12 West Capital Management LP: investment adviser

In managing the Funds, 12 West invests principally in equity, equity-related and credit securities traded globally. 12 West Capital Management, LLC is the General Partner of 12 West, and Joel Ramin is its Managing Member. 12 West Capital GP LLC is the Funds’ General Partner (the “General Partner”). Mr. Ramin is also the Managing Member of 12 West Capital GP LLC. 12 West does not participate in wrap fee programs. As of December 31, 2025, we managed U.S. $1,347,862,740 in regulatory assets, all of which is managed on a discretionary basis.

The Domestic Feeder Fund and the Offshore Feeder Fund offer three classes: Class A with no hurdle, Class B with a compounding 6% hurdle, and Class C with a market hurdle such as the Russell 2000 Growth Index. All classes are subject to a high water mark limitation and have either a 12.5% or 25% quarterly Investor-Level Gate. The 12.5% InvestorLevel Gate also includes a two year claw-back provision. DC Opportunity Fund LLC and 12 West Long-Term Hold Overflow Fund LP performance-based allocations are also subject to a minimum hurdle rate. Management fees and performance-based allocations are deducted from the Funds’ accounts by instructing the Funds’ administrator. The Funds shall pay their organizational and initial offering expenses as well as their operating expenses including, but not limited to, all fees, costs and expenses associated with the financing, sourcing, acquiring, holding, hedging and disposing of its investments or proposed

investments (including, without limitation, custodial fees, brokerage fees, short sale expenses, clearing and settlement expenses, bank fees, hedging expenses, ticket charges, commissions, consulting services, due diligence, research and investment related travel expenses, as well as all fees, expenses, interest payments and principal payments due to any legal, financial, accounting, consulting or other advisors, or any lenders, investment banks and other financing sources in connection with the financing, sourcing, acquiring, holding, hedging and disposing of Fund investments or proposed Fund investments, entity formation and maintenance expenses, expenses relating to proxy voting and class action process and services and expenses relating to risk accounting and trading systems), all entity-level taxes, fees or other governmental charges, the costs of any insurance (including, without limitation, directors and officers insurance, if any), expenses incurred in the collection of monies owed to the Fund, the management fee, legal, auditing, consulting, research, and accounting fees and expenses (including, without limitation, expenses associated with the preparation of financial statements, tax returns and Schedules K-1), extraordinary expenses (including, without limitation, litigation-related and indemnification expenses and the costs of any reporting to Fund investors, reasonable expenses of any meetings of the Fund investors, and any “broken-deal” or failed transaction expenses. All the expenses paid by the Funds are fully described in the Funds’ management agreements and offering documents. For further details on our brokerage practices, refer to Item 12 of this brochure. 12 West and its employees do not accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.

Such arrangements also create an incentive to favor higher paying accounts over other accounts in the allocation of investment opportunities. 12 West has policies and procedures designed and implemented to ensure that all Funds are treated fairly and equitably, consistent with 12 West’s fiduciary obligations, to prevent this conflict from influencing the allocation of investment opportunities among Funds. No other hourly, flat or asset-based fees are charged to the Funds. We have, and in the future may, enter into side letters or similar separate agreements with one or more investors in the Funds that may alter the terms and conditions generally applicable to investors in the Fund (including without limitation, with respect to the management fee, the incentive allocations, lock-up periods, transfers, notices, and reporting and disclosure).

Investments made by the Master Fund, as applicable, are collectively referred to as the “Investments.” The Investment Manager, in its sole and absolute discretion, expects to invest the Master Fund’s assets primarily in publicly-traded equity and equity-related securities and will be focused on, but not limited to, companies with the potential to grow rapidly for long periods of time across any industry or geography in the U.S. and internationally. The Investment Manager pursues durable growth because it believes that over very long periods, an equity return generally will approximate the growth in cash flow per share of a company. The Investment Manager believes in constraining assets under management to preserve the ability to make concentrated investments in emerging businesses no matter how small they might be when discovered. There may be a moderate competitive advantage that could accrue to the Investment Manager as competing managers follow their shorter-term success with fundraising, often driving the best minds and teams towards larger, more mature companies. The Investment Manager intends to manage the Master Fund’s asset size to allow for a concentrated portfolio regardless of market capitalization. Limiting assets under management can be, in certain circumstances, a competitive advantage in short-selling where being nimble and market-cap agnostic may yield a broader set of targets. The Investment Manager expects that the long positions held by the Master Fund in the equity of any particular target company at the time of investment generally will be in the range of three to twenty percent (3-20%) of the Master Fund’s assets, and short positions generally will be in the range of one to fifteen percent (1-15%) of the Master Fund’s assets, with median long positions expected to be seven to 10 percent (7-10%) of the Master Fund’s assets, and median short positions two to five percent (2-5%) of the Master Fund’s assets. The Investment Manager anticipates that investment ideas meriting sizing towards the high end of these ranges will be rare but will size investments in its sole and absolute discretion. The Principal’s experience of more than two decades in short-selling has, in the Investment Manager’s view, honed his ability to uncover clearly defined and high-conviction catalysts. The Investment Manager believes that having a large short position for a short and discrete period of time to capitalize on a well-researched and high-conviction catalyst is less risky and more likely to result in profitable short-selling than a collection of smaller “open-ended” short ideas (i.e., ideas with no catalyst). The Investment Manager plans to expose the portfolio to positions of the greatest size for discrete periods of time in advance of catalysts, and to manage the risk around this sizing strategy by immediately covering the position once the catalyst occurs, or fails to occur, thus making permanent loss of capital less likely than such an openended short strategy.

When making a new long investment, the Investment Manager hopes to hold onto the position for decades and will frequently and regularly trade that position to optimize its size. When the Investment Manager cannot find compelling investment opportunities, the Master Fund will not be compelled to remain fully invested. The Investment Manager believes the willingness to stay invested in businesses exhibiting durable growth improves the odds of fully capturing the potential for compounding in those equities. RISK FACTORS An investment in the Funds involves a high degree of risk, including the risk that the entire amount invested may be lost. Investors should consider the following factors before investing in the Funds. The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Funds. See the Funds’ management agreements and offering documents for a more exhaustive list of risk factors. Prospective investors are urged to consult their professional advisers and to thoroughly review the offering documents for each particular Fund before deciding to make an investment in any of 12 West’s Funds. Market Risk. The profitability of any investment activity is affected by general economic conditions, which may affect the level and volatility of interest rates and timing of investor participation in both equities and interest-sensitive securities. The most difficult type of market environment for our strategy is expected from a speculative environment, in which hype, promotional management teams and/or investor euphoria drive stock price movements instead of company fundamentals. No guarantee or representation is made that the investment program will be successful or that the Funds’ returns will exhibit low correlation with the overall market. The profitability of a significant portion of the Funds’ investment program depends to a great extent upon our correctly predicting the future course of price movements of securities and other investments. There can be no assurance that we will be able to accurately predict these price movements. Leverage; Interest Rates; Margin. From time to time, we utilize leverage as part of our investment strategy. While leverage can serve to increase returns to investors, the use of leverage can also expose the Funds to additional levels of risk including (i) greater losses from investments than would otherwise have been the case had the Funds not borrowed to make the investments, (ii) premature liquidations of investment positions forced by margin calls or changes in margin requirements and (iii) losses on investments where the investment fails to earn a return that equals or exceeds the Funds’ cost of leverage. In case there is a sudden and precipitous drop in value of the Funds’ assets, we might not be able to liquidate their assets quickly enough to repay their borrowings, further magnifying the losses incurred by the Funds. In certain credit environments, we may find it difficult or impossible to obtain leverage for the Funds, which could impair our ability to fully implement our investment strategy. In addition, leverage can be terminated on short notice by the lender, which can result in our being forced to unwind positions quickly and at prices below what we deem to be fair value for the positions. Short Selling. From time to time, we engage in the short selling of securities. Short selling involves our borrowing securities which we do not own and then selling them for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling can enable the Funds to profit from declines in market prices to the extent such declines exceed the transaction costs and the costs of borrowing the securities.

A short sale creates the risk of a theoretically unlimited loss, since the price of the underlying security could theoretically increase without limit, thus increasing the cost to the Funds of buying those securities to cover the short position. Short sellers are also subject to the potential risk of a “short squeeze,” which is a situation in which the short seller is prematurely forced out of a short position. The lender of a security used to cover a short generally has the right to demand the return of the security that has been loaned at any time. If a lender were to demand the return of securities that the Funds had borrowed, the Funds would be required to replace the borrowed securities by borrowing identical securities from another lender. If we are unable to replace the borrowed securities, we would be required to close out the short sale by buying identical securities in the market in order to make delivery. In such an event, the Funds could incur significant losses if the securities sold short had increased in value. Securities of Sub-Investment Grade Companies. We may advise the Funds to invest in the securities of sub-investment grade and highly leveraged companies. Although such investments may result in significant returns to the Funds, they may involve a substantial degree of interestrate and liquidity risk. If “natural leverage” created by a company’s high level of borrowing were to work against our short position, there is a risk of increased loss for the Funds. Although we may not do so frequently, should we purchase distressed and/or non-performing debt securities, and subsequent to purchasing them find that they are no longer readily traded by broker-dealers, these securities may not show any return for a considerable period of time and ultimately may not compensate the investors adequately for the risks assumed. Small to Medium Capitalization Companies. We invest in the stocks of companies with small or medium-sized market capitalizations. While we believe that making such investments can provide significant potential for capital appreciation, investing in small or medium-sized market capitalization stocks can also be riskier than investing in stocks of larger companies. The prices of smaller-capitalization stocks are often more volatile than those of largecapitalization stocks. In addition, due to thin trading in some smaller-capitalization stocks, these stocks may be less liquid than larger capitalization stocks. Derivative Instruments. 12 West could potentially create leverage via the use of instruments such as options and other derivative instruments. The value of a derivative depends largely upon price movements in the underlying asset; hence many of the risks applicable to trading the underlying asset are also applicable to derivatives of such asset. In addition, there are a number of other risks associated with derivatives trading, such as increased exposure to liquidity risks and counterparty risks. Options can provide a greater potential for profit or loss than an equivalent investment in the underlying asset and may involve different risks than investing directly in the underlying asset. From time to time, 12 West advises the Funds to purchase and sell ("write") options on equities on national and international securities exchanges. The seller ("writer") of a covered put option (i.e., the writer has a short position in the underlying security) receives a premium for writing the put option but gives up the opportunity for gain on the underlying security below the exercise price of the option and assumes the risk of an increase in the market price of the underlying security above its sales price (in establishing the short position). The writer of an uncovered put option assumes the risk of a decline in the market price of the underlying security below the exercise price of the option. The buyer of a put option assumes the risk of losing its entire investment in the put option. The writer of a covered call option (i.e., the writer holds the underlying security) receives a premium for writing the call option but assumes the risk of a decline in the market price of the underlying security below the value of the underlying security less the premium received and gives up the opportunity for gain on the underlying security above the exercise price of the option. The writer of an uncovered call option assumes the risk of a theoretically unlimited

increase in the market price of the underlying security above the exercise price of the option. The buyer of a call option assumes the risk of losing its entire investment in the call option. Options may be cash settled, settled by physical delivery or settled by entering into a closing purchase transaction. In entering into a closing purchase transaction, the Funds may be subject to the risk of loss to the extent that the premium paid for entering into the closing purchase transaction exceeds the premium received when the option was written. Futures Contracts. The use of futures is a highly specialized activity which involves investment strategies and risks different from those associated with ordinary portfolio securities transactions, and there can be no guarantee that their use will increase the Funds’ return or not cause the Funds to sustain large losses. While the use of these instruments by the Funds may reduce certain risks associated with portfolio positions, the requisite techniques entail certain other risks. The Funds could experience losses if the values of their futures positions were poorly correlated with their other investments or if they could not close out their positions because of an illiquid market. In addition, the Funds will incur transaction costs, including trading commissions, in connection with their futures transactions, and these transactions could significantly increase the Funds’ investment turnover rate. There is no assurance that a liquid secondary market will exist for futures contracts or options purchased or sold, and the Funds may be required to maintain a position until exercise or expiration, which could result in losses. Many futures exchanges limit the amount of fluctuation permitted in contract prices during a single trading day. Once the daily limit has been reached in a particular contract, no trades may be made that day at a price beyond that limit. Contract prices could move to the daily limit for several consecutive trading days permitting little or no trading, thereby preventing prompt liquidation of futures and options positions and potentially subjecting the Funds to substantial losses. Counterparty Risk. Some of the markets in which we effect transactions are "over-thecounter" or "interdealer" markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of "exchange-based" markets. This exposes the Funds to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether bona fide or not) or because of a credit or liquidity problem, thus causing the Funds to suffer a loss. Such "counterparty risk" is accentuated for contracts with longer maturities where events may intervene to prevent settlement or where the Funds have concentrated their transactions with a single or small group of counterparties. We are not restricted from dealing with any particular counterparty or from concentrating any or all of our transactions with a single counterparty. The ability of the Funds to transact business with any one or number of counterparties, the lack of any meaningful and independent evaluation of such counterparties' financial capabilities and the absence of a regulated market to facilitate settlement may increase the potential for losses by the Funds. Custody Risk. There are risks involved in dealing with the custodians or prime brokers who settle Fund trades. The Funds maintain custody accounts with Morgan Stanley & Co, LLC and Goldman Sachs & Co. Inc. as its prime brokers and custodians (the “Prime Brokers”). Although we monitor the Prime Brokers and believe that they are appropriate custodians, there is no guarantee that the Prime Brokers, or any other custodians that the Funds may use from time to time, will not become bankrupt or insolvent. While both the U.S. Bankruptcy Code and the U.S. Securities Investor Protection Act of 1970 seek to protect customer property in the event of a bankruptcy, insolvency, failure or liquidation of a broker-dealer, it is likely that, in the event of a failure of a broker-dealer that has custody of Fund assets, the Funds would incur losses due to their assets being unavailable for a period of time and/or the ultimate receipt of less than full recovery of their assets.

12 West and/or the Prime Brokers may appoint sub-custodians in certain non-U.S. jurisdictions to hold the assets of the Funds. The Prime Brokers may neither be responsible for cash or assets which are held by sub-custodians in certain non-U.S. jurisdictions nor for any losses suffered by the Funds as a result of the bankruptcy or insolvency of any such subcustodian. The Funds may therefore have potential exposure on the default of any subcustodian, and, as a result, many of the protections that would normally be provided to a Fund by a custodian may not be available to the Funds. Under certain circumstances, including certain transactions where the Funds’ assets are pledged as collateral for leverage from a nonbroker-dealer custodian or a non-broker-dealer affiliate of the Prime Brokers or where the Funds’ assets are held at a non-U.S. custodian, the securities and other assets deposited with the custodian or broker may not be clearly identified as being assets of the Funds, and thus the Funds could be exposed to a credit risk with regard to such parties. Custody services in certain non-U.S. jurisdictions remain undeveloped, and, accordingly, there is a transaction and custody risk of dealing in certain non-U.S. jurisdictions. Given the undeveloped state of regulations on custodial activities and bankruptcy, insolvency or mismanagement in certain non-U.S. jurisdictions, the ability of the Funds to recover assets held by a sub-custodian in the event of the sub-custodian's bankruptcy or insolvency could be in doubt, as the Funds may be subject to significantly less favorable laws that lack many of the protections that would be available under U.S. laws. In addition, there may be practical or temporal problems associated with enforcing the Funds’ rights to its assets in the case of a bankruptcy or insolvency of any such party. Diversification Risk. The Funds will be heavily concentrated in equity securities. In addition, the Funds may not be diversified among industries, geographic areas or issuers. Accordingly, the Funds may be subject to a more rapid change in value than would be the case if the Funds were required to maintain a wide diversification among industries, investment areas, types of securities and issuers. Risk of Global Investing. Investments in securities of non-U.S. issuers (including non-U.S. governments) and securities denominated or whose prices are quoted in non-U.S. currencies pose, to the extent not properly hedged, currency exchange risks (including blockage, devaluation and non-exchangeability) as well as a range of other potential risks including expropriation, confiscatory taxation, political or social instability, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding securities of nonU.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those of U.S. issuers. Transaction costs of investing in non-U.S. securities markets are generally higher than in the U.S. There is generally less government supervision and regulation of exchanges, brokers and issuers than there is in the U.S. The Funds might have greater difficulty taking appropriate legal action in non-U.S. courts. Non-U.S. markets also have different clearance and settlement procedures that in some markets have at times failed to keep pace with the volume of transactions, thereby creating substantial delays and settlement failures that could adversely affect the Funds’ performance. Currency Risks. The Funds’ investments that are denominated in currencies other than the U.S. dollar are subject to the risk that the value of the particular currency will change in relation to one or more other currencies. As a result, the Funds could realize a net loss on an investment, even if there were a gain on the underlying investment before currency losses were taken into account. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. We may seek to hedge these risks by investing in currencies, currency futures contracts and options on currency futures contracts, forward currency contracts, swaps, swaptions or any combination thereof (whether exchange traded or not), but there can be no assurance that such strategies will be implemented or effective.

Debt Securities. We may invest in unrated or low-grade debt securities which are subject to greater risk of loss than higher-rated debt securities. The Funds may invest in debt securities which rank junior to other outstanding securities and obligations of the issuer, all or a significant portion of which may be secured on substantially all of that issuer’s assets. The Funds may invest in debt securities that are not protected by financial covenants or limitations on additional indebtedness. In addition, evaluating credit risk for foreign debt securities involves greater uncertainty because credit rating agencies throughout the world have different standards, making comparison across countries difficult. Liquidity; Valuation. While the Funds trade primarily liquid equities, we designate certain investments as a “Designated Investment” at the time of acquisition of such investment. Designated Investments generally include illiquid or difficult to value investments. The sale of any such investments may be possible only at substantial discounts. Limitations on Withdrawals. Our terms of withdrawal include restrictions and are set forth in the offering documents for the Funds. An investor’s redemption from the Funds may be subject to a withdrawal fee. In addition, investors who either partially or completely withdraw from the Funds may still be subject to liability related to a specific time period in which the withdrawing investor was invested in the Funds. Liabilities may include, among others, tax claims, claims of 12 West or its affiliates for indemnification and liabilities arising from litigation. For certain Funds we may also require, at any time, upon at least twenty days’ prior written notice, that any investor withdraw all or a portion of their investment. Business and Regulatory Risks of Private Investments Funds. The regulatory environment for private funds is evolving, and changes in the regulation of private funds and their investing activities may adversely affect the ability of a Fund to pursue its investment program and the value of the investments held by the Fund. There has been an increase in governmental, as well as self-regulatory, scrutiny of the alternative investment industry in general. It is impossible to predict whether changes in regulations may occur, but any regulations that restrict a Fund’s activities could have a material adverse effect on the Fund’s investments, including, without limitation, changes to regulatory and tax matters that may have an adverse impact on the Fund’s investment activities. In addition, regulatory scrutiny may increase the Fund’s exposure to potential liabilities and to legal, compliance and other related costs. Increased regulatory oversight may also impose additional administrative burdens on us, including, but not limited to, responding to investigations and implementing new policies and procedures. Such burdens may divert our time, attention, and resources from such Fund’s activities. Market Disruption and Geopolitical Risk. The Funds may be subject to the risk of loss arising from direct or indirect exposure to a number of types of other catastrophic events, including, without limitation, (i) public health crises, including any outbreak of SARS, H1N1/09 influenza, avian influenza, coronavirus, Ebola or other existing or new epidemic diseases or the threat thereof; (ii) other major events or disruptions, such as hurricanes, earthquakes, tornadoes, fires, flooding and other natural disasters; (iii) acts of war or terrorism, including cyberterrorism or (iv) major or prolonged power outages or network interruptions. The extent of the impact of any such catastrophe or other emergency on a Fund and its investments’ operational and financial performance will depend on many factors, including the duration and scope of such emergency, the extent of any related travel advisories and restrictions, the impact on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. In particular, to the extent that any such event occurs and has a material effect on global financial markets or specific markets in which a Fund participates (or has a material effect on a Fund’s investments or locations in which such investments or we operate or on any of their respective personnel) the risks of loss could be substantial and

could have a material adverse effect on a Fund or our ability to fulfill a Fund’s investment objectives. General Economic Conditions and Recent Events. Various sectors of the global financial markets have recently experienced extended periods of market volatility, such as disruptions in global supply chains, natural disasters due to climate change, high inflation, the ongoing invasion of Ukraine by Russian forces, and U.S. imposed tariffs. These geopolitical conditions continue to disrupt global markets having an adverse effect on the financial markets domestically and globally. Consumer and business confidence could increase market volatility and reduce liquidity, which could cause a materially adverse effect on Funds’ performance and overall ability to achieve its investment strategies. Conflicts of Interest Generally. Each Fund’s governing documents discuss what we believe to be the most significant conflicts of interest associated with an investment in such Fund. Some of these conflicts are summarized in this Brochure. However, this Brochure does not attempt to describe all of the conflicts of interest associated with an investment in the Funds. Investors should carefully consider the conflicts of interest herein as well as those in the governing documents prior to investing in a Fund.

The foundation of the Code is based on the underlying principles that: • Employees must at all times place the interests of the Funds first; • Employees must make sure that all personal securities transactions are conducted consistent with the Code and should avoid any actual or potential conflicts of interest or abuse an individual’s position of trust and responsibility; and • Employees should not take inappropriate advantage of their position at 12 West. All 12 West employees are deemed to be “Access Persons” and are required to adhere to the Code, which covers the duty of confidentiality as well as personal trading. All employees are required to certify their adherence to the Code upon commencement of employment and quarterly thereafter. In general, employees (and members of their immediate households) are not permitted to invest in equities, options, futures or commodities, except for the purpose of holding or liquidating any such holdings after the commencement of employment at 12 West. All such trades require pre-approval from the CCO. This policy does not apply to transactions involving government securities or open-end mutual funds, ETFs or other instruments which afford the investor no discretion over individual securities transactions. All 12 West employees must send duplicate copies of trade confirmations and brokerage statements to the CCO. These records are used to monitor compliance with the foregoing policies. Employees must also obtain pre-approval from the CCO before engaging in any outside business activities. Insider Trading Policies and Procedures 12 West maintains Insider Trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information. Among other things, such policies seek to control and monitor the flow of inside information to and within 12 West and to prevent trading based on inside information. On a periodic basis, our employees are required to certify to their compliance with the Compliance Manual and the Code, including the Insider Trading Policies. Our Code is available upon request. Privacy Policy We are committed to maintaining the confidentiality, integrity and security of our investors’ personal information. It is our policy to collect only information necessary or relevant to our management business and use only legitimate means to collect such information. We do not disclose any non-public personal information about current or former investors to anyone except for servicing and processing transactions and as required by law. We restrict access to non-public personal information about investors to those employees with a legitimate business need for the information. We follow security practices and maintain physical, electronic and procedural safeguards aimed at protecting investor non-public personal information. Additionally, we provide a copy of our privacy policy to our investors on an annual basis.

Our privacy policy is available upon request.

In selecting an appropriate broker-dealer, we take into consideration pricing, quality of service, reliability, financial status, execution capability, commission rates, responsiveness, quality of research services (e.g., ideas, analysis, and investment strategies), specialized execution and block positioning capabilities, clearance and settlement and custodial services. Aggregation In general, we aggregate trade orders for the Funds to achieve more efficient execution or to provide for equitable treatment among accounts. The Funds participating in aggregated trades will be allocated securities based on the average price achieved for such trades with all other transaction costs shared on a pro rata basis. 12 West will not aggregate transactions unless consistent with our duty to seek best execution. We reserve the right to, at our sole discretion, change brokerage and custodial arrangements for the purpose of trading on behalf of the Funds without further notice to investors. Allocation Our policy prohibits any allocation of trades in a manner that results in more favorable treatment for our proprietary accounts, affiliated accounts or any Fund. We follow a policy for the fair and equitable allocation of transactions that generally analyzes each trade, taking into consideration the specifics of each trade and the characteristics of each Fund. To the extent that multiple Funds participate in a particular investment, such investment will generally be allocated pro-rata among such Funds, unless facts specific to the transaction and Funds warrant an alternative allocation methodology. Principal Trading Our policy and practice is to not engage in any principal transactions. However, in the event that 12 West does engage in such transactions, it will do so consistent with our fiduciary duties and ensure that the transaction is in the best interest of the participating accounts and will obtain informed consent from the participating accounts as required by applicable law and regulation, including Section 206(3) of the Advisers Act and its internal written policies. Soft Dollars The Firm does not currently enter into soft dollar arrangements with brokers, although the Firm has in the past and may in the future. Soft dollar arrangements arise when an investment adviser obtains products and services, other than securities execution, from a broker in return for directing Fund securities transactions to the broker. Soft dollar arrangements may pose a conflict of interest for 12 West in that such arrangements may allow 12 West to pay with Fund commissions expenses that might otherwise be borne by 12 West. 12 West may have

an incentive to select a broker based on 12 West’s interest in receiving the research or other products or services offered by such broker rather than on Funds’ interests in receiving most favorable execution. To the extent that it engages in soft dollar transactions, 12 West will comply with the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934, as amended. Under this provision, in exercising its discretionary authority to select or arrange for the selection of brokers for execution of transactions for Funds, and, subject to its duty to obtain best execution, 12 West may consider the value of research and brokerage products and services (collectively, “Research”) provided by such brokers. Research may include, among other things, proprietary research from brokers, which may be written or oral. Research products may include, among other things, databases and quotation services. Research services may include, among other things, research concerning market, economic and financial data, a particular aspect of economics or on the economy in general, statistical information, pricing data and availability of securities, financial publications, electronic market quotations, performance measurement services, analyses concerning specific securities, companies, industries or sectors, market, economic and financial studies and forecasts, appraisal services and invitations to attend conferences or meetings with management or industry consultants. Accordingly, if 12 West determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, a Fund may pay commissions to such broker in an amount greater than the amount another broker might charge. Trade Errors On occasion, the Firm experiences errors with respect to trades made on behalf of the Funds. Trade errors can result from a variety of situations, including for example, when the wrong security is purchased or sold, when the correct security is purchased or sold but for the wrong account, when the wrong amount is purchased or sold (e.g., 1,000 shares instead of 10,000 shares are traded) or when a misallocation among the Funds occurs. The SEC has conveyed its general view that an adviser has a fiduciary duty to place trades accurately. We endeavor to detect trade errors prior to settlement and correct them in an expeditious manner. In addition, we will not correct a trade error made for one Fund by causing the other Fund to buy or sell the securities. We also will not directly or indirectly use soft dollars to correct trade errors.rately. Directed Brokerage Directed brokerage refers to instances in which a client retains the discretion to choose brokers and instructs us to direct portfolio transactions to a particular broker-dealer. We do not permit any directed brokerage arrangements.