Alphadyne Asset Management LP: investment adviser

Alphadyne Asset Management Holdings Limited (the “JP Sub-Adviser”) was established on February 12, 2016 as a Cayman Islands Limited Liability Company. The JP Sub-Adviser has a branch office in Tokyo, Japan and is registered with the local Japanese regulator, the Kanto Local Finance Bureau, to provide discretionary investment management services. The JP Sub-Adviser is wholly owned by the Investment Manager.

Alphadyne Asset Management (Hong Kong) Limited (the “HK Sub-Adviser”) was established in January 2018 as a Hong Kong private limited company. The HK Sub-Adviser has an office in Hong Kong and is licensed by the Hong Kong Securities and Futures Commission (“SFC”) to conduct Type 9 (asset management) regulated activities in Hong Kong. The HK Sub-Adviser is wholly owned by the Investment Manager. Alphadyne (Singapore) Pte. Ltd. (the “SG Sub-Adviser”) was established in December 2019 as a Singapore limited company. The SG Sub-Adviser has an office in Singapore and has obtained a Capital Markets Services License from the Monetary Authority of Singapore to conduct regulated activities in Singapore. The SG Sub-Adviser is wholly owned by the Investment Manager.

Alphadyne Asset Management Fondsmæglerselskab (Europe) A/S (the “DK Sub-Adviser” and, together with the UK Sub-Adviser, the JP Sub-Adviser, the HK Sub-Adviser, and the SG Sub-Adviser, the “SubAdvisers”) was established in March 2024 as a Danish public limited company. The DK Sub-Adviser has an office in Denmark and has obtained a MiFID Investment Firm license from the Danish Financial Supervisory Authority to provide discretionary investment management services. The DK Sub-Adviser is wholly owned by the Investment Manager. The Investment Manager provides investment management services on a discretionary basis to clients, which are commingled investment vehicles and separately managed accounts primarily intended for institutional investors and other sophisticated investors.

Currently, the Investment Manager provides investment management services to the following clients (each a “Fund” and collectively, the “Funds”): Alphadyne International Master Fund, Ltd.; Alphadyne Global Rates Master Fund, Ltd. and Alphadyne Diversified Strategies Master Fund Ltd. (f/k/a Alphadyne International (ERISA) Master Fund Ltd.) (collectively, the “Alphadyne Funds”). The Alphadyne Funds are commingled investment vehicles established by the Investment Manager (note that individual investors in the Alphadyne Funds are hereinafter referred to as “Investors”). Please refer to the offering materials of each of the Alphadyne Funds for further details regarding each Fund’s legal structure and terms of investment.

Pursuant to investment management agreements with the Alphadyne Funds (collectively, the “Advisory Agreements”), the Investment Manager generally has authority to retain affiliated or unaffiliated entities to provide investment advisory services to the Funds, provided that such entities are compensated out of the Investment Manager’s compensation under the Advisory Agreements. The Investment Manager has retained its affiliate and indirect subsidiary, the UK Sub-Adviser, to provide investment management services to the Funds pursuant to a sub-advisory agreement (the “UK Sub-

Advisory Agreement”). The Investment Manager, as agent for and on behalf of the relevant Funds, has also retained its affiliate and direct subsidiary, the JP Sub-Adviser, to provide investment management services to the Funds pursuant to certain agreements (the “JP Sub-Advisory Agreement”). The Investment Manager, as agent for and on behalf of the relevant Funds, has also retained its affiliate and direct subsidiary, the HK Sub-Adviser, to provide investment management services to the Funds pursuant to certain agreements (the “HK Sub-Advisory Agreement”). The Investment Manager, as agent for and on behalf of the relevant Funds, has also retained its affiliate and direct subsidiary, the SG Sub-Adviser, to provide investment management services to the Funds pursuant to certain agreements (the “SG Sub-Advisory Agreement”). The Investment Manager, as agent for and on behalf of the relevant Funds, has also retained its affiliate and direct subsidiary, the DK Sub-Adviser, to provide investment management services to the Funds pursuant to certain agreements (the “DK SubAdvisory Agreement”). Each of the Sub-Advisers are expected at all times to manage, on a discretionary basis, in excess of $101,956,000 in assets for the Funds.

The Investment Manager and the Sub-Advisers are together filing a single Form ADV under an umbrella registration. The Sub-Advisers are identified as relying advisers on Schedule R of the Investment Manager’s Form ADV Part 1A.

The Funds generally employ directional (macro) and relative value investment strategies focused principally in the global interest rate and foreign exchange markets across North America, Europe and Asia.

As of January 1, 2026, the Investment Manager managed approximately US $11 billion in assets on a discretionary basis, and its regulatory assets under management as of December 31, 2025 were US $164.8 billion. Regulatory assets under management are calculated in a manner consistent with the Alphadyne Funds’ audited financial statements, which are prepared in accordance with accounting principles generally accepted in the United States of America. The Investment Manager does not manage any assets on a non-discretionary basis.

The Investment Manager previously owned Astignes Capital Asia Pte. Ltd. (f/k/a Alphadyne Asset Management Pte. Ltd.) (“Astignes”), located in Singapore, which generally served as an investment adviser to the Funds since inception. Over several years, Astignes and the Investment Manager became separate legal entities with their own sources of revenue, operations and governance (the “Spinout”). Until close of business December 31, 2019, Astignes and the Investment Manager were under the common control of Bart Broadman, a co-founding principal of the Investment Manager and owner of Astignes since January 1, 2018. A “change of control” of the Investment Manager took place on January 1, 2020, when Mr. Broadman ceased to have any managerial or economic interest in the Investment Manager. The board of managers of Alphadyne GP Holdings LLC, comprised of Mr. Khuong-Huu, Mr. Regan and Mr. Broadman, dissolved effective close of business December 31, 2019. Mr. Khuong-Huu is the sole manager of the Investment Manager and effectively has sole control over the business and affairs of the Investment Manager. Effective July 1, 2024, Mr. Evans, in his role as President and Chief Risk Officer, together with the support of an experienced management team, is responsible for overseeing the day-to-day operations and management of the Investment Manager. The details of the Spinout are, as one would expect, detailed and complex. Any questions regarding the spinout may be directed to the Investment Manager’s CCO, Ajay Mehra, at 212-806-3790.

Effective January 1, 2021, the Investment Manager acquired a majority controlling and economic interest in Whitney Peak Capital, LP (“Whitney Peak”), an Exempt Reporting Adviser exempt from registration with the SEC (the “Acquisition”). Alphadyne GP Holdings, LLC, the general partner of the Investment Manager, acts as Whitney Peak’s general partner, and Kenneth Minklei, formerly the sole owner of Whitney Peak, remains the Chief Executive Officer and Chief Investment Officer of Whitney Peak. The Investment Manager expects that Whitney Peak, or one of its Principals, may perform

certain investment advisory and consulting services for the Investment Manager. Please see Item 10 below for additional information.

The Sub-Advisers receive annual fees as specified under their respective Sub-Advisory Agreements, as applicable, for the provision of investment management services during each fiscal year. Such fee is payable by the Investment Manager and is intended to be an arm’s length fee (calculated on the basis of Organisation for Economic Co-operation and Development guidelines and principles).

The Investment Manager receives performance compensation that is generally equal to 20% or more of a client’s net profits, if any, subject to a “loss carryforward” provision (the “Incentive Fee”). For certain Funds, a different rate may apply in respect of some classes of interests. Please refer to each Fund’s offering materials to understand the manner in which the Incentive Fee is structured, by Fund. The Incentive Fee may be negotiable and may be waived or reduced with regard to Investors that are employees or affiliates of the Investment Manager or the Sub-Advisers; relatives of such persons; and for certain large or strategic Investors.

Investors are generally permitted to redeem/withdraw capital from the Funds on a quarterly basis subject to an Investor’s applicable notice requirement. Each Fund generally requires at least 60 days’ advance written notice for redemptions/withdrawals and has generally included within its investment terms a 25% investor-level gate on redemptions/withdrawals, though certain Investors or classes of interests may have different liquidity terms and include at least 90 days’ advance written notice. Certain classes of interests will require the payment of a redemption fee equal to 3% of the amount redeemed if such classes are redeemed prior to the anniversary of the date on which such classes were purchased. The redemption/withdrawal gate, the redemption fee, together with the applicable notice period for any redemption, are designed to help the Investment Manager effectively manage the redemption/withdrawal process. More specifically, such mechanisms allow the Investment Manager to have a clear view of cash outflows from each Fund, thus allowing the Investment Manager to tailor liquidation scenarios to meet redemption/withdrawal needs. The Funds, in consultation with the Investment Manager, may waive or reduce these liquidity and redemption/withdrawal terms with regard to Investors that are employees or affiliates of the Investment Manager or the Sub-Advisers; relatives of such persons; and for large or strategic Investors.

Please refer to the offering materials of each of the Funds for further details on investment terms for each of the Funds.

The Investment Manager’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which will be indirectly incurred by Investors by virtue of their investment in a Fund. These include Fund-related legal, compliance (including, but not limited to, regulatory filing fees and client’s portion of any Investment Manager regulatory filing obligations or compliance expenses incurred directly in connection with the Fund, such as expenses related to compliance with

(i) Form PF, (ii) short and long exposure and/or ownership filings with U.S. and foreign regulators (iii) Form CPO-PQR, (iv) the Markets in Financial Instruments Directive, (v) the U.S. Foreign Account Tax Compliance Act (“FATCA”), (vi) the intergovernmental agreement between the United States and the Cayman Islands to improve international tax compliance and the exchange of information, (vii) antimoney laundering laws and know-your-customer requirements, including the costs associated with the appointment of any Anti-Money Laundering Compliance Officer, Money Laundering Reporting Officer and Deputy Money Laundering Reporting Officer required pursuant to the anti-money laundering regulations of the Cayman Islands, (viii) the intergovernmental agreement between the United Kingdom and the Cayman Islands to improve international tax compliance and the exchange of information, (ix) the multilateral competent authority agreement between the Cayman Islands and over 100 other countries to implement the OECD (Organisation for Economic Cooperation and Development) Standard for Automatic Exchange of Financial Account Information – Common Reporting Standard or (x) the law of any jurisdiction or any treaty providing for documentation or information similar to that required to be furnished under FATCA or an intergovernmental agreement); audit, tax, accounting (including third-party accounting services) and administrator (including middle/back office and risk services) fees and expenses; organizational expenses; thirdparty and out-of-pocket research, diligence and market data costs and expenses; professional fees and expenses of consultants, legal counsel, finder and other professionals in connection with investigating, evaluating and structuring investments, including unconsummated investments; research and diligence-related fees and expenses (including fees for news and quotation equipment and connectivity costs and services, market and other research-related data services); fees for market information systems and related connectivity costs; and investment-, operations-, portfolio-, and trading-related software, including trade order management software (i.e., software used to route trade orders) and related connectivity costs; expenses of purchasing, carrying and disposing of portfolio positions such as commissions, borrowing charges on securities sold short, interest expenses and other financing charges (including initial and variation margin); prime brokerage fees; custodial fees; clearing costs; exchange fees; expenses related to proxy voting research, reporting, execution and recordkeeping services; costs and expenses associated with investor communications and reporting organizational expenses; side letters with limited partners and compliance therewith; organizational and offering expenses, other than placement fees (if any) and including expenses attributable to compliance with the Alternative Investment Fund Managers Directive (“AIFMD”) and other private placement, lobbying law and distribution rules in the U.S. and other foreign jurisdictions; applicable insurance costs (including errors and omissions insurance and directors and officers insurance); brokerage fees and bank charges; Directors' fees and expenses; extraordinary expenses, if any (e.g., expenses related to litigation and threatened litigation, if any, and expenses related to legal inquiries (formal and informal), including regulatory “sweeps”); appropriate reserves which may be created, accrued and charged against a Fund’s assets for expenses and contingent liabilities, if any, on or after the date any such contingent liability becomes known; the pro rata share of the expenses of the applicable master fund; and any other expenses related to the purchase, sale or transmittal of Fund assets (including travel directly related to portfolio management, risk management, research or the structuring of the Fund’s investments). The Investment Manager will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the U.S. Investment Advisers Act of 1940 (the “Advisers Act”) and in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3.

Such charges, fees and commissions are exclusive of and in addition to the Investment Manager’s fee, and the Investment Manager will not receive any portion of these charges, fees and commissions. Notwithstanding anything to the contrary, with effect from January 1, 2026, the Funds will bear certain Investment Team-Related Expenses of the Investment Manager, up to a cap of 0.50% (fifty basis points) of the net asset value of the Master Fund for each fiscal year (“Investment Team-Related Expense Cap”).

The Investment Manager will bear the amount (if any) by which the aggregate amount of the Investment Team-Related Expenses in any fiscal year exceeds the Investment Team-Related Expense Cap. Please refer to the offering materials of the Funds for further details regarding fees and expenses.

Item 12 further describes the factors that the Investment Manager and the Sub-Advisers each consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

The Investment Manager, the Sub-Advisers, their employees and certain other persons associated with the Investment Manager and the Sub-Advisers may invest in, or receive compensation or other benefits tied to the performance of, certain accounts under their management, thereby obtaining a pecuniary interest in such accounts, which may create an incentive to favor such accounts over other accounts in the allocation of investment opportunities. The Investment Manager and the Sub-Advisers have procedures reasonably designed and implemented to ensure that all clients are treated fairly and equitably over time, and to prevent this conflict from influencing the allocation of investment opportunities among clients. These procedures generally include provisions designed to ensure that, to the extent reasonable, accounts that are managed in a similar fashion participate in investment opportunities pro rata based on an account’s trading assets (“Trading Assets”), or in some other manner that the Investment Manager and the SubAdvisers determine is fair and equitable over time such as maintaining constant month-to-month allocation ratios, provided that the Investment Manager and the Sub-Advisers retain flexibility to independently meet each Fund’s investment objectives and effectively employ their respective investment strategies. Notwithstanding the foregoing, there can be no assurance that the Investment Manager will successfully apply such procedures in every instance. Accordingly, there can be no assurance that the application of the Investment Manager’s allocation policies will result in the allocation of a specific investment opportunity to an account, or that an account will participate in all investment opportunities falling within the scope of its investment objectives and strategy. In addition, each such account is evaluated independently for purposes of determining whether its target volatility is being attained, and in the absence of any contractual pari passu or other mandate, the Investment Manager is under no obligation to consider the clients’ relative performance, risk exposure, or any other attribute with a view towards a potential risk adjustment, because, as mentioned, each client is evaluated independently in determining appropriate risk levels. Due to differing objectives, personnel, views, information, timing, instruments, location and/or other factors, investment strategies may (and do) take investment positions within their respective portfolios (each a “Portfolio”), within a client and/or across clients, that are different from or adverse to those taken by other investment strategies. This includes but is not limited to, positions directly or otherwise contrary to those held in other Portfolios. To the extent that a Portfolio holds positions that are different from or adverse to those held by another Portfolio(s), the Investment Manager and/or its Sub-Advisers may be presented with circumstances where the interests of one Portfolio conflict with those of another Portfolio, such as, among others, with respect to the expected returns for the position, the expected volatility of the position, the type of investment, directional exposure, and/or the timeframe for and method of exiting the position. In addition, the individual Portfolios will each incur brokerage and other trading fees and expenses associated with independently taking these positions,

irrespective of the fact that the positions may in fact be completely or substantially offsetting. There will be no obligation to purchase, sell or exchange any position or financial instrument for a Portfolio if the Investment Manager, and/or its Sub-Advisers, as applicable, believe in good faith when the investment decision is made that such transaction or investment would be appropriate or desirable for a particular Portfolio. These areas are monitored by the CCO.

No other hourly, flat or asset-based fees are charged to the Funds.

Generally, the minimum initial investment in a Fund is US $1,000,000, but each Fund’s offering memorandum specifies the minimum initial investment requirements that pertain to that Fund.

To execute its strategies the Investment Manager and the Sub-Advisers conduct two main types of trading. The first is directional or macro trading, which generally involves taking positions that express a view on the future direction of a market parameter, such as an interest rate, a foreign exchange rate or the level of a market’s volatility. The second is relative value trading, which generally involves taking positions intended to exploit (i) temporary anomalies in the relative values of similar

instruments or markets and (ii) general patterns of correlation between such instruments or markets. Some trades will represent a combination of directional and relative value trading.

The Investment Manager’s and the Sub-Advisers’ primary focus is on interest rate and foreign exchange markets, as well as related volatility markets. However, they also trade in credit, equity and commodity markets.

In the course of its trading, the Investment Manager and the Sub-Advisers mainly use plain-vanilla interest rate swaps, Treasuries and other sovereign bonds, bond and interest rate futures, foreign exchange forwards, and related exchange-traded or over-the-counter (“OTC”) options. The Investment Manager and the Sub-Advisers may also use the following instruments, among others: credit default swaps, exchange-traded options on broad equity market indices (e.g., the S&P 500 Index), highly-liquid equity futures, and futures and options on indices of single commodities (such as gold and oil) or on baskets of commodities.

The Funds have complete flexibility to, and intend to, create or organize (alone or in conjunction with others, including the Investment Manager, the Sub-Advisers or other affiliates -- including other clients and/or funds) or otherwise utilize special purpose subsidiaries or other special purpose investment entities, swaps or other derivatives or structured products (collectively referred to herein as “Products”) to trade and/or access investments, particularly in instances where the Investment Manager, in its sole discretion, determines that there is a potential tax, regulatory, finance, operational, confidentiality and/or other advantage to such Product. The Investment Manager currently believes that this structure creates significant operational efficiencies, which in turn reduces operational risk and the potential for trade allocation errors. Further, it could provide for a more creditworthy vehicle, which the Investment Manager believes may allow it to obtain beneficial financing and other terms from counterparties and/or third parties. In such structures, the relevant trading and/or investment activity takes place at the Product level and ownership of the applicable portfolio investments would be attributed directly to such Products. The profit and loss of the portfolio investments in the Product(s), in turn, would be allocated to each investor (including but not limited to, as applicable, the Funds) in such Product(s) in proportion to its respective ownership percentage -- which percentage will reset monthly based on its then contributed capital.

Material Risks The above strategies involve a significant degree of risk of loss that clients and Investors should be prepared to bear. The following is a summary of some of the material risks associated with the above strategies. Although the summary below does not fully describe all of the risks associated with such an investment, each Fund’s offering memorandum contains a more complete description of the applicable risks associated with an investment in that Fund. Clients and Investors should understand that it is not possible to identify all of the risks associated with investing, and that the potential risks applicable to a Fund will depend on the nature of the Fund and its investment strategies, as well as the types of investments it holds. While the Investment Manager and the Sub-Advisers seek to manage the Funds so that risks are appropriate to the return potential for the strategy, it is often not possible or desirable to fully mitigate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. Certain mandates may be limited as to type of investment and may not be diversified. The Funds are not intended to provide a complete investment program. An investment in the Funds involves significant risks and is suitable only for those persons who can bear the economic risk of the loss of their entire investment and who have limited need for liquidity in their investment.

Clients and Investors are responsible for appropriately diversifying their assets to guard against the risk of loss. Products The Funds and clients, as applicable, may, and intend to, pursue trading activities and/or investment opportunities through Products, which Products, in turn, would be owned by such Funds and/or clients in proportion to their respective ownership percentages in such Products. This type of ownership structure -- especially when utilizing leverage -- may give rise to actual or perceived conflicts of interest, including but not limited to in circumstances where any Product(s) (or, if applicable, one of more of its underlying owner(s)) fails to fund or otherwise satisfy its capital contribution or other obligations (collectively referred to herein as a “Capital Default”), thereby potentially causing the Product to default or otherwise fail to meet its obligations. The Investment Manager, in seeking to mitigate Capital Defaults, intends to have each of the investors (including but not limited to, as applicable, the Funds) in such Product(s) provide a pro rata guarantee of its capital obligations in favor of the relevant Product’s applicable counterparties and/or third parties. This pro rata guarantee should be in direct proportion to such investor’s ownership percentage in the respective Product (which percentage will reset monthly based on its then contributed capital), and will be generally determined as of the point in time when a claim is made by a counterparty and/or third party. The Investment Manager also may, in its sole discretion, seek other contractual or other measures to mitigate cross liability and/or other concerns among investors in a Product. Any determinations, remedies, or actions taken involving investors in a Product will be made on an arm’slength basis, and in a fair and equitable manner over time. Substantial Changes in Regulation Legal, tax and regulatory changes could occur that may adversely affect the Funds, the Investment Manager and/or the Sub-Advisers. The regulatory environment for hedge funds is evolving, and changes in the regulation of hedge funds may adversely affect the value of investments held by a Fund and the ability of each Fund to obtain the leverage it might otherwise obtain or to pursue its trading strategies. In addition, securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. Regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivative transactions and short selling and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial actions. The effect of any future regulatory change on a Fund, the Investment Manager and the Sub-Advisers could be substantial and adverse.

There can be no assurance that the Fund or the Investment Manager will avoid regulatory examination and possibly enforcement actions. Recent SEC enforcement actions and settlements involving U.S.based private fund advisers have involved a number of issues, including undisclosed fee sharing arrangements with co-investors; the undisclosed disproportionate allocations of fees, costs and expenses to managed funds for services that benefited the applicable adviser but without cost to the adviser; the undisclosed allocation of transaction fees to co-investors to reduce the magnitude of management fee offsets; engagement in unregistered broker-dealer activities; the undisclosed allocation of the fees, costs and expenses related to unconsummated co-investment transactions (i.e., the allocation of broken deal expenses); undisclosed legal fee arrangements affording the applicable adviser with greater discounts than those afforded to funds advised by such adviser; and the undisclosed acceleration of monitoring fees. Although the Investment Manager believes the foregoing

practices were or have been common historically amongst private fund advisers within the U.S. private funds industry, if the SEC or any other governmental authority, regulatory agency or similar body takes issue with the practices of the Investment Manager or any other Affiliated Parties as they pertain to any of the foregoing or any other activities, the Investment Manager will be at risk for regulatory sanction. Even if an investigation or proceeding did not result in a sanction or the sanction imposed against the Investment Manager was small in monetary amount, the Investment Manager could be subject to adverse publicity relating to the investigation, proceeding or imposition of any such sanction.

There is also a risk that regulatory agencies in the United States and beyond will continue to adopt new laws or regulations (including tax laws or regulations), or change existing laws or regulations, or enhance the interpretation or enforcement of existing laws and regulations.

In summary, regulation generally as well as regulation more specifically addressed to the private funds industry, including tax laws and regulation, whether in the United States or abroad, could increase the cost of acquiring, holding or divesting investments, the profitability of such enterprises and the cost of operating the Fund. Additional regulation could also increase the risk of third-party litigation.

Fund-Level Risk Metrics

The Investment Manager actively manages portfolio risks using several ways of measuring portfolio risk, including without limitation, VaR, historical stress testing and analysis of potential market scenarios and liquidity. These risk metrics seek to quantify potential losses to the Funds’ portfolio as it exists at a certain point in time based on specific methodologies. These scenarios and risk metrics, however, are not designed or intended to, among other things, quantify possible additional losses resulting from the process of liquidating positions over a specific period of time. Alphadyne’s risk management systems and procedures do not guarantee that future losses will not be incurred, including a total loss of capital.

Lack of Liquidity of Fund Assets

With respect to the portfolios of the Funds, Fund assets may, at any time, include securities and other financial instruments or obligations that are illiquid or thinly traded investments, making purchase or sale of such securities and financial instruments at desired prices or in desired quantities difficult or impossible. The risk of market illiquidity is materially heightened by the use of leverage and the possibility that margin calls will need to be met in declining or disrupted market conditions. Furthermore, the sale of any such investments may be possible only at substantial discounts, or by incurring significant transaction costs, and it may be extremely difficult or impossible to liquidate or value any such investments accurately and such challenges may be further magnified and adverse to the Fund if the Fund or other accounts managed by Alphadyne own a substantial portion of a financial instrument in a financial market that inherently limits the liquidity of such investment position. As a result, a Fund may be required to hold such instruments despite adverse price movements, which may result in significant losses that are amplified by the degree of leverage employed. In particular, investments in funds of third-party managers and other Funds are generally non-transferable and may be subject to significant restrictions on liquidity, including lock-up periods, gates, redemption/withdrawal charges and rights of suspension. Such restrictions are likely to be greater than the liquidity limitations that a Fund would have if the strategies of the third-party manager or other Fund were implemented directly by such Fund. In addition, if a Fund makes a short sale of an illiquid security or instrument, it may have difficulty in covering the short sale, resulting in a potentially unlimited loss on that position. Under stressed market conditions, even higher-rated securities may become illiquid, and the yields and prices of such securities may become as volatile as certain much lower-rated securities.

Leverage In addition, each Fund makes use of various forms of leverage which increases the effect of any investment value changes or liquidity events on the net assets of such Fund. The amount of leverage that a Fund may utilize is specific to the agreements set forth with various counterparties. There is no guarantee that a Fund's borrowing arrangements or other arrangements for obtaining leverage will continue to be available, or if available, will be available on terms and conditions acceptable to such Fund. Unfavorable economic conditions also could increase funding costs, limit access to the capital markets or certain lenders (including derivative counterparties), or result in a decision by lenders not to extend credit to a Fund. In addition, a decline in market value of a Fund’s assets may have particular adverse consequences in instances where such Fund has borrowed money based upon the market value of those assets. A decrease in market value of those assets may require such Fund to post additional collateral or otherwise sell assets at a time when it may not be in the best interest of such Fund to do so. Accordingly, if any of these events occur, it could have a material adverse effect on such Fund. Counterparty Risk

A Fund may be exposed to counterparty risk with regard to the brokers and/or prime brokers with whom it trades with on a bilateral and/or give-up basis and may also bear the risk of settlement default. In particular, in transactions entered into bilaterally between a broker and a Fund or given-up to a prime broker, such Fund does not benefit from those protections afforded to such Fund in exchangetraded transactions, which generally are backed by clearing organization guarantees and other protections and thus exposes such Fund to the risk of broker default. Although the Investment Manager monitors each of the Funds’ brokers and prime brokers (the “Brokers”) and believes that the appropriate Brokers have been selected, there is no guarantee that any of the Brokers will not become insolvent or default. As a result, on the back of any counterparty insolvency or default, the Funds may be exposed to significant credit implications. In addition to broad counterparty risks discussed above, the Funds may be exposed to different levels of risks in dealing with U.S. and non-U.S. custodians or prime brokers who settle and clear trades. Each Fund maintains a custody account with its prime brokers and primary custodians (each, a “Prime Broker”). In particular, assets held in custody by a U.S or non-U.S. Prime Broker may be borrowed, lent or otherwise used by the U.S. or non U.S. Prime Broker for its own purposes pursuant to its contractual right of re-hypothecation, whereupon such assets will become the property of the U.S. or non-U.S. Prime Broker and the applicable Fund will have a legal claim against the U.S. or non-U.S. Prime Broker for the return of equivalent assets. In the U.S., the Securities Investor Protection Act of 1970, the Bankruptcy Code and Rule 15c-3 of the Securities Exchange Act of 1934 seek to protect customer property at a high level in the event of a bankruptcy, insolvency, failure, or liquidation of a broker-dealer, however even so, there is no certainty that, in the event of a failure of a U.S. Prime Broker that has custody of Fund assets, a Fund 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. In addition, a Fund and/or the Prime Brokers may appoint sub-custodians in certain non-U.S. jurisdictions to hold the assets of such Fund. Given the undeveloped state of regulations on custodial activities and bankruptcy, insolvency, or mismanagement in certain non-U.S. jurisdictions, in the event of the sub-custodian’s or non-U.S. Prime Broker’s bankruptcy or insolvency, the ability of a Fund to recover assets held by such sub-custodian or non-U.S. Prime Broker, which may or may not be held pursuant to a right of re-hypothecation, could be in doubt, as such Fund may be subject to less favorable laws than many of the protections that would be available under U.S. laws. In addition, there may be delays associated with enforcing a Fund's rights to its assets in the case of a bankruptcy or insolvency of any such party.

Non-Diversification It is anticipated that the Funds’ portfolio may be concentrated with respect to certain investments (including with respect to type, duration and/or other features), issuers and/or geographic areas. Accordingly, the investment portfolio of the Funds may be subject to more rapid change in value than would be the case if the Fund maintained a wider diversification among these types of investments, issuers and/or geographic areas. Certain sectors of the global financial markets may experience extended periods of adverse conditions featuring market uncertainty, reduced liquidity, greater volatility, general widening of credit spreads and a lack of price transparency, which all may have an adverse impact on the Funds’ investments. Concentrated investment positions can be adversely affected by the level of volatility in the financial markets; the larger the positions, the greater the potential for loss. There is no guarantee that the Fund will be able to achieve its investment objectives or provide any return on invested capital. The Fund may lose some or all of invested capital.

Non-U.S. Securities

Investing in emerging markets and the securities of non-U.S. governments and companies which are generally denominated in non-U.S. currencies and utilization of options on non-U.S. securities, involves certain considerations comprising both risk and opportunity not typically associated with investing in other more established economies or securities markets or in the securities of U.S. companies. Such considerations include (i) the risk of nationalization or expropriation of assets or non-U.S. taxation; (ii) social, economic and political uncertainty; (iii) dependence on exports and the corresponding importance of international trade; (iv) price fluctuations, less liquidity and smaller capitalization of securities markets; (v) changes in exchange rates and exchange control regulations; (vi) rates of inflation; (vii) controls on non-U.S. investment and limitations on repatriation of invested capital and on a Fund’s ability to exchange local currencies for U.S. dollars; (viii) governmental involvement in and control over the economies; (ix) that governments may decide not to continue to support economic reform programs generally and could impose centrally planned economies; (x) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers and less available information than is generally the case in the United States; (xi) less extensive government supervision of the securities markets, brokers and issuers; (xii) the settlement period of securities transactions in emerging markets may be longer; (xiii) less developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors; (xiv) higher transaction costs and greater price volatility; (xv) imposition of foreign taxes; (xvi) greater difficulty in enforcing contractual obligations; (xvii) less available information than is generally the case in the United States; and (xviii) greater risks associated with counterparties and settlement. The performance of the Funds will be measured in U.S. dollars with respect to the Dollar Shares, Euros with respect to the Euro Shares, GBP with respect to the GBP Shares and JPY with respect to the JPY Shares.

The Funds may also invest in “distressed” sovereign debt obligations. There are additional, particular risks relating to the investment and trading of these instruments. These risks include the uncertainties involved in enforcing and collecting debt obligations against sovereign nations. The ability to enforce and collect obligations against foreign sovereigns may be affected by world events, changes in U.S. foreign policy, and other factors outside the control of the Funds. Swap Transactions

The Funds may each periodically enter into transactions in the forward or other markets that could be characterized as swap transactions and which may involve interest rates, fixed-income and other securities, currencies and other items. A swap transaction may be structured as an individuallynegotiated, non-standardized agreement between two parties to exchange cash flows based on different interest rates, exchange rates, or prices, with payments calculated by reference to a principal (“notional”) amount or quantity. In addition, under the Dodd-Frank Wall Street Reform and Consumer

Protection Act (the “Dodd-Frank Act”) certain major classes of swaps have been standardized and are now subject to requirements to be executed on regulated trading facilities and subsequently submitted for centralized clearing. Transactions in these markets present certain risks similar to those in the futures, forward, and options markets, including: (i) the Dodd-Frank Act includes provisions that comprehensively regulate swap transactions for the first time, and many non-U.S. governmental authorities have adopted or are in the process of contemplating similar regulatory requirements for the swaps markets within their jurisdiction; (ii) there generally are no limitations on daily price moves in individually-negotiated swap transactions; (iii) speculative position limits are not currently applicable to swap transactions, although the counterparties with which a Fund may deal may limit the size or duration of positions available as a consequence of credit considerations; in addition, to the extent any such swap transactions are required to be cleared by a regulated clearinghouse pursuant to the Dodd-Frank Act, they may become subject to position limits imposed by the relevant clearinghouse or by the U.S. Commodity Futures Trading Commission (the “CFTC”) or the SEC; (iv) participants in the swaps markets are not required to make continuous markets in swaps contracts; (v) the markets for individually-negotiated swaps are largely “principals’ markets,” in which performance with respect to a swap contract is the responsibility only of the counterparty with which the trader has entered into a contract (or its guarantor, if any), and not of any exchange or clearinghouse, as a result, each Fund is subject to the risk of the inability or refusal to perform with respect to such contracts on the part of the counterparties with which such Fund trades; and (vi) credit default swaps with the “pay as you go” feature may require reimbursement of credit protection payments made by the seller to be made by the buyer for up to a year after the swap terminates, and the seller may also have to make multiple credit protection payments to the extent the reference obligation is not fully performing. While the Dodd-Frank Act is intended in part to reduce certain of the risks described above that may be characteristic of individually-negotiated swaps, there can be no guarantee that the Dodd-Frank Act will be successful in this respect, and any such success may not be evident for some time after the DoddFrank Act is fully implemented.

Over-the-Counter Transactions

As a result of the Dodd-Frank Act, the CFTC requires specified derivative transactions that were previously executed on a bilateral basis in the over-the-counter markets to be executed through a regulated securities, futures or swap exchange or execution facility. For example, certain interest rate swaps and credit default index swaps are generally required by the CFTC to be submitted for clearing. It is not yet clear when the parallel SEC requirements will go into effect.

Among other things, in the U.S. trades submitted for clearing are subject to minimum initial and variation margin requirements set by the relevant clearinghouse, as well as possible SEC- or CFTCmandated margin requirements. Derivatives dealers may require a Fund to give them the right unilaterally to increase collateral requirements for cleared OTC trades beyond regulatory and clearinghouse minima. These factors may increase the amount of collateral a Fund is required to provide and the costs associated with providing it.

In addition, margin rules adopted by the U.S. banking regulators and the CFTC are in effect and may subject the Funds to regulatory margin requirements for uncleared derivatives transactions with CFTC-registered swap dealers. These rules, along with other regulatory requirements, may increase the costs to the Funds for their CFTC-regulated derivatives trades (including through requirements to post collateral which could adversely affect the Funds’ available liquidity), materially alter the terms of derivative contracts, reduce the availability or desire of derivatives, reduce the ability to monetize or restructure existing derivative contracts and increase the Funds’ exposure to less creditworthy counterparties. Any reduction in a Fund’s use of derivatives as a result of the Dodd-Frank Act and regulations could adversely affect such Fund.

In an effort to facilitate derivatives strategies, a Fund and/or the Investment Manager might become members of exchanges and/or swap execution facilities (“SEFs”). Doing so would subject a Fund and/or the Investment Manager to a wide range of regulation and other obligations and associated costs. Like other self-regulatory organization, SEFs are expected to regularly revise and interpret their rules and those revisions and interpretations could adversely affect a Fund. If a Fund opts not to trade on a SEF directly but instead through a broker, such trading may nevertheless require a Fund to consent to the SEF’s jurisdiction as a self-regulatory organization and to be subject to the SEF’s rules, which could adversely impact a Fund.

In Europe and the United Kingdom, EMIR imposes requirements in respect of derivative contracts that may affect any Fund derivatives activities in Europe and the United Kingdom, including a general obligation to clear certain types of OTC derivative contracts through a duly authorized central counterparty. The EU and United Kingdom regulatory framework for derivatives is also affected by MiFID II.

In Singapore, the Securities and Futures Act 2001 and its subsequent amendments lay out a regulatory framework for reporting over-the-counter derivatives contracts traded in and/or booked in Singapore. Detailed reporting requirements can be found in the Securities and Futures (Reporting of Derivatives Contracts) Regulations 2013 and its subsequent amendments.

The implementation of these regulations is ongoing as of the date of this Brochure. Dealers and certain other market participants, in addition to the clearing and margin requirements discussed above, are subject to registration obligations and other regulatory requirements, such as business conduct standards, disclosure requirements, reporting and recordkeeping requirements, transparency requirements, position limits, limitations on conflicts of interest and other regulatory burdens. These requirements increase the overall costs for OTC derivative dealers and other market participants, which may be passed along, at least partially, to end users of the products, such as the Funds, in the form of higher fees or less advantageous dealer marks. Commodity and Futures Contracts

A Fund may invest a substantial portion of its assets in commodity futures contracts and options thereon. While the trading in commodity and futures contracts and options thereon are highly specialized activities which may increase the total return in a Fund's investments they may entail greater than ordinary investment risks.

Commodity futures markets are highly volatile and 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 commodity futures trading account. As a result, a relatively small price movement in a commodity futures contract may result in substantial losses to the trader. Commodity futures trading may also be illiquid. Certain commodity exchanges do not permit trading in particular futures contracts at prices that represent a fluctuation in price during a single day’s trading beyond certain set limits. If prices fluctuate during a single day’s trading beyond those limits, we could be prevented from promptly liquidating unfavorable positions and thus be subject to substantial losses.

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.

A Fund’s futures activities may involve futures and options traded in U.S. and non-U.S. markets. The risks of trading futures in non-U.S. markets may be greater than trading in futures on U.S. exchanges.

For example, non-U.S. futures are cleared on and subject to the rules of a non-U.S. board of trade, and fewer or different protections may apply to participants in non-U.S. markets than may apply under the rules and regulations of the CFTC and the U.S. National Futures Association (the “NFA”). In addition, funds provided as margin for non-U.S. futures and options may not be provided the same protections as funds received in respect of U.S. transactions.

Portfolio Turnover

The investment strategy of a Fund may require us to actively trade that Fund’s portfolio, and as a result, turnover and brokerage commissions and other transaction expenses of such Fund may significantly exceed those of other investment entities of comparable size.

Importance of Valuation Models

Our strategies may be based, in part, on valuation models which key personnel have developed over time. Numerous firms commit substantial resources to update and maintain existing models as well as the ongoing development of new models and algorithms. As market dynamics shift over time, a previously highly successful model may become outdated – perhaps without our recognizing that fact before substantial losses are incurred. There can be no assurance that we will be successful in maintaining effective valuation models. Cybersecurity Risk

With the increased use of technologies such as the Internet to conduct business, the Funds are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyberattacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Other cyber incidents may be caused by usage errors, power, communications or other service outages and catastrophic events such as fires, tornados, floods, hurricanes and earthquakes. Cyber incidents affecting the Investment Manager’s and other service providers (including, but not limited to, Fund accountants, custodians, transfer agents and financial intermediaries) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with a Fund’s ability to value its securities or other investments, impediments to trading, the inability of Fund investors to transact business, violations of applicable privacy and other laws, theft, publication or deletion of confidential, private, and/or personally identifying information, including information relating to Fund investors, or their beneficial owners, and/or our intellectual property or trade secrets, regulatory fines, legal claims, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which a Fund invests, counterparties with which a Fund engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers for Fund investors) and other parties. In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future. While our and the Funds’ service providers have established business continuity plans in the event of, and risk management systems to prevent, such cyber incidents, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Breaches such as those involving covertly introduced malware, impersonation of authorized users and industrial or other espionage may not be identified even with sophisticated prevention and detection systems, potentially resulting in further harm and preventing issues from being addressed appropriately. Furthermore, the Funds cannot control the cyber security

plans and systems put in place by their service providers or any other third parties whose operations may affect the Funds or their investors. The Funds and their investors could be negatively impacted as a result.

Artificial Intelligence

The Investment Manager and its Sub-Advisers may incorporate uses of artificial intelligence (“AI”), into its businesses and operations. However, there are significant risks involved in utilizing AI and no assurance can be provided that such use will enhance the businesses or operations or result in such businesses or operations being more efficient or profitable. For example, AI algorithms could be flawed, insufficient, of poor quality, reflect unwanted forms of bias, or contain other errors or inadequacies, any of which may not be easily detectable. AI has also been known to produce false or “hallucinatory” inferences or outputs and AI can present ethical issues and subject users to new or heightened legal, regulatory, ethical, or other challenges. Inappropriate or controversial data practices by developers and end-users, or other factors adversely affecting public opinion of AI, could impair the acceptance of AI solutions. If the AI solutions that the Investment Manager and its Sub-Advisers create or use are deficient, inaccurate or controversial, the Investment Manager and its Sub-Advisers could suffer operational inefficiencies, competitive harm, legal liability, brand or reputational harm, or other adverse impacts on their businesses and financial results.

In addition, regulation of AI is rapidly evolving worldwide as legislators and regulators are increasingly focused on this emerging technology. The technologies underlying AI and its uses are already subject to a variety of laws and regulations, including intellectual property, privacy, data protection and cybersecurity, consumer protection, competition, and equal opportunity laws, and are expected to be subject to increased regulation and new laws or new applications of existing laws and regulations. AI is the subject of ongoing review by various U.S. governmental and regulatory agencies, and various U.S. states and other foreign jurisdictions are applying, or are considering applying, their platform moderation, cybersecurity, and data protection laws and regulations to AI or are considering general legal frameworks for AI, such as the proposed European Union Artificial Intelligence Act, the provisional rules for which were agreed to by the European Parliament and Council on December 8, 2023, subject to formal adoption and publication in the European Union’s Official Journal. It is possible that the Investment Manager and its Sub-Advisers will not be able to anticipate how to respond to these rapidly evolving frameworks, and Alphadyne Funds could be required to expend resources to adjust their offerings in certain jurisdictions if the legal frameworks are inconsistent across jurisdictions. Furthermore, because AI technology itself is highly complex and rapidly developing, it is not possible to predict all of the legal, operational or technological risks that may arise relating to the use of AI. Risk of Pandemics and other Health Crises; General Economic and Market Conditions

The Investment Manager and its Sub-Advisers will operate, and the Funds will invest in, countries that are susceptible to natural disasters and epidemics such as Severe Acute Respiratory Syndrome, Avian flu and Coronavirus (COVID-19). Natural disasters and epidemics, depending on the scale of their occurrence, have caused and may in the future cause different degrees of damage to economies and business activity in countries throughout the world, including in countries in which the Funds invest and/or the Investment Manager and its Sub-Advisers operate. As a result, a natural disaster or epidemic may adversely affect (i) the ability of the Investment Manager and its Sub-Advisers to provide investment management services and (ii) the Fund’s financial condition, results or operation and severely impact the value of its investments. For example, the recent outbreak of COVID-19 has contributed to, and may continue to contribute to, volatility and disruptions in financial markets, changes in interest rates, liquidity and liquidation values of investments, and general levels of

economic activity, and may reduce the availability of financing to the Funds, which could have a material adverse impact on the Funds’ returns and operations. The Funds may hold certain illiquid investments, or investments that become illiquid as a result of systemic risks, including market disruptions, and such investments may limit the Funds’ ability to adapt to any such changes in the market environment or mitigate any corresponding losses. Because the impact of a public health crisis such as COVID-19 or similar pandemic or outbreak is difficult to predict, such an event presents material uncertainty and risk with respect to the Funds’ performance, which could materially exacerbate the risks that the Funds are already exposed to or introduce new ones. Investors and prospective Investors are strongly encouraged to read all of the risk factors identified in each Fund’s respective offering memorandum, including but not limited to, those with respect to market disruptions, liquidity, counterparty exposure, the use of short sales, significant leverage, concentrated positions and operational risks, to ensure that they understand all of the risks associated with an investment in the Funds.

The success of the Funds’ activities will also be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the Funds’ investments), trade barriers, currency exchange controls and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of securities prices and the liquidity of the Funds’ investments, including, without limitation, common equity and related equity derivative instruments, high-yield securities, convertible securities and derivatives, including futures and option prices, which can be highly volatile. During periods of limited liquidity and higher price volatility, whether due to a COVID-19 outbreak or other economic causes, the Funds’ ability to acquire or dispose of its investments at a price and time that the Funds deem advantageous may be impaired.

Consequences of Force Majeure Events

The Funds’ investments may be affected by force majeure events (e.g., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, and outbreaks of an infectious disease such as COVID-19). Some force majeure events may adversely affect the ability of a party, including a counterparty to a portfolio investment, to perform its obligations until it is able to remedy the force majeure event. Furthermore, force majeure events that are incapable of or are too costly to cure may have a permanent adverse effect on an investment. Certain force majeure events (such as war or an outbreak of an infectious disease such as COVID-19) could also have a broader negative impact on the world economy and international business activity generally, or in a country in which the Funds have invested specifically. Any of the foregoing may therefore adversely affect the performance of the Funds and its investments and/or increase the risks inherent in the Funds’ investments.

brokers in part for the purpose of rebalancing positions held by various Alphadyne funds, and that Alphadyne structured these orders such that they were executed without the incurrence of material market risk. Alphadyne was directed to pay a fine of $65,000 while neither admitting nor denying the rule violation.

The JP Sub-Adviser, an affiliate of the Investment Manager, is authorized and regulated by the Financial Services Agency in Japan pursuant to the Financial Instruments and Exchange Act and registered AAMHL's financial instruments business with the Kanto Local Finance Bureau and performs investment management services for the benefit of the Funds. The HK SubAdviser, an affiliate of the Investment Manager, is licensed by the Hong Kong Securities and Futures Commission (“SFC”) to conduct Type 9 (asset management) regulated activities, regulated by the SFC with regards to such business in Hong Kong, and performs investment management services for the benefit of the Funds. The SG Sub-Adviser, an affiliate of the Investment Manager, has a Capital Markets Services License from the Monetary Authority of Singapore and performs investment management services for the benefit of the Funds. The DK Sub-Adviser, an affiliate of the Investment Manager, has a MiFID II investment License from the Danish Financial Supervisory Authority to provide discretionary investment management services.

Whitney Peak, an affiliate of the Investment Manager, is an Exempt Reporting Adviser exempt from registration with the SEC. While the Investment Manager and Whitney Peak generally operate separate and independent investment advisory businesses, the Investment Manager expects that Whitney Peak will perform certain investment advisory and consulting services for the Investment Manager in the future. The scope of such services has not yet been determined, but is not currently expected to create a material conflict of interest with respect to the Investment Manager’s clients. In addition, certain private funds advised by Whitney Peak invest a portion of their assets in funds managed by the Investment Manager. Because of Whitney Peak’s affiliation with the Investment Manager, Whitney Peak will have an incentive to invest more of such funds’ assets in the Funds. For information regarding this and other potential conflicts of interest with respect to Whitney Peak’s clients and how such conflicts are being managed, please refer to Whitney Peak’s Form ADV Part 2A and/or the offering memorandum for the applicable fund.

The Investment Manager is also affiliated with Alphadyne Capital LLC (the “General Partner”), which acts as the general partner of certain U.S. limited partnerships associated with the Funds, and Alphadyne GP Holdings LLC, which acts as the general partner of the Investment Manager and Whitney Peak. Each of the Investment Manager, the Sub-Advisers, Whitney Peak and the General Partner (the “Affiliated Parties”) may conduct other business, including any business within the securities industry, whether or not such business is in competition with the Funds. The Affiliated Parties may act as general partner, investment adviser or investment manager for others, may manage funds, separate

accounts or capital for others, may have, make and maintain investments in their own name or through other entities and may serve as an officer, director, consultant, partner or stockholder of one or more investment funds, partnerships, securities firms or advisory firms. The results of the Funds’ activities may differ significantly from the results achieved by the Affiliated Parties for other accounts or clients which they manage or for which they provide investment advisory or investment management services.

All personnel of the Investment Manager and the Sub-Advisers must put the interests of their respective clients before their own personal interests and must act honestly and fairly in all respects in dealings with clients. All personnel of the Investment Manager and the Sub-Advisers must also comply with all federal securities laws.

The Code of Ethics includes provisions relating to disclosure and/or approval of outside business activities, acceptance and reporting of certain gifts and business entertainment, reporting of violations, personal securities accounts and personal securities trading procedures, among other things. All access persons of the Investment Manager and the Sub-Advisers must acknowledge the terms of the Code of Ethics at the start of their employment and no less than annually thereafter.

The Investment Manager and the Sub-Advisers, in appropriate circumstances, consistent with clients’ investment objectives, could cause accounts over which the Investment Manager has management authority to effect, and may recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which the Investment Manager, the Sub-Advisers, their affiliates and/or clients, directly or indirectly, have a position of interest. The Investment Manager’s and the Sub-Advisers’ employees and certain other persons associated with the Investment Manager the SubAdvisers are required to follow the Investment Manager’s and the Sub-Advisers’ Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of the Investment Manager and the Sub-Advisers and their affiliates may trade for their own accounts in securities which are recommended to and/or purchased for their respective clients. The Code of Ethics is reasonably designed to assure that the personal securities transactions, activities and interests of the employees of the Investment Manager and the Sub-Advisers will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities have been designated as exempt from certain of the personal account dealing requirements, based upon a determination that these would not materially interfere with the best interest of the Investment Manager’s and Sub-Advisers’ clients. In addition, the Code of Ethics requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between the Investment Manager, the Sub-Advisers and their clients.

Alphadyne affiliates invested in the Alphadyne Funds may directly or indirectly pledge their investments as collateral for personal margin loans and/or credit lines and, in the event of default, such investments may be foreclosed upon by such loan or credit facility providers.

A copy of the Code of Ethics will be made available to existing or prospective clients or Investors upon request to the Investment Manager or the Sub-Advisers.

Trade Allocation and Use of Correlation Adjustment Factor. The Investment Manager, the Sub-Advisers and their affiliates provide investment management and advisory services to more than one Fund, which may create conflicts of interest. A Fund may have investment objectives or implement investment strategies similar to or different from those of other Funds. The Investment Manager and the Sub-Advisers will use their best efforts to ensure that no Fund is treated unfairly in relation to any other Fund in the allocation of securities or investment opportunities or in the order in which transactions are executed over time. To the extent a particular investment is suitable and/or viable for more than one Fund, such investments will generally be allocated among the Funds pro rata based on an account’s Trading Assets or in some other manner that the Investment Manager and the SubAdvisers determine is fair and equitable over time, such as maintaining constant month-to-month allocation ratios, provided that the Investment Manager and Sub-Advisers retain flexibility to independently meet each Fund’s investment objectives and effectively employ their respective investment strategies. Where less than the maximum desired number of shares of a particular security to be purchased is available at a favorable price, the shares purchased will be allocated among the Funds in an equitable manner as determined by the Investment Manager and the Sub-Advisers.

The Investment Manager and the Sub-Advisers, in pursuing the investment objectives of more than one Fund, may execute trades in aggregate for all participating clients in an investment theme which is internally referred to as one or more trades and/or positions that express an investment idea. Such trades will generally be allocated in accordance with the Investment Manager’s allocation policies and procedures. Although they may pursue similar strategies, the accounts managed by the Investment Manager and the Sub-Advisers may have different targeted volatilities. In order to assist the Funds in achieving their targeted volatilities, the Investment Manager and the Sub-Advisers establish a correlation adjustment factor that is applied consistently across all accounts under their management implementing the same or substantially similar strategies. The correlation adjustment factor, when multiplied by an account’s assets under management and an account-specific leverage factor, results in an amount of Trading Assets used for purposes of allocating trades in aggregate for all participating clients in an investment theme. Specifically, to the extent a particular investment is suitable and/or viable for more than one Fund, the Investment Manager’s default methodology will be to allocate such investment between or among such clients pro rata based on their relative Trading Assets. As a general matter, the Investment Manager will determine the correlation adjustment factor and resulting allocation ratios on a monthly basis, which in the absence of a materiality adjustment may remain constant from month-to-month to reduce operations risk, although the Investment Manager has discretion under the allocation policies and procedures to modify the correlation adjustment factor and allocation ratios at any time, so long as the resulting allocation ratios are fair and equitable to all clients participating in an investment strategy.

The Investment Manager’s allocation policies and procedures provide for a non-exhaustive list of exceptions to the default methodology described above. A significant exception relates to the distinction between new investment themes being implemented by the Investment Manager (which are allocated pursuant to the default methodology) and the closing, risk adjustment or hedging of, or adding to, existing investment themes held by client accounts. For example, under the exceptions to the default methodology, if the Investment Manager decides to close out an existing investment theme that (i) is held by multiple accounts managed by the Investment Manager, (ii) originated in a prior month, and (iii) was allocated according to that prior month’s allocation ratios, the Investment

Manager generally would close out the position using the allocation ratios in effect when the position was initially established. Similarly, if the Investment Manager decides to add to an existing investment theme that was established in a prior month based on that month’s allocation ratios, the Investment Manager generally would allocate a transaction using the allocation ratios that were in effect when the position was initially established. The Investment Manager also maintains the discretion, pursuant to its allocation policies and procedures, to adjust allocations among accounts it manages in order to, among other things, divest assets for either immediate or future redemptions, invest additional assets due to subscriptions or changes in the investment strategy-level capital allocations made by the CIO, increase risk exposure for a new client or wind down risk exposure for a client that is closing, liquidating and/or otherwise terminating its relationship with the Investment Manager.

Cross Transactions. The Investment Manager and the Sub-Advisers may, to the extent permitted and subject to market conditions, effect market transactions, at arm’s length, between two clients of the Investment Manager (“Cross Trades”) in efforts, for example, to “risk adjust” the portfolios to ensure that each client has the desired ownership of a particular investment position. Moreover, cross trades could be executed to reflect intended allocations among the Investment Manager’s clients. Such cross trades may be executed without the involvement of a Broker, so long as the Investment Manager determines that the terms are market or the equivalent of arm’s length and obtains prior consent from clients.

Above all, the Investment Manager and the Sub-Advisers consider the ability of a trade to be given up to a prime broker as meeting the duty to seek best execution, on the basis that prime brokered trades provide operational, portfolio management and cost benefits to each Fund managed by the Investment Manager and the Sub-Advisers. Other factors considered when selecting brokers include, but are not limited to: (i) market position, market liquidity and order size, (ii) quality and speed of execution, (iii) existing position of an applicable Fund, (iv) counterparty responsiveness, venue and quality of settlement, (v) value of research provided and execution capability, (vi) commission rates and applicable fees, (vii) financial responsibility and responsiveness, (viii) competitiveness of commission rates, spreads, mark-ups and mark-downs, (ix) willingness and ability of the broker or dealer to commit capital to a particular transaction, (x) sophistication of the trading capabilities and infrastructure/facilities of the broker or dealer, (xi) market knowledge of the broker or dealer and (xii) the quality and flexibility of customizing reports.

In selecting brokers or dealers to execute transactions, the Investment Manager and the Sub-Advisers need not solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not the practice of the Investment Manager or the Sub-Advisers to negotiate “execution only” commission rates; thus, a Fund may be deemed to be paying for research and brokerage services provided by the broker with “soft” or “client commission” dollars which are included in the commission rate. The Investment Manager and the Sub-Advisers generally do not have any formalized “soft dollar” arrangements to use client commissions to obtain research and brokerage services. To the extent the Investment Manager and the Sub-Advisers receive research or other products or services other than execution from broker-dealers in connection with Fund securities transaction, any such services will be limited to research and brokerage within the meaning of Section 28(e) of the Securities Exchange

Act of 1934, as amended. Accordingly, research and brokerage services may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, certain financial and economic studies and forecasts, as well as discussions with research personnel; financial and industry publications; statistical and pricing services, utilized in the investment management process; and services related to the execution, clearing and settlement of securities transactions and functions incidental thereto. Research services obtained by the use of commissions arising from a particular Fund’s portfolio transactions may be used by the Investment Manager and the Sub-Advisers in their other investment activities. In such scenarios where Fund brokerage commissions are used to obtain research or other products or services, the Investment Manager and the Sub-Advisers would receive a benefit because the Investment Manager and the SubAdvisers do not have to produce or pay for the research, products or services. As such, the Investment Manager and the Sub-Advisers may have an incentive to select a broker-dealer based on its interest in receiving the research or other products or services, rather than on Funds’ interest in receiving most favorable execution.

The Investment Manager and the Sub-Advisers may place transactions with a broker-dealer that (i) provide the Investment Manager, the Sub-Advisers or an affiliate with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refer Investors to a Fund, if otherwise consistent with seeking best execution, provided the Investment Manager and/or the SubAdvisers are not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of Investors. With that said, the Investment Manager and the Sub-Advisers may have an incentive to select a broker-dealer based on their interest in receiving Investor referrals rather than on a Fund’s interest in receiving most favorable execution.

When appropriate, the Investment Manager and the Sub-Advisers may, but are not required to, aggregate client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will share commission costs equally and will generally be allocated securities based on the average price achieved for such trades. Partially filled orders will be allocated on an equitable basis.

Lastly, when a trade error is made on behalf of a client account, the Investment Manager and the SubAdvisers will use their best efforts to break or otherwise correct the trade. However, if errors do occur, as a result of human or systematic errors which may or may not be related to, without limitation, trading errors, allocation errors and/or financial recordkeeping, and not as a result of gross negligence, willful misconduct or violation of the applicable laws, the profit or loss related to such error will generally be allocated to the Funds.

Generally, clients are not responsible for any part of the compensation that solicitors receive, and we do not charge clients introduced by such solicitors any higher fee or any additional amount as a result of obligations to pay such solicitors for their solicitation services.

At this time, the Investment Manager has a marketing arrangement with one third-party marketer that may receive compensation from the Investment Manager for Investor referrals.

If, however, a Fund, Investment Manager or the Sub-Advisers receive a proxy request with respect to a security that the Investment Manager or the Sub-Advisers determine potentially could provide material profit or loss benefits to such Fund from voting, the Investment Manager or the Sub-Advisers will seek to vote the proxy in the best interest of such Fund. In practice, the Investment Manager and the Sub-Advisers generally do not vote proxies unless it determines it is in the best interest of such Fund.

The Investment Manager and the Sub-Advisers follow procedures designed to identify conflicts or potential conflicts that could arise between their own interests and those of their respective clients. If it is determined that any such conflict or potential conflict is not material, the Investment Manager or the Sub-Advisers may vote proxies notwithstanding the existence of the conflict. If it is determined, however, that a conflict of interest or potential conflict of interest is material, the Investment Manager or the Sub-Advisers will generally abstain from voting such proxies. The Investment Manager or the Sub-Advisers will not solicit direction from clients on how such votes will be cast.

Clients may obtain a copy of the Investment Manager’s or the Sub-Advisers’ proxy voting policies and procedures upon request. Information about how the Investment Manager or the Sub-Advisers voted specific proxies on behalf of client accounts will also be made available to clients upon request to the Investment Manager or the Sub-Advisers.