuer fails to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that debt to decline. Aksia may also invest in debt securities which are not protected by financial covenants or limitations on additional indebtedness. Most fixed income instruments trade in over-the-counter transactions and lack the benefit of transparent exchange pricing. Bids and asks for these instruments are generally wider than equity securities, and trading is less frequent. These factors may cause distortions and/or volatility in the prices of fixed income-related instruments. Lastly, investments in lower-rated debt securities are also subject to the risk that the securities may fluctuate more in price and are less liquid than higher-rated securities because issuers of such lower-rated debt securities are weaker financially and are more likely to encounter financial difficulties and be more vulnerable to adverse changes in the economy. Forward Contracts. Forward contracts are not traded on any exchange and are therefore not guaranteed by any exchange or clearinghouse and are subject to the creditworthiness of the counterparty of the trade. There have been periods during which certain counterparties have refused to continue to quote prices for forward contracts or have quoted prices with an unusually widespread. Forward contracts may be traded with only one or a few counterparties, which may create more liquidity problems than if such arrangements were made with numerous counterparties. The risk of market illiquidity or disruption could result in major losses. Exchange Traded Funds (“ETFs”). Investments in ETFs represent shares of ownership in either funds or unit investment trusts that hold portfolios of common stocks, bonds or other instruments, which are designed to generally correspond to the price and yield performance of an underlying index. A primary risk factor relating to ETFs is that the general level of stock or bond prices may decline, thus affecting the value of an equity or fixed income ETF, respectively. An ETF may also be adversely affected by the performance of the specific sector or group of industries on which it is based. Moreover, although ETFs are designed to provide investment results that generally correspond to the price and yield performance of their underlying indices, ETFs may not be able to exactly replicate the performance of the indices because of various sources of tracking error, including their expenses and a number of other factors. REITs. REITs are affected by underlying real estate values, which may have an exaggerated effect to the extent that REITs concentrate investments in particular geographic regions or property types. Investments in REITs are also subject to the risk of interest rate volatility. Further, rising interest rates will cause investors in REITs to demand a higher annual yield from future distributions, which will in turn decrease market prices for equity securities issued by REITs. REITs are subject to risks inherent in operating and financing a limited number of projects because they are dependent upon specialized management skills and have limited diversification. REITS depend generally on their ability to generate cash flow to make distributions to investors. Sovereign Debt. A Client may invest in sovereign debt issued by governments, their agencies and instrumentalities either in the currency of their domicile or in a foreign currency. Investors in sovereign debt may be asked to participate in debt restructuring, including the deferral of interest and principal payments, and may also be requested by the issuer to extend additional loans. It is impossible to predict whether the strategies will be able to successfully avoid losses relating to sovereign default. There is no current means of collecting on defaulted sovereign debt as part of bankruptcy or other proceedings. In addition to general default risk relating to sovereign debt, if sovereign debt is denominated in a currency other than

In connection with the use of futures contracts and options, there may be an imperfect correlation between the change in market value of a security and the prices of the futures contracts and options in the Client’s account. In addition, investments in security futures and options may encounter a lack of a liquid secondary market for a futures contract and the resulting inability to close a futures position prior to its maturity date.

Aksia LLC and certain of its wholly owned subsidiaries, including Aksia CA LLC, Aksia Japan Co., Ltd., Aksia Europe Limited, Aksia Hong Kong Limited, Aksia CH LLC and Aksia ME Ltd, based in California, Tokyo, London, Hong Kong, Switzerland and Dubai, respectively, assist Aksia in providing research and investment advisory services to Clients on private investment funds. Aksia CA LLC is a relying adviser to Aksia LLC, Aksia Japan Co., Ltd. is registered with the Japanese Financial Services Agency, Aksia Europe Limited is authorized by the U.K. Financial Conduct Authority, Aksia Hong Kong Limited is registered with the Hong Kong Securities and Futures Commission, Aksia CH LLC is authorized by the Swiss Financial Market Supervisory Authority, and Aksia ME Ltd. is authorized by the Dubai Financial Services Authority. In addition, Aksia LLC wholly owns a number of general partner entities, each of which serves as a general partner to an Aksia client fund. Lastly, Aksia Information Technology PC, located in Athens, Greece, provides information technology, research, advisory and other support services to Aksia LLC and its affiliates, and Manager Portal, LLC, a wholly owned subsidiary of Aksia LLC, is a technology platform designed for investment managers to share information directly with current and prospective investors. D. Material Conflicts of Interest Relating to Other Investment Advisers. Not applicable.

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics. Aksia has adopted a Code of Ethics (the “Code”) that obligates Aksia and its supervised persons to put the interests of Aksia’s Clients before their own interests and to act honestly and fairly in all respects in their dealings with Clients. All of Aksia’s personnel are also required to comply with applicable federal securities laws. Clients or prospective clients may obtain a copy of the Code by contacting Maya Fishman at (212) 710-5771 or maya.fishman@aksia.com. Aksia and its Supervised Persons may give and/or receive gifts, services or other items to/from any person or entity that does business with or potentially could conduct business with or on behalf of Aksia. Aksia has adopted policies and procedures governing gifts and business entertainment which includes preclearance of gifts and business entertainment in excess of certain de minimis thresholds and pre-clearance by the CCO or her delegate prior to giving/receiving gifts above a certain de minimis threshold. In the course of their business activities, Aksia or its related persons may come into possession of confidential or material nonpublic information about issuers. Aksia is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a Client. Aksia maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Aksia is meeting its obligations to Clients and remains in compliance with applicable law. In certain circumstances, Aksia may possess certain confidential or material, nonpublic information that, if disclosed, may be material to a decision to buy, sell or hold a security, however, Aksia will be prohibited from communicating such information to Clients or using such information for Clients’ benefit. In such circumstances, Aksia will have no responsibility or liability to Clients for not disclosing such information to Clients (or the fact that Aksia possesses such information), or not using such information for Client’s benefit, as a result of following Aksia’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. B. Client Transactions in Securities where Adviser has a Material Financial Interest. While Aksia does not directly invest in any securities that Aksia or a related person recommends to Clients, there are certain circumstances where Aksia may recommend, purchase or sell for its Clients funds managed by Portfolio Managers that are affiliated with Clients of Aksia. This can create the perception that Aksia is recommending a Portfolio Manager because of its affiliation with a Client of Aksia. Aksia addresses this potential conflict of interest via policies and procedures reasonably designed to ensure that its activities are carried out in compliance with applicable regulatory requirements and with the best interests of Clients in mind. Such policies and procedures include a screening of such potential investment through Aksia’s extensive due diligence process comprised of multiple layers of review by multiple individuals. C. Investing in Securities Recommended to Clients. Aksia’s Code prohibits Aksia or its supervised persons from directly executing personal securities transactions of any kind in any securities on a restricted securities list maintained by the compliance department. However, as described in Item 7 above, from time to time, Aksia may also form investment vehicles owned by Aksia, its members, its employees and/or its affiliates, that invest (directly or indirectly) in Investment Management Clients (each, a “GP Commitment”). This arrangement creates a conflict of interest because Aksia or its related persons has an incentive to favor Clients in which it owns a financial interest over its other Clients. In addition, supervised persons also may invest personally in the Calamos Aksia Funds described in Item 4 on the same terms as other investors. These investments are subject to Aksia’s Code and personal trading policies. Aksia addresses the potential conflicts of interest created by employee investments in securities recommended to clients via the implementation of its policies and procedures relating to the allocation of investment opportunities. All of Aksia’s supervised

This poses a conflict of interest for Aksia in its recommendations to its Clients. To mitigate this conflict, Aksia would disclose its pecuniary interest in such Client Affiliated Managers to its Clients and take other steps to maintain Aksia’s objectivity. Clients can also instruct Aksia to avoid making investment allocations to Client Affiliated Managers. D. Conflicts of Interest Created by Contemporaneous Trading. Not applicable.

Accordingly, when a Client directs brokerage to a specific broker, Aksia requires that (i) the Client provides such direction in writing to Aksia and (ii) Aksia provide the Client with appropriate written disclosure, which will be acknowledged by the Client. In certain limited circumstances, Aksia may receive a distribution in kind and need to dispose of such investment. In such circumstance, Aksia would consider a number of factors in selecting a broker-dealer to execute such transaction and determine the reasonableness of the broker-dealer’s compensation. Such factors include reputation, financial strength and stability, net price, and efficiency of execution. Aksia is not obligated to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Aksia would not receive research or other products or services other than execution from a broker-dealer in connection with a Client’s securities transaction, and as such would not use “soft dollars.”

Factors Prompting a Non-Periodic Review of Accounts. Significant market events affecting underlying funds in Client accounts, changes in the investment objectives or guidelines of a particular Client, or specific arrangements with particular Clients may trigger reviews of Client accounts on other than a periodic basis, including weekly or bi-weekly. C. Content and Frequency of Regular Account Reports. For Clients that subscribe to Aksia’s operations and accounting services, each Client (or the investor in each vehicle) receives written reports pursuant to the terms of each Client’s agreement, but in any event at least monthly. Aksia’s Clients also have ongoing access to research, analytics, portfolio tools, and reporting through Aksia’s password protected website. Frequency of reports depends on certain triggering events which may occur intra-month, monthly, quarterly and annually.

Investors in these Client Funds receive audited financial statements within 120 or 180 days of the end of the Client Fund’s fiscal year, as applicable. Client Fund investors that have not received audited financial statements in a timely manner should contact Aksia immediately. With respect to other Client funds, Aksia has engaged an independent auditor to perform an actual examination once during each calendar year, in order to verify the funds and securities of such Client Funds.

Item 16: Investment Discretion Aksia provides investment advisory services on a discretionary basis to some of its Investment Management Clients. Please see Item 4 for a description of limitations such Investment Management Clients may place on Aksia’s discretionary authority. Prior to assuming full or limited discretion in managing an Investment Management Client’s assets, Aksia enters into an investment management agreement or other agreement that sets forth the scope of Aksia’s discretion. Any limitations on such discretion are individually agreed to between the Investment Management Client and Aksia and memorialized in the respective agreement with Aksia. Such limitations may include: limits on Aksia’s ability to purchase or sell securities without the Investment Management Client’s prior written consent, prohibitions from investing in certain types of strategies, diversification constraints, and sector or strategy allocation constraints. Aksia’s procedures require the objective allocation of general investment opportunities to ensure fair and equitable allocation among Client accounts. In the event there is limited capacity in a general investment opportunity in which multiple Clients are interested, Aksia will first evaluate the opportunity in light of a number of factors, including, but not limited to the investment guidelines and restrictions relevant to each Client and the specifics of the proposed investment, in order to determine whether the opportunity could be suitable for the Client. Once Aksia has identified the Clients for which the opportunity may be suitable, Aksia will reach out to each Client to gauge such client’s interest in investing. When Aksia has received responses from the identified Clients, Aksia will advise the underlying manager offering the general investment opportunity which of Aksia’s Clients are interested in investing in its vehicle and request that the manager determine the allocations to the various Aksia Clients. Aksia will first recommend a co-investment opportunity (a “Co-Investment”), to Clients for which (i) Aksia has an obligation to perform co-investment sourcing services and (ii) such opportunity is consistent with the relevant Client’s co-investment program preferences (“Participating Clients”), subject to any limitations placed upon Aksia by the underlying manager offering the Co-Investment. Aksia will then submit an indication of interest to the manager, specifying a distinct amount of the opportunity to be made available for each eligible Participating Client. In the event of a Co-Investment opportunity with scarce capacity, the underlying manager offering the Co-Investment opportunity will generally determine the allocations among Aksia’s relevant Participating Clients. If the underlying manager delegates full or partial authority to Aksia, Aksia will seek to allocate the investment to Participating Clients in a fair and equitable manner with a preference towards a pro rata allocation based on interest. Following such allocation, if there is an additional excess allocation remaining, such excess allocation may be offered to any client of Aksia or to any third party, in each case selected by Aksia in its sole discretion. Aksia will first recommend a secondary opportunity (a “Secondary”) to Clients that have specifically contracted with Aksia to provide Secondary sourcing services and that have Secondary program preferences and capabilities that would allow for participation in the Secondary opportunity. Once Aksia determines the interest for each Client, Aksia will seek to directly or indirectly allocate the opportunity among such Clients pro-rata based on interest. If the seller is unable to allocate the opportunity across multiple Clients, Aksia will then use a rotation approach and review the date of each eligible Client’s most recent offer of a Secondary opportunity. The Client with the most time elapsed since its last Secondary offer will be offered the Secondary opportunity. If the relevant Client chooses not to submit a bid in respect of such Secondary opportunity, then the process will be repeated with the next Client based on the time elapsed since the last Secondary offer until a bid is submitted in respect of the opportunity, or all identified Clients have been offered the opportunity. If a bid has still not been submitted in respect of such opportunity, the opportunity may then be offered to Clients for which Aksia is not expressly contractually obligated to perform Secondary sourcing services but for whom such opportunity may not be consistent with the relevant client’s general investment preferences and capabilities.

Where such prior written notice is received, Aksia will vote proxies in accordance with such written instructions received from the Investment Management Client, provided that such instructions are provided to Aksia in a timely manner. If a material conflict of interest between Aksia and an Investment Management Client exists, Aksia will determine whether voting in accordance with the guidelines set forth in the proxy voting policies and procedures is in the best interests of the Investment Management Client or take some other appropriate action. Aksia does not have proxy voting authority with respect to the Advisory Clients or Research Clients. Clients may obtain a copy of Aksia’s proxy voting policies and procedures and information about how Aksia voted an Investment Management Client’s proxies by contacting Maya Fishman at (212) 710-5771 or maya.fishman@aksia.com.