Acuitas Investments, LLC: investment adviser

Acuitas is the investment adviser of Acuitas Long/Short Fund, LP and Acuitas Emerging Markets Small Cap Fund, LP (collectively the “Private Funds”), each a private investment limited partnership formed in Delaware. Acuitas also provides discretionary investment advice to separately managed accounts for which we employ our Microcap, Small Cap and Emerging Markets Small Cap strategies. Acuitas specializes in managing multi-manager strategies in the least efficient areas of the equity markets. We select and monitor other independent investment advisers (“subadvisers") who purchase and sell securities for each client’s account. The subadvisers are generally retained through a contractual subadvisory relationship with us. Additional details about the Private Funds’ investment strategies, and the terms and conditions on which we offer ownership interests to eligible investors are described in a current Private Placement Memorandum ("PPM") for each Private Fund, which is provided to all prospective investors. Information in this brochure summarizes certain disclosures in the PPMs. A prospective Private Fund investor is urged to rely on the fuller descriptions in the PPMs, and to contact Acuitas with any questions about the disclosures in the PPMs or this brochure. The Mutual Fund and ETF are managed in accordance with their investment objectives. Information about the Mutual Fund and the ETF are provided in their respective prospectuses and statements of additional information, which are available on the SEC’s website at www.sec.gov or on Acuitas’ website at www.acuitasfunds.com. In servicing our clients, Acuitas takes into account the investment objectives, restrictions and guidelines of each client. However, for the ETF, Private Funds and Mutual Fund, advisory services are not tailored to the individual needs of the investors. Investors in these products may not impose restrictions on Acuitas with respect to the investments we make. The investment strategy is defined in the PPMs for the Private Funds and the respective prospectus for the Mutual Fund and ETF. See also the section entitled "Methods of Analysis, Investment Strategies and Risk of Loss" in this brochure.

As of December 31, 2025, Acuitas managed $ $1,481,084,662 in discretionary assets.

Microcap – 1.10% Small Cap – 0.80% International Small Cap – 1.00% Emerging Markets Small Cap – 1.10%

Fees for the Private Funds are as follows:

Long/Short – 0.5% annual rate with a 10% performance allocation Emerging Markets Small Cap – 0.8% annual rate

Advisory fees and expense-related information for the Mutual Fund and ETF can be found in the current prospectus for each vehicle. Fees for separate accounts will be billed in advance or arrears, as noted in the client agreement, using custodian market values and will exclude any amounts known to be invested in the Acuitas Mutual Fund or ETF. The separately managed accounts will be invoiced directly. Any fees unearned will be either pro-rated or refunded in the event a client terminates. Fees for the ETF, Private Funds and Mutual Fund are included in the gross expenses and paid directly to the Adviser. The management fees paid to Acuitas typically include the fee charged by the subadviser. The Private Funds bear expenses associated with their investment activities and operations and certain other expenses, which may include but are not limited to brokerage commissions; banking and custody charges; interest and fees relating to borrowing; withholding taxes; expenses of research and data collection and analysis; costs of communicating with Limited Partners; legal, accounting, auditing, organizational expenses (but not Acuitas’ organizational expenses); and expenses incurred in the offering and sale of ownership interests in the Private Funds.

Acuitas bears organizational costs and overhead costs associated with operating the investment advisory business, including office space, utilities and compensation of personnel. Investors within the Mutual Fund and ETF will be responsible for a portion of the operating expenses of the Mutual Fund or ETF in which they are invested. Clients may be charged fees in addition to the management fee paid to Acuitas. This can include brokerage commissions and other custodian fees.

However, the potential to receive performance-based fees can create a motive for Acuitas to make riskier investments for the Private Funds and provide preferential treatment since there is an incentive to receive additional fees. However, this is mitigated due to the fact that Acuitas selects other managers to manage and trade for the Private Funds. The subadvisers engaged to manage assets may receive performance-based compensation. In any performance-based compensation arrangement, an investor should understand that the prospect of increased compensation for strong performance could induce the subadviser to recommend investments that are unreasonably risky because the subadviser believes the investment has a prospect of achieving substantial gains that will generate higher performance-based compensation. Because the subadvisers are responsible for all buy and sell decisions for individual securities, Acuitas’ fee arrangement with the various clients will have no impact on portfolio decisions. Manager selection will be based on the desired risk and return characteristics outlined in the respective investment management agreement or PPM. Manager selection may vary for similar mandates due to timing of funding, manager capacity, assets under management or other parameters.

The Subscription Agreement executed by each investor states in detail the several categories of "accredited investor" and "qualified client" under those definitions and requires the investor to qualify for both in order to invest. For the Mutual Fund, clients can be individuals or institutions. Minimum initial investments and additional investments for the Mutual Fund are $2,500 and $100 for Investor Shares and $10,000 and $100 for Institutional Shares, respectively. Please note that Acuitas is not currently offering Investor Shares for purchase although we may choose to do so in the future. There is no minimum for the ETF and it is traded daily on the NASDAQ exchange under the ticker symbol AIMS. Investors will need to establish a brokerage account in order to purchase the ETF. The minimum for separately managed accounts is generally $10 million, but is negotiable and considered on a case-by-case basis.

Small Cap – The Acuitas Small Cap strategy uses a multi-manager approach focused on domestic small cap equities. Acuitas generally considers U.S. Small Cap to include those companies represented in the Russell 2000 Index which the strategy uses as a benchmark. Portfolios generally include allocations to microcap securities to take advantage of market inefficiencies.

Microcap – The Acuitas Microcap strategy uses a multi-manager approach focused on domestic microcap equities. Acuitas generally considers U.S. microcap to include those companies represented in the Russell Microcap Index which the strategy uses as a benchmark. We seek to remain invested down the market capitalization spectrum to take greatest advantage of market inefficiencies.

International Small Cap – The Acuitas International Small Cap strategy uses a multi-manager approach focused on non-U.S. small cap and microcap equities. This is a global product with a moderate exposure to emerging markets. We benchmark our product versus the FTSE Global Small Cap ex U.S. Index. Portfolios include allocations to international microcap to capitalize on what we feel is an area with even greater inefficiency.

Emerging Markets Small Cap – The Acuitas Emerging Markets Small Cap strategy uses a multi-manager approach focused on small cap and microcap equities in emerging markets. We benchmark our product versus the FTSE Emerging Small Cap Index. Portfolios include allocations to equities in frontier markets to capitalize on what we feel is an area with even greater inefficiency.

Long/Short Equity – The Acuitas Long/Short Equity strategy is a multi-manager, absolute return process focused on small and microcap equities, globally. While this strategy is not benchmarked to a traditional long-only market capitalization weighted index, market capitalization criteria for the strategy is generally consistent with Russell’s global suite of small and microcap indexes.

Investment Philosophy Inefficient Market. Acuitas focuses on microcap and small cap segments of the equity markets because we believe they are the least efficient market segments and offer the best opportunities for excess return above the relevant benchmarks. These are the areas in which skilled investment managers should have the greatest ability to demonstrate exceptional stock selection skills.

Research. The core of Acuitas’ investment process is our manager research. The manager research process is driven by a combination of fundamental and quantitative analysis. The initial goal of the research process is to understand the underlying investment manager’s investment process as thoroughly as possible. To achieve this, Acuitas gathers and reviews information about the manager’s firm, investment team and investment process. Once we have identified an investment product of interest, Acuitas' investment professionals typically visit the firm’s offices to learn more about the team and process. Calls and onsite meetings are supplemented by analysis of the manager’s portfolio holdings, review and analysis of its performance patterns and further fundamental research. If Acuitas is able to generate a high level of confidence in the firm’s investment strategy and team, the investment product will be considered for our clients. The primary consideration is Acuitas' confidence in the likelihood the product will outperform its benchmark over five or more years. As a general guide, the Acuitas investment team is able to build enough confidence to invest with about ten percent of the managers we follow closely. Idea Generation. New idea generation is an important part of Acuitas' investment process. We are proactive at searching for new investment products that could be candidates for investment. New products can be identified in a variety of ways, including new startup companies, existing managers starting new products or from databases or referrals. Often new microcap and small cap products are managed by investment teams with which Acuitas has been familiar in the past through research of other firms or products. Portfolio Construction. Acuitas seeks to minimize investment risk and volatility by placing assets with multiple managers. During the research process, we develop a strong fundamental understanding of the underlying manager’s investment process, what types of stocks the portfolios are likely to be invested in, and in what markets the portfolio would be likely to perform well or poorly. For example, investment managers that use a high growth strategy are likely to outperform their benchmarks at different times than investment managers who focus on stocks selling at low valuations. This process gives us insight into combinations of products that should be most complementary and offer the most diversification benefits. Acuitas' investment professionals combine multiple products into portfolios that we believe will minimize the portfolio’s risk while preserving its opportunity for excess return. Acuitas anticipates that accounts will contain a combination of value, growth and core products. Acuitas’ ability to outperform our benchmarks is expected to result from the underlying managers' stock selection skills. Accordingly, we seek to limit factor risks versus the benchmark such as style, market capitalization and other factors. Our goal is to diversify portfolios so that they resemble their respective benchmarks on these dimensions, while capitalizing on the underlying managers’ stock selection skill. Quantitative and Performance Analysis. Acuitas uses quantitative analytical tools to supplement our fundamental research. These tools allow our investment professionals to improve their understanding of an investment manager’s process and

portfolios. The quantitative research includes analysis of current portfolios’ risks, how well different investment products complement one another, and what historical return patterns have been experienced. This perspective helps us to improve our understanding of risk characteristics and return patterns expected in the future, thereby improving portfolio construction. Quantitative analysis also helps Acuitas' professionals verify that an underlying investment manager is following its processes and taking reasonable risks given its investment processes. While understanding past performance patterns is a critical component of our process, and can help to develop future expectations, past performance is not a primary driver of our confidence in a manager’s ability to outperform in the future. Performance patterns are typically cyclical, and it may be the case that the managers who have struggled most recently will be best positioned to outperform in the future. Monitoring and Upgrading. Acuitas will be responsible for ongoing monitoring and research of the investment managers we have selected to manage client assets. Acuitas will focus on ensuring that client assets stay invested with managers in whom we have high confidence, and in products that offer the best opportunity for success. Acuitas professionals will be in frequent contact with the underlying managers, including onsite meetings with the managers’ investment teams, to help ensure their competitive advantages remain intact. In addition, Acuitas will collect and analyze portfolio holdings and monitor risk exposures to analyze whether the portfolios are being invested in a manner consistent with our expectations. Acuitas professionals will diligently look for ways to improve the risk/reward characteristics of client portfolios. Material Risks Acuitas pursues the investment strategies described above, however, the investment parameters for each investment type (Private Fund, Mutual Fund, ETF or separate account) will be outlined in more detail in their respective PPM, prospectus or investment management agreement. Although Acuitas makes every effort to preserve capital and achieve real growth of wealth, investing in the stock markets involves risk of loss that each client should be prepared to bear. Investments may be exposed to, among others, the following risk factors: General Risks

Multi-Manager Risk. Acuitas has broad discretion in selecting managers and in developing a risk profile for our portfolios. Acuitas may develop a risk profile that results in selection of managers whose strategies prove unsuccessful.

Selection of Managers. Acuitas conducts due diligence to select managers with which to invest assets. However, due diligence does not assure success in selection of managers or their performance and may not uncover problems associated with a particular manager. Acuitas may rely upon representations made by managers or other investment professionals. If representations upon which we rely are misleading, incomplete or false, Acuitas may select managers which we otherwise

might have eliminated from consideration if we had received fully accurate and complete information.

Access to Managers. Although Acuitas may want to invest with a particular manager, reasons beyond our control may prevent us from investing. For example, we may not gain access to or invest with a desired manager because the account does not meet eligibility or minimum investment requirements or the manager is not accepting additional investors at the time.

Account Valuations. In computing the asset value of our portfolios, Acuitas places a substantial degree of reliance on the accuracy of the valuations and performance results received from the account custodians. All information is obtained from sources deemed reliable, but there is no representation as to its accuracy. We encourage all clients to compare Acuitas reports with account statements received directly from their custodian.

Diversification. Although each account has diversification objectives, at times Acuitas may invest with a limited number of managers, especially if the amount of money invested in the account is relatively small at the time. A portfolio invested in a limited number of managers may be subject to greater volatility than a portfolio invested with a larger number of managers. Acuitas is not tied to a fixed allocation scheme but may allocate the portfolios among the managers in whatever manner Acuitas determines is most likely to achieve the account’s objectives, and the managers we select may in turn have substantial discretion to allocate and reallocate assets among portfolio investments. There is a risk that Acuitas and/or the managers will, directly or indirectly, commit a disproportionate share of an account’s assets to a few investment strategies.

Manager Operational Risks

Limits of Company Control. Acuitas selects and monitors managers but typically does not make trading decisions. Our success will depend upon the expertise and judgment of the underlying managers who we carefully select and hire to trade assets.

Strategies of Managers. A manager may employ differing trading strategies for several of the manager’s clients. Acuitas’ clients may not achieve the most favorable results with any manager. It is possible that clients may experience poor returns on investments generally.

Performance–Based Compensation to Managers; Layering of Fees. The fee arrangements with managers generally provide that the manager will receive a minimum fee calculated as a percentage of assets under management. Some fee arrangements also may provide that the manager will receive some portion of the appreciation, including unrealized appreciation, of the value of the account or Private Fund being managed. In such arrangements, the manager may suffer no

penalty for realized losses or decreases in the value of the account or Private Fund. Generally, the manager’s compensation is determined separately for each year or shorter fee computation period. Performance-based fee arrangements often (though not always) carry forward losses to subsequent years in determining the fee for those years – so-called “high water mark” structures. Those fee arrangements may give the managers an incentive to make purchases that are unduly risky or more speculative than would be the case in the absence of such performance-based compensation arrangements, in order to restore the manager to a profit sharing position. It is also possible that incentive fees may be paid to managers that show net profit even though the investment, as a whole, incurs a net loss. In addition to the fees charged by managers with whom assets are invested, compensation is payable to Acuitas as described under “Fees and Expenses.” Acuitas’ asset-based compensation is payable regardless of the profitability of the client’s account. The various fees result in a layering that reduces the rate of return that investors can expect to derive from the Private Fund’s investments. Performance based fee arrangements do not apply to the Mutual Fund or ETF. Investment and Trading Risks in General

Equity Risk. Equity holdings, including common stocks, may decline in value because of changes in prices of a particular holding or a broad stock market decline. These fluctuations could be a drastic movement or a sustained trend. The value of a security may decline for a number of reasons that directly relate to the issuer of a security, such as management performance, financial leverage and reduced demand for the issuer’s goods or services, or broader economic or market events, including changes in interest rates, Common stocks in general are subject to the risk of an issuer liquidating or declaring bankruptcy, in which case the claims of owners of the issuer’s debt securities and preferred stock take precedence over the claims of common stockholders.

Loss of Capital. All investments risk the loss of capital. Acuitas does not guarantee or represent that our investment strategies will be successful. Investment results may vary substantially over time.

Investment in Foreign Securities. Investment in foreign securities may involve greater risk than investment in domestic securities due to political considerations, currency controls, the fluctuation of currency exchange rates, foreign taxation, illiquidity of foreign securities markets, unique foreign regulations applicable to such securities, difficulty in enforcing contractual obligations, less government supervision of foreign brokers and custodians, lack of uniform accounting and auditing standards and certain other factors.

Emerging Markets Risk. Investments in emerging markets present greater risks than investing in foreign issuers in general. The risk of political or social upheaval is typically greater. Inflation and rapid fluctuations in inflation rates have had, and may continue to have, negative effects on the economies and markets of certain emerging market countries. A relative lack of information about companies in emerging markets may also exist. Securities traded on emerging markets are potentially illiquid and may be subject to volatility and high transactions costs.

Futures Contracts. Acuitas does use futures contracts to provide equity exposure for some portfolios’ cash reserves. Underlying managers may use futures in the Long/Short Fund as well. Prices of futures can be highly volatile. Among other factors, changing supply and demand relationships, domestic and foreign governmental programs and policies and national and international political and economic events all influence price movements of futures contracts.

Small and Microcap Company Risk. Investments in small and micro capitalization companies may be less liquid and their security prices may fluctuate more than those of larger, more established companies. These factors could adversely affect the ability to sell such securities at a desirable time and price.

Exchange Traded Funds Risk. An investment in an ETF involves substantially the same risks as investing directly in the underlying securities. An ETF may not achieve its investment objective or execute its investment strategy effectively, which may adversely affect performance. ETFs bear fees and expenses and may trade at a premium or discount to the net asset value of its portfolio securities.

Leverage. The Long/Short strategy may utilize leverage by borrowing on margin, entering into swaps and other derivative contracts and other leveraging strategies. Such leverage increases the risk of loss and volatility. As a result, a relatively small price movement in a security may result in immediate and substantial losses to an investor.

Options and Other Derivatives. The Long/Short strategy may invest in exchangetraded and over-the-counter derivatives, including futures and other commodity interests, swaps, options and contracts for differences. These instruments can be highly volatile and expose the investor to a high risk of loss.

Limited Liquidity of Investments. Some strategies may invest in securities that are thinly traded and relatively illiquid. In such cases, the subadviser may not be able to liquidate its investments promptly or it may have to sell them at far less than it believes they are worth. Typically, investments in illiquid securities will be well under 15% of any portfolio.

Investors interested in the Private Funds should refer to the PPM for more information on risks associated with investing in the Private Funds.

While Acuitas believes that individuals may invest for their own accounts, we consider it even more important that advisory personnel avoid conflicts of interest (or even the appearance of conflict) between our clients’ and their own securities’ transactions. Accordingly, the Code of Ethics covers a broad range of securities transactions. The Code imposes limits on personal securities trading and includes sanctions for violations of trading restrictions. The Code of Ethics also includes a strict prohibition against insider trading. In connection with most restrictions or affirmative obligations, the Code of Ethics includes examples so that Acuitas personnel will be better prepared to recognize and avoid

situations in which a conflict of interest may arise that could be detrimental to Acuitas clients. Acuitas may promote our pooled investment vehicles for which we act as adviser to certain separate account clients or prospects on a fully disclosed basis. Because of the relationship between Acuitas and any pooled vehicle that Acuitas advises, we could be considered to have recommended the investment as suitable for a separate account client if such client should invest in the vehicle. Acuitas will inform each client of its relationship with an Acuitas managed fund prior to the client’s investment but does not intend to advise its separate account clients as to the appropriateness of the investment and will not receive any compensation for doing (except to the extent that Acuitas receives fees from that pooled fund). Acuitas will deliver a copy of our Code of Ethics to any actual or prospective investor or client, on request and without charge.

Acuitas’ statements may vary from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities. You should contact us immediately if you do not receive account statements from your custodian on at least a quarterly basis.

If a conflict of interest is determined to exist, Acuitas will vote the securities as we would vote them if only the client's interests were being considered. Under the Private Funds’ Limited Partnership Agreements, Acuitas has discretion to invest assets in other private investment funds managed by unaffiliated advisers. If Acuitas exercises such discretion, to the limited extent that investors in the underlying private investment funds in which the Private Fund invests are permitted to vote on matters under the limited partnership agreement or similar document governing the investment in those underlying funds, Acuitas has full discretion to vote on behalf of the Private Fund. Acuitas will keep records of our votes on any such matters for at least seven years after the end of the fiscal year in which the most recent such action occurred. On request from a Limited Partner at any time, Acuitas will disclose in writing how the Fund voted on any such matter. A copy of Acuitas’ Proxy Voting Policies and Procedures, and information about how we voted client securities, will be provided to any client promptly upon the client's oral or written request.

Personal information we collect: The types of personal information we collect will depend on the product and service you have with us, but can typically include:

Social security number and/or tax identification number Wire Instructions Name and Address

Personal information we disclose: Acuitas does not disclose or sell information about our current or former clients to any third parties, except in the following circumstances:

To companies that are necessary in order to service your account As required by regulatory authorities or law enforcement officials who have jurisdiction over Acuitas, or as otherwise required by law.

How we protect your personal information: To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. If you have any questions about this notice or our privacy policies, please contact us at 206-299-2073.