Hildene Capital Management: investment adviser

The commitment was coincident with certain affiliated entities of HoldCo signing a definitive agreement to acquire SILAC, Inc., the parent company of SILAC Insurance Company, a provider of fixed indexed annuities. Jefferies entered into a strategic relationship with Hildene in 2022, as a result of which Jefferies already owns a revenue share in HCM’s asset-management business. Jefferies will exchange its existing revenue share; a portion of its interest in a Hildene-managed private fund; and $340 million in cash for a 50% interest in HoldCo. Certain of HCM’s principals will contribute their current ownership in HCM plus approximately $250 million of fund and related equity interests to HoldCo, and will own the remaining 50% of HoldCo. Subject to customary closing conditions, including receipt of required regulatory and client approvals, these transactions are expected to close in the second quarter of 2026. Hildene Collateral Management Company, LLC (“HCMC I”), a Delaware limited liability company, was founded in December 2016 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC II, LLC (“HCMC II”), a Delaware limited liability company, was founded in October 2018 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC III, LLC (“HCMC III”), a Delaware limited liability company, was founded in December 2019 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. Taberna European Capital Management, LLC, (“Taberna Europe” and, together with HCMC I, HCMC II and HCMC III collectively, “HCMC”), a Delaware limited liability company, was purchased by HCMC Holding Company, LLC (“HCMC HoldCo”) in February 2025, and provides portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC I, HCMC II, HCMC III and Taberna Europe are each a wholly-owned subsidiary of HCMC HoldCo. Prior to January 2025, HCMC HoldCo was majority beneficially owned by the Jefferson Entities. Effective as of January 2025, HCMC HoldCo and its subsidiaries are wholly-owned direct and indirect subsidiaries of Hildene Re Holdings, LLC, Series 1 (“Hildene Re Holdings”). Hildene Re Holdings is majority owned by Hildene Insurance Holdings, LLC (“HIH”), a private fund managed by HCM as discussed further below. The remaining interests in Hildene Re Holdings are owned by Hildene Re Management Holdings, LLC, a Delaware limited liability company and an affiliated company of HCM. HCMC HoldCo is indirectly owned by HCM clients and employees. None of HCMC HoldCo, HCMC I, HCMC II, HCMC III nor Taberna Europe are publicly owned or traded. Hildene Structured Advisors, LLC (“HSA”), a Delaware limited liability company, was founded in October 2017 to provide portfolio and collateral management services primarily to new issue collateralized debt obligations sponsored by HSA. HSA is a wholly-owned subsidiary of HoldCo, and is not publicly owned or traded.

Each of HCMC I, HCMC II, HCMC III, Taberna Europe and HSA are included in Form ADV, Schedule R, as relying advisers, and are referred to individually herein as a “CM Affiliate” and collectively herein as “CM Affiliates.” Compensation received by each CM Affiliate is retained by such CM Affiliate and is ultimately retained by the clients and employees that own such CM Affiliate. Types of Advisory Services HCM provides continuous investment management services on a fully discretionary basis to a diverse array of clients, including institutions and pooled investment vehicles and in limited circumstances, nondiscretionary investment management services. Services provided are consistent with each client’s investment guidelines as noted in the applicable investment management agreement and/or offering documents. HCM primarily provides advice with respect to structured finance opportunities such as collateralized debt obligations (“CDOs”), collateralized loan obligations (“CLOs”), residential mortgage-backed securities (“RMBS”), and other types of debt securities or debt obligations backed by the payments from pools of fixed income instruments. HCM also advises clients on other types of fixed income and equity securities, including, without limitation, trust preferred securities issued by bank and insurance holding companies and real estate investment trusts, high yield bonds, syndicated bank loans, mortgage loans, common and preferred equity of various issuers, consumer loans, multifamily loans and other types of investments. HCM specializes in complex financial instruments and uncovering overlooked long-term value opportunities within inefficient markets. With a disciplined, systematic approach, HCM seeks to achieve high risk-adjusted returns through calculated investments at deeply discounted fundamental values in dislocated markets. Structured finance investments and other types of investments that HCM advises on can be complex, opaque and require specialized expertise to analyze. HCM provides its investment management services through a variety of vehicles, including private funds and separate accounts. A description of the advisory services HCM provides in respect of these vehicles is as follows. Private Funds Hildene Opportunities Master Fund, Ltd. (“HOF”) HOF was launched in May 2008 for the purpose of investing and trading primarily in structured finance securities including collateralized debt obligations, collateralized loan obligations, mortgage-backed securities, asset-backed securities, bank debt, special situations, high-yield bonds and special situation equity securities. HOF is part of a “master-feeder” fund structure comprised of investments by three feeder funds, Hildene Opportunities Fund, LP, a Delaware limited partnership established for U.S. taxable investors, Hildene Opportunities Offshore Fund, Ltd., a Cayman Islands-based corporation established for non-U.S investors and U.S. tax-exempt investors, and Hildene Opportunities Rated Feeder Fund, LP, a Delaware limited partnership established for U.S. based insurance company investors. HOF’s investment objective is to achieve absolute risk-adjusted returns over an extended period of time with a minimum correlation to the broadly-based stock and bond indices. HOF invests (directly and indirectly) primarily in CDOs backed by trust-preferred securities (“TruPS”) issued by small and regional financial institutions in the United States (including CDOs managed by affiliates of HCM).

HOF invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Opportunities Master Fund II, Ltd. (“HOF II”) HOF II was launched in August 2011 for the purpose of investing and trading primarily in credit-related opportunities including small and medium-sized corporate credits, single name credits, CLOs, seasoned residential mortgage-backed securities, asset-backed securities, bank debt, special situations, high-yield bonds, seasoned ABS CDOs, CRE CDOs, TruPS CDOs and other structured credit investments (including CDOs managed by affiliates of HCM). HOF II is part of a “master-feeder” fund structure comprised of investments by two feeder funds, Hildene Opportunities Fund II, LP, a Delaware limited partnership established for U.S. taxable investors, and Hildene Opportunities Offshore Fund II, Ltd., a Cayman Islandsbased corporation established for non-U.S investors and U.S. tax-exempt investors. HOF II’s investment objective is to achieve absolute risk-adjusted returns over an extended period of time with a minimum correlation to the broadly-based stock and bond indices. To do this, HOF II primarily invests in credit-based securities, applying a thorough and multi-faceted fundamental valuation of the underlying structure. This entails an in-depth analysis of the legal components, a detailed analysis of the underlying cash flows and a thorough understanding of the overall credit risk of the underlying investment. HOF II invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Insurance Holdings, LLC (“HIH”) In August 2022, Hildene established Hildene Re SPC, Ltd. (previously known as Ludlow Re SPC, Ltd.), a Class B-III licensed insurance company domiciled in the Cayman Islands (“Hildene Re”). Hildene Re is wholly owned by Hildene Re Holdings. Hildene Re has entered into reinsurance contracts to reinsure fixed index annuities through quota share agreements with two U.S.-based insurance companies. Hildene launched HIH in July 2024 to: (i) acquire a majority interest in Hildene Re Holdings and Hildene Re, which were formerly owned by other Hildene-managed accounts as well as principals and employees of Hildene, (ii) make strategic investments in insurance companies and (iii) invest in assets or origination platforms that are a fit for Hildene Re’s regulatory portfolio requirements. Hildene expects Hildene Re to continue to enter into additional reinsurance transactions in the future. Hildene Private Credit Fund I, LP (“HPCF”) HPCF was launched in January 2022, held its first close in November 2022 and its final close in April 2024. The fund was formed for the purpose of investing and trading primarily in residential, multifamily and consumer/specialty assets through the formation of unique, exclusive or limited access strategic relationships with operating partners that are actively involved in the origination, sourcing, monitoring, servicing or securitizing of residential, multifamily and consumer loans. HPCF’s investment objective is to achieve absolute risk-adjusted returns with low correlation to traditional fixed income and equity benchmarks through a combination of current income and capital appreciation.

Hildene Private Credit Rated Feeder Fund I, LP (“HPCF Rated Fund”) was formed in September 2023 and invests all of its investable assets in limited partner interests of HPCF. HPCF invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Asset Based Credit Fund II (“HABC II”) HABC II was formed in October 2024 and held its first close in August 2025. The fund was formed for the purpose of investing and trading primarily in residential, multifamily and potentially consumer/specialty assets through the formation of unique, exclusive or limited access strategic relationships with operating partners that are actively involved in the origination, sourcing, monitoring, servicing or securitizing of residential, multifamily and consumer loans. HABC II’s investment objective is to generate superior riskadjusted returns primarily by investing in housing, consumer or other asset-backed credit instruments, which may include, but are not limited to, acquiring or originating housing-related loans or other financing transactions relating to the acquisition, construction or improvement of real estate. HABC II is part of a dual “master-feeder” fund structure comprised of investments by two feeder funds, Hildene Asset Based Credit Fund II, LP (“HABC II Onshore”), a Delaware limited partnership established for U.S. taxable investors, and Hildene Asset Based Credit Offshore Fund II, LP a Cayman Islands-based exempted limited partnership for non-U.S investors and U.S. tax-exempt investors. Hildene Asset Based Credit Rated Feeder Fund II, LP (“HABC II Rated Fund”) was formed in July 2025 and invests all of its investable assets in limited partner interests of HABC II Onshore. HABC II invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. HCM 2021-1, LLC In January 2021, Hildene launched HCM 2021-1, LLC (“HCM 2021-1”), a co-investment vehicle established to acquire multifamily credit investments, predominantly "B-pieces" backed by Freddie Mac loans. Hildene TruPS Co-Invest Fund, LP (“TruPS Co-Invest Fund”) In October 2022, Hildene launched the TruPS Co-Invest Fund for the purpose of investing in certain TruPS CDOs. Bryant Park & Orchard Park Credit Funds Bryant Park Credit Fund I, LP (previously known as Hildene Rated Credit Fund I, LP) and Bryant Park Credit Fund II, LP (previously known as Hildene Rated Credit Fund II, LP) were formed in September 2022, Bryant Park Credit Fund III, LP (previously known as Hildene Rated Credit Fund III, LP) was formed in May 2023 and Bryant Park Credit Fund IV, LP was formed in December 2023. Bryant Park Credit Fund I, LP, Bryant Park Credit Fund II, LP, Bryant Park Credit Fund III, LP and Bryant Park Credit Fund IV, LP are collectively referred to herein as the “Bryant Park Credit Funds.” The Bryant Park Credit Funds’ investment objective is to generate superior risk-adjusted returns primarily by investing in TruPS, including both TruPS CDOs and single name TruPS.

Orchard Park Credit Fund I, LP (“Orchard Park Credit Fund”) was formed in February 2024. The Orchard Park Credit Fund’s investment objective is to generate superior risk-adjusted returns primarily by investing in TruPS, including both TruPS CDOs and single name TruPS. Separate Accounts HCM manages separate accounts for institutional clients. These separate accounts invest primarily in structured finance opportunities, including CDOs and CLOs, preferred stock and subordinated debt issued by banks or bank holding companies, high yield bonds, and other types of credit-related assets. Specific investment strategies employed by HCM in connection with any separate account are memorialized in an advisory services contract with the account holder. Notwithstanding the foregoing, HCM generally retains the authority to invest and trade on behalf of its clients in a wide variety of instruments and securities of all kinds and descriptions, whether privately placed or publicly traded, including, but not limited to, common or preferred stock, bonds and other debt securities (including U.S. government and agency securities), convertible securities, accounts receivable, notes, interests in other investment funds and vehicles, loans and loan participations (including second lien or mezzanine loans on a secured or unsecured basis), instruments issued by distressed companies, limited partnership or limited liability company interests, repurchase agreements with respect to any securities, mutual fund shares, closed-end investment funds, options, warrants, commodities, futures contracts, currencies (including forward contracts therein), derivative products of all types (including interest rate and currency derivatives, total return swaps, credit default swaps and other types of swaps, forward contracts and structured/indexed securities), monetary instruments, cash and cash equivalent investments. Reinsurance Accounts In connection with Hildene Re’s reinsurance business, Hildene manages separate accounts that invest insurance- and reinsurance-related capital (“Hildene Insurance Accounts”). Among other things, Hildene Insurance Accounts invest in securities of issuers affiliated with Hildene accounts, including asset back securities and other debt securities and instruments issued (as part of a financing, refinancing or similar transaction) by other Hildene accounts. Hildene Insurance Accounts also provide financing to other Hildene accounts from time to time. Other Clients HCM may also from time to time manage other accounts which utilize investment strategies that may or may not be similar to strategies employed by HCM on behalf of existing clients. Tailored Advice and Investment Restrictions HCM offers investment strategies through a variety of vehicles, including separate accounts and private funds. HCM may agree to tailor its advice in respect of separate account clients on a client-by-client basis, and may agree to impose reasonable restrictions on the types of investments made on behalf of such accounts. HCM’s investment advice in respect of the private funds it manages is governed by the offering materials and governing documents of such funds, and is not tailored to specific investors in such funds. On occasion, investment opportunities may be identified which are larger than existing capacity for a fund. In such circumstances, HCM may allow specific clients and/or fund investors to participate directly in such

investments, either on a standalone basis or alongside an investment by the fund. Any such opportunities are presented only to individual clients or fund investors who are sophisticated enough to understand both the risks of the investment and the risk to the client from direct exposure to the same investment held within the fund. Such opportunities may also be offered to prospective clients. Relying Advisers Hildene Collateral Management Company, LLC HCMC I is primarily engaged in the business of providing portfolio and collateral management services to various CDO issuers. HCMC I currently acts as collateral manager for the following CDO issuers: Trapeza CDO I, LLC, Trapeza CDO III, LLC, Trapeza CDO IX, Ltd., Trapeza CDO X, Ltd., Trapeza CDO XI, Ltd., Trapeza CDO XII, Ltd. and Trapeza CDO XIII, Ltd. (collectively, the “Trapeza CDOs”); and Alesco Preferred Funding X, Ltd., Alesco Preferred Funding XI, Ltd., Alesco Preferred Funding XII, Ltd., Alesco Preferred Funding XIII, Ltd., Alesco Preferred Funding XIV, Ltd., Alesco Preferred Funding XVI, Ltd. and Alesco Preferred Funding XVII, Ltd. (collectively, the “HCMC Alesco CDOs”). The management rights in respect of the Trapeza CDOs were acquired from Trapeza Capital Management, LLC and its affiliates between March 2017 and June 2017. The management rights in respect of the HCMC Alesco CDOs were acquired from affiliates of Fortress Investment Group LLC in November 2018. The Trapeza CDOs and HCMC Alesco CDOs are each governed by an indenture and collateral management agreement that sets forth the manner in which each CDO is to be managed, including types of eligible collateral, investment objectives and risk criteria. HCMC I is entitled to fees for its services and such fees will be indirectly borne by clients to the extent the clients invest in HCMC I-managed CDOs. HCMC II, LLC and HCMC III, LLC HCMC II and HCMC III are primarily engaged in the business of providing portfolio and collateral management services to various CDO issuers. HCMC II currently acts as collateral manager for the following CDO issuers: Taberna Preferred Funding IV, Ltd., Taberna Preferred Funding VI, Ltd. and Taberna Preferred Funding VIII, Ltd. (the “HCMC II Taberna CDOs”). HCMC III currently acts as collateral manager for the following CDO issuers: Taberna Preferred Funding I, Ltd., Taberna Preferred Funding II, Ltd. and Taberna Preferred Funding V, Ltd. (together with the HCMC II Taberna CDOs, collectively, the “Taberna CDOs”). The management rights in respect of the Taberna CDOs were acquired in March 2020. HCMC III also serves as collateral manager for Alesco Preferred Funding IX, Ltd. (“Alesco IX”), which HCMC III assumed the management rights to in March 2021. Additionally, HCMC III serves as collateral manager for MMCapS Funding XVII, Ltd. and MMCapS Funding XVIII, Ltd. (collectively, the “MMCapS CDOs”). The management rights in respect of the MMCapS CDOs were acquired in December 2024. HCMC III also serves as collateral manager for Alesco Preferred Funding V, Ltd. (“Alesco V”) and Alesco Preferred Funding VIII, Ltd. (“Alesco VIII”), which HCMC III assumed the management rights to in July 2025, and Alesco Preferred Funding III, Ltd. (“Alesco III”), Alesco Preferred Funding IV, Ltd. (“Alesco IV”) and Alesco Preferred Funding VI, Ltd. (“Alesco VI”, together with the HCMC Alesco CDOs, Alesco IX, Alesco V, Alesco VIII, Alesco III and Alesco IV, the “Alesco CDOs”), which HCMC III assumed the management rights to in September 2025. The Taberna CDOs, Alesco CDOs and the MMCaps CDOs are each governed by an indenture and collateral management agreement that sets forth the manner in which each CDO is to be managed, including types of eligible collateral, investment objectives and risk criteria. HCMC II and HCMC III are entitled to fees for

their services and such fees will be indirectly borne by clients to the extent the clients invest in HCMC IIor HCMC III-managed CDOs. Taberna European Capital Management, LLC Taberna Europe is primarily engaged in the business of providing portfolio and collateral management services to various CDO issuers. Taberna Europe currently acts as collateral manager for the following CDO issuers: Taberna Europe CDO I p.l.c. and Taberna Europe CDO II p.l.c. (the “Taberna Europe CDOs”). HCMC HoldCo acquired 100% of the membership interests of Taberna Europe in February 2025. The Taberna Europe CDOs are each governed by a trust deed and collateral management agreement that sets forth the manner in which each CDO is to be managed, including types of eligible collateral, investment objectives and risk criteria. Taberna Europe is entitled to fees for its services and such fees will be indirectly borne by clients to the extent the clients invest in Taberna Europe-managed CDOs. The Trapeza CDOs, Alesco CDOs, Taberna CDOs, Taberna Europe CDOs and MMCapS CDOs, together with each other CDO managed from time to time by HCMC or any other collateral manager affiliate of HCMC HoldCo, are referred to herein collectively as the “HCMC CDOs.” Certain clients of Hildene, including, but not limited to, HOF, HOF II, HIH, TruPS Co-Invest Fund, the Bryant Park Credit Funds, Orchard Park Credit Fund, certain separately managed accounts and the Insurance-Wrapped Vehicles (defined below) invest in one or more of the HCMC CDOs. Hildene Structured Advisors, LLC HSA is primarily engaged in the business of providing portfolio and collateral management services to new issue CDOs sponsored by Hildene clients. As of December 31, 2025, HSA acts as collateral manager or collateral servicer on the following securitization transactions: Hildene TruPS Securitization 2018-1, Ltd. (“HITR 2018-1”); Hildene TruPS Securitization 2019-2, Ltd. (“HITR 2019-2”); Hildene TruPS Securitization 2020-3, Ltd. (“HITR 2020-3”); Hildene TruPS Securitization 4, Ltd. (“HITR 4”); Hildene TruPS Securitization 5, Ltd. (“HITR 5”); and Hildene TruPS Securitization 6, Ltd. (“HITR 6”, together with HITR 2018-1, HITR 2019-2, HITR 2020-3, HITR 4, and HITR 5, the “HITR CDOs”). Additionally, HSA acts as collateral servicer to 17 TruPS resecuritizations (the “Repack Issuers”). HSA also serves as servicer to Star Point 2025-1, Ltd (“Star Point”), a resecuritization backed by mortgagebacked securities issued by Freddie Mac in connection with its Small Balance Loan Program. Additionally, HSA serves as collateral servicer to three insurance‑wrapped securitization vehicles and a related premium reserve account entity established in connection with an insurance-wrapped vehicle (the “InsuranceWrapped Vehicles”). HSA has also sponsored and currently manages two other pre-securitization warehouse vehicles in anticipation of one or more future securitization transactions: HITR Quattro, Ltd. (previously known as Hildene TruPS Securitization 2021-4, Ltd.) (“HITR Quattro”); and Hildene Financials Securitization 20201, Ltd. (“HIFI 2020-1”). HSA also provides portfolio and collateral management services to a CDO issuer, Hildene Community Funding CDO, Ltd. (“HCOMF”, together with the HITR CDOs, HITR Quattro, HIFI 2020-1, the Repack Issuers, Star Point, and the Insurance-Wrapped Vehicles, together with each other CDO managed from time to time by HSA, collectively, the “HSA CDOs”), the management rights in respect of which were acquired from StoneCastle Investment Management, LLC in August 2020. HSA has entered into an investment management agreement, collateral management agreement and/or collateral servicing

agreement with each of the HSA CDOs that, together with any applicable indentures, sets forth the manner in which each HSA CDO is to be managed, including types of eligible collateral, investment objectives and risk criteria. HSA is responsible for the selection of any securities to be acquired and held by each of the HSA CDOs as collateral. Certain clients of Hildene, including, but not limited to, HOF, HOF II, HIH, HCM 2021-1, TruPS Co-Invest Fund, the Bryant Park Credit Funds, Orchard Park Credit Fund, and certain separately managed accounts, invest in one or more of the HSA CDOs, and will likely invest in future warehouses or CDOs managed by HSA. See items 5 and 6 for additional information regarding fees in connection with HSA sponsored clients. Wrap Fee Programs Hildene does not offer or participate in any wrap fee programs. Client Assets Under Management As of December 31, 2025, net client assets managed by Hildene on a discretionary basis were approximately $18,342,600,000, including (i) approximately $8,490,629,000 of private fund and separately managed account assets managed by HCM; (ii) approximately $7,970,628,000 aggregate par notional value of collateralized debt obligations managed by HCMC; and (iii) approximately $1,872,138,000 aggregate par notional value (or fair value, if available) of collateralized debt obligations (“Sponsored CDO AUM”) managed by HSA. To avoid double-counting of client assets under management, Sponsored CDO AUM excludes the fair market value of securities issued by HSA-sponsored CDOs that are retained by other Hildene clients. As of December 31, 2025, Hildene managed approximately $9,205,000 client assets on a non-discretionary basis.

Management fees are typically non-refundable once paid, though Hildene may negotiate with a client to refund a pro rata portion of management fees paid in advance in respect of certain separately managed accounts in the event such account is terminated during the applicable fee period. As discussed in Item 6, HCM also typically receives an incentive fee or allocation based on the performance of each account for which it provides investment management services, subject to a high-water mark or preferred return, including to certain clients that do not pay a management fee. HCMC receives base collateral management fees equal to between 0.03% to 0.25% per annum of the collateral balance of each CDO it manages. However, some portions of HCMC’s fees may be payable only after certain levels of payments have been made to the holders of securities issued by the CDO. In addition, HCMC may receive a subordinated collateral management fee of between 0.10% and 0.20% per annum of the collateral balance of the CDO, including any previously accrued but unpaid subordinated collateral management fees, and may also receive performance fees as discussed in Item 6 below. All fees attributable to the HCMC CDOs are paid quarterly (or, for some Trapeza CDOs, biannually) to HCMC by an independent trustee for the CDO in accordance with the terms of the applicable indenture. Management fees attributable to the HCMC CDOs are calculated by the trustee and confirmed by HCMC. HCMC does not require the CDOs to pay fees in advance. Prior to March 19, 2026, HSA waived all base or subordinated collateral management fees in connection with securitization transactions for which it served as collateral manager or collateral servicer. HSA has since implemented changes to its fee practices and now receives collateral management and/or related fees with respect to certain HSA CDOs to the extent that the investments in such HSA CDOs are not managed by Hildene, as provided in the applicable governing documents. In connection with these changes, investors for which HSA was previously waiving fees, including but not limited to accounts in which Hildene principals, employees, or affiliates have an ownership or economic interest, may receive rebates, offsets, or other reductions of such fees. Beginning March 19, 2026, with respect to the HITR CDOs and HCOMF, HSA receives subordinated collateral management fees equal to 0.30% per annum of the collateral balance of the CDO, including any previously accrued but unpaid subordinated collateral management fees, and may also receive performance fees as discussed in Item 6 below. All fees attributable to the HSA CDOs are paid quarterly to HSA by an independent trustee for the CDO in accordance with the terms of the applicable indenture. Management fees attributable to the HSA CDOs are calculated by the trustee and confirmed by HSA. HSA does not require the CDOs to pay fees in advance.

Neither HCM nor any of its relying advisers or supervised persons accept compensation for the sale of securities or other investment products. Other than management fees and the incentive fees discussed above and in Item 6 below, neither HCM nor its relying advisers receive any additional fees from clients for its services. In addition to management fees and incentive fees, funds and separate accounts managed by HCM and its relying advisers incur certain fees and expenses in connection with the provision of investment advisory services. As provided in a client’s account documents, clients may bear expenses such as administrator fees, custodian/settlement agent fees, insurance, research, organizational expenses, accounting/audit fees, taxes, legal fees and transaction costs. Expenses incurred by a client are generally paid directly by the client, but Hildene may pay the expenses directly and seek reimbursement from the applicable client. Certain costs and expenses may be incurred for the benefit of, or be shared by, multiple clients, including clients which are not eligible to bear such costs and expenses. Such shared expenses generally will be allocated across the applicable clients on a pro rata basis based on relative assets under management or in such other manner as Hildene deems appropriate. Hildene will bear the portion of such shared costs and expenses otherwise allocable to clients who benefit from, but are not eligible to pay, such shared costs and expenses. From time to time, entities affiliated with HCM (each, an “Affiliated Entity”) may provide services (“Affiliate Services”) to, and in turn, receive compensation for such Affiliate Services from, an HCM client. In addition, from time to time, HCM may provide services to a client or share its personnel and/or facilities in a manner that is outside the scope of its investment management duties (“Shared Services”), and receive compensation for such Shared Services from such client, which compensation shall be in addition to its investment management fee. Affiliate Services and Shared Services may include providing consulting, actuarial, financial and other services to HCM clients and/or its clients’ portfolio companies. For more information, please see “Affiliate and Shared Services” in Item 10 below. Additional information on fees and expenses can be found in the applicable account governing document. See Item 12 Brokerage Practices, for a description of transaction costs borne by clients and client accounts.

Each client paying an incentive fee to HCM must qualify as a “qualified client” under Rule 205-3 promulgated under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Earned incentive payments are deducted from a client’s assets at the end of each year and/or upon each withdrawal of capital by a client, and, in the case of private funds managed by HCM, are typically treated as an allocation by such fund to HCM or its affiliates. HCM may manage its own accounts or the accounts of an affiliate of HCM (an “Affiliated Account”) alongside client accounts on a side-by-side basis. Affiliated Accounts and client accounts may have similar investment objectives, investment guidelines and investment limitations, and certain investment opportunities considered by HCM may be suitable for both clients and Affiliated Accounts. In such circumstances, in accordance with HCM’s trade allocation policy, HCM shall first allocate such opportunities to HCM’s clients for whom allocation would be appropriate, in such amounts as may be appropriate, prior to allocating such opportunities to any Affiliated Accounts. In any circumstance involving the side-by-side management of client accounts and Affiliated Accounts, HCM shall always put client accounts first. HCM has adopted the foregoing policy to ensure the fair and equitable allocation of investment opportunities among clients and Affiliated Accounts. HCM also manages client accounts (including private funds and separately managed accounts) on a sideby-side basis. For more information, please see “Allocation of Trades” in Item 12 below. HCMC charges a performance fee of between .15% and .25% per annum to certain of the Trapeza CDOs and Alesco CDOs it manages, as set forth in the applicable indenture and collateral management agreement. The performance fee is payable when the equity class of securities of the CDO has achieved a specified return on investment. Prior to March 19, 2026, HSA waived all performance fees in connection with securitization transactions for which it served as collateral manager or collateral servicer. HSA has since implemented changes to its fee practices and now receives collateral management and/or related fees with respect to certain HSA CDOs to the extent that the investments in such HSA CDOs are not managed by Hildene, as provided in the applicable governing documents. In connection with these changes, investors for which HSA was previously waiving fees, including but not limited to accounts in which Hildene principals, employees, or affiliates have an ownership or economic interest, may receive rebates, offsets, or other reductions of such fees. In addition, HSA may earn an incentive management fee with respect to the HITR CDOs and HCOMF, as set forth in the applicable indenture and collateral management agreement. The incentive management fee is performance‑based and is payable only to the extent that the equity or subordinated tranche of the

securitization achieves specified return thresholds. HSA does not currently charge any fees in respect of the services it provides to any of the other HSA CDOs. HSA may in the future charge a management fee and/or an incentive fee in respect of such CDOs for which it provides collateral management services.

Prospective investors should refer to the appropriate fund offering documents or separate account advisory contract, as the case may be, for additional qualification requirements for investment. HCMC provides portfolio and collateral management services to the HCMC CDOs. Certain private funds and separate accounts managed by HCM are also investors in the HCMC CDOs managed by HCMC. HSA provides portfolio and collateral management services to the HSA CDOs. Certain private funds and separate accounts managed by HCM are also investors in the HSA CDOs managed by HSA.

HCM uses a bottom-up approach that analyzes investment opportunities from a fundamental and technical perspective, evaluating innate structural value, net asset value, liquidation value and other fundamental and technical factors. Using this approach, HCM purchases instruments and securities that it believes are mispriced because of either their complexity or a technical component in the marketplace. Ultimate value is achieved through a long-term view that focuses on the general realization of value in the underlying assets. HCM believes that performance is best achieved when understanding all the macroeconomic components of the overall market and dissecting microeconomic drivers that define a structure or company. HCM typically gathers information about an investment from a number of sources including, but not limited to, trustee reports, licensed and proprietary software, issuers, customers, vendors, suppliers, competitors, consultants, advisors, dealers and industry executives. Through these channels of communication, HCM is often alerted to relevant news, nuances and information that may enhance the effectiveness of its investment analysis. HCM also gathers information from public filings (10-K's, 10-Q's, 8-K's, 13-G's, etc.), trade and financial publications, publication search engines, yield rankings, valuation screens, corporate action calendars, investment conferences and other available information sources. HCM’s due diligence is founded on an in-depth knowledge of underlying structural nuances. A thorough analysis of the expected result based on financial engineering and an overall understanding of the terminal value and risks of the underlying credits of a specific company are utilized in decision-making. HCMC monitors the portfolio investments of the HCMC CDOs to evaluate their performance. However, because the reinvestment period has ended with respect to each of the HCMC CDOs, HCMC is not actively making new portfolio investments on behalf of the HCMC CDOs. In monitoring portfolio investments with respect to the HCMC CDOs, HCMC analysts review a variety of sources for information including, but not limited to, financial newspapers and magazines; inspections of and meetings with portfolio companies; third party research materials; corporate rating services; company press releases; and corporate regulatory filings. For new issue CDOs, HSA has discretionary authority over each HSA CDO’s assets during the presecuritization warehouse period and is responsible for the selection of any securities to be acquired and held in each of the warehouses. Post-securitization, HSA monitors the portfolio investments of the HSA CDOs to evaluate their performance. However, because the new issue HSA CDOs are comprised of static portfolios, HSA does not make new portfolio investments on behalf of the HSA CDOs after securitization.

For Insurance-Wrapped Vehicles, HSA has discretionary authority over the investment and reinvestment of assets held in an Insurance-Wrapped Vehicle’s premium reserve accounts in connection with certain structured finance transactions. Such discretion is exercised subject to the terms of the applicable transaction documents. In monitoring portfolio investments with respect to the HSA CDOs, HSA analysts review a variety of sources for information including, but not limited to, financial newspapers and magazines; inspections of and meetings with portfolio companies; third party research materials; corporate rating services; company press releases; and corporate regulatory filings. Summary of Material Risks Hildene invests in securities that are complex and may be distressed. Prices of securities react to the business and financial condition of the issuer as well as macro-economic factors. Investing in any security entails risk of loss, particularly when the securities are complex or distressed. Hildene has listed certain risks below; however the list of risks is not comprehensive or complete. Clients are strongly advised to review the risk factors and potential conflicts of interest contained in the relevant offering materials, organizational documents and/or investment management agreements relating to their investments with Hildene. The investment strategies that Hildene employs for its clients entail various risks, including, but not limited to, the following:

General Investment Risk. All investments involve risks, including the risk that the entire amount invested may be lost. There can be no assurance that HCM will be able to obtain the expected financial terms on its targeted investments. In addition, there can be no assurance that HCM will be able to generate returns or that the returns will be commensurate with the risks of investing in the type of companies and transactions that HCM will engage in.

Structured Finance Securities. The investment strategies employed by Hildene involve investing and trading in structured finance products. Investing in structured finance securities entails a variety of unique risks. In addition, the performance of a structured finance security will be affected by a variety of factors, including its priority in the capital structure of the issuer thereof, the availability of any credit enhancement, the level and timing of payments and recoveries on and the characteristics of the underlying receivables, loans or other assets that are being securitized, remoteness of those assets from the originator or transferor, the adequacy of and ability to realize upon any related collateral and the capability of the servicer of the securitized assets.

Distressed Securities. The investment strategies employed by Hildene may involve investing in distressed securities or underperforming or non-performing debt. Distressed debt securities are subject to the significant risk of an issuer’s inability to meet principal and interest payments on the obligations (credit risk) and also may be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). Distressed securities may react to developments affecting market and credit risk to a greater extent than non-distressed securities. In addition, certain types of distressed securities involve bankruptcy risks, including with respect to securities purchased after an issuer emerges from a bankruptcy reorganization. With respect to post-reorganization securities, such securities typically entail a higher degree of risk than investments in securities of companies which

have not undergone a reorganization or restructuring. Moreover, post-reorganization securities can be subject to increased selling or downward pricing pressure after the completion of a bankruptcy reorganization or restructuring. If Hildene’s evaluation of the anticipated outcome of an investment situation should prove incorrect, clients holding such investment could experience a loss.

Financial Institution Risk. Clients are subject to the risk that one of the client’s account’s banks, brokers, hedging counterparties, lenders or other custodians of some or all of the account’s assets (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty (each, a “Distress Event”). Distress Events can be caused by factors including, but not limited to, eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. In the event a Financial Institution experiences a Distress Event, Hildene and/or its accounts may not be able to access deposits, borrowing facilities or other services for an extended period of time or ever. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (“FDIC”), in the case of banks, or the Securities Investor Protection Corporation (“SIPC”), in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. Although in recent events governmental intervention has resulted in additional protections for depositors, there can be no assurance that governmental intervention will be successful or avoid the risk of loss, substantial delays or negative impact on banking or brokerage conditions or markets. A Distress Event may have a potentially adverse effect on the ability of Hildene to manage client accounts and their investments, and on the ability of Hildene and/or its clients to maintain operations, which in each case could result in significant losses and unconsummated investment acquisitions and dispositions. Such losses have the potential to include fees and expenses incurred by a client in the event the client is not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of investors to make capital contributions or otherwise), as well as the inability of a client to acquire or dispose of investments at prices believed to reflect the fair value of such investments. Although Hildene expects to exercise contractual remedies under the agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. Although Hildene seeks to do business with Financial Institutions that it believes are creditworthy and capable of fulfilling their respective obligations to clients, Hildene is under no obligation to use a minimum number of Financial Institutions with respect to any client, or to maintain account balances at or below the relevant insured amounts.

Concentration of Investments. The investment strategies employed by Hildene may be concentrated and may involve investing in a small number of investments. The allocation of a large portion of an account’s capital to one or a small number of investments could increase the risk of investing in the account because of the lack of diversification in its portfolio. The concentration of an account’s portfolio in any one issuer, industry or strategy would subject such account to a greater degree of risk with respect to the failure of one or a few issuers or with respect to economic downturns in relation to such industry. Certain clients accounts are concentrated in CDOs backed by TruPS

issued by small and regional banks and insurance companies. The issuers of these TruPS operate within a sector of the economy which has recently been, and may continue to be, subject to significant stress.

Leverage. Hildene uses leverage in connection with the investment strategies employed for certain clients, including the use of borrowed funds and investments in certain types of options. Hildene may also employ leverage through the use of total return swaps or credit default swaps, or through repurchase transactions. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. To the extent a client purchases securities with borrowed funds, its net assets will tend to increase or decrease at a greater rate than if borrowed funds are not used. The level of interest rates generally, and the rates at which such funds may be borrowed in particular, could affect the performance of a client’s account. If the interest expense on borrowings were to exceed the net return on the portfolio securities purchased with borrowed funds, the use of leverage would result in a lower rate of return than if the applicable account were not leveraged.

Limited Liquidity. The investment strategies employed by Hildene may involve investing in assets that are illiquid or have limited liquidity. At times, Hildene may be unable to realize certain of its illiquid investments, or would only be able to realize such investments at a value determined by Hildene to be a discount to their true value. If an investment is thinly traded or is not traded at all, Hildene could have difficulty unwinding the investment at a desirable price. If invested in illiquid assets, a client’s account might suffer significant losses if forced to unwind an illiquid investment as a result of changing market conditions, margin calls or other factors.

Investments in Undervalued Securities. The investment strategies employed by Hildene may involve investing in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from these investments may not adequately compensate for the business and financial risks assumed. Hildene may make certain speculative investments in securities which Hildene believes to be undervalued, however, there are no assurances that the securities purchased will in fact be undervalued. In addition, Hildene may be required to hold such securities for a substantial period of time before realizing their anticipated value.

Risks Associated with Residential Mortgage Loans. Investments in residential mortgage loans, including mortgages made to borrowers with lower credit scores, are sensitive to economic factors that could affect the ability of borrowers to pay their obligations under mortgage loans. Residential mortgage loans may incur substantial delinquencies and defaults and adversely affect the amount of liquidation proceeds realized in the event of foreclosures and liquidations and may face increased or decreased prepayment activity. Residential mortgage loans may face substantial delinquencies and defaults, which may become the subject of loss mitigation measures, including modifications that reduce the principal balance of the mortgage loans, or may result in partial or total loss on the mortgage loans. Defaults on mortgage loans may occur in large concentrations over a short period of time, which may increase, possibly substantially, the level of applied realized loss amounts, and result in rapid

declines in the performance and value of investments. The values of the related mortgaged properties may have declined since the mortgage loans were originated. The time periods to resolve defaulted mortgage loans generally have in the past been long and the time periods for resolving defaulted mortgage loans in the future may be long, and those periods may be further extended because of borrower bankruptcies, borrower litigation instituted for the purpose of delaying foreclosure or other loss mitigation, court delays due to capacity issues and any federal and state legislative, regulatory and/or administrative actions or investigations, which may be especially true in the case of a mortgage loan made to a borrower that has substantial debts other than the mortgage loan, or in connection with any federal and state legislative, regulatory and/or administrative actions or investigations.

Hedging Transactions. Certain clients utilize financial instruments such as futures and options to seek to hedge against fluctuations in the relative values of their investment portfolio positions and to hedge against other investment assets. Hedging against a decline in the value of the investment portfolio positions does not eliminate fluctuations in the values of the investment portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the investment portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the investment portfolio positions should increase. Moreover, it may not be possible to hedge against a fluctuation at a price sufficient to protect any investment assets from the decline in value of the investment portfolio positions anticipated as a result of such fluctuations. For example, the cost of options is related, in part, to the degree of volatility of the underlying securities. Accordingly, options on highly volatile securities may be more expensive than options on other securities and of limited utility in hedging against fluctuations in those securities.

Model Risk. Hildene’s investment analysis and risk management rely on financial, quantitative, actuarial, and structural models, including models developed internally and by third parties. Models necessarily reflect assumptions, estimates, and historical data, and may not accurately predict future outcomes. Model errors, limitations, incorrect assumptions, or reliance on incomplete or inaccurate data could result in mispricing, inappropriate investment decisions, or losses. Actual results may differ materially from model‑based projections, particularly during periods of market stress or dislocation.

Use of Artificial Intelligence and Machine Learning. Hildene may utilize artificial intelligence (“AI”), including machine learning and generative AI tools, in connection with certain aspects of its investment research, due diligence, portfolio management support, risk management, compliance, and operational processes. AI tools may be used to analyze large datasets, summarize information, identify patterns or anomalies, assist with scenario analysis, or enhance internal efficiency. AI is used as a supplemental tool and does not replace human judgment in investment decision‑making. Hildene’s use of AI is governed by internal policies and procedures designed to ensure compliance with applicable laws and regulations, protect confidential and material non‑public information, and manage the risks associated with AI technology. Hildene personnel must obtain approval prior to using any AI tools for business purposes, and only approved AI tools may be utilized. The use of AI involves certain risks, including the risk of inaccurate, incomplete, or biased outputs; data quality limitations; cybersecurity and information security risks; potential confidentiality breaches; reliance on third‑party technology providers; and evolving regulatory requirements. AI tools may generate outputs that appear authoritative but contain errors, omit relevant information,

or reflect embedded assumptions that may not be appropriate in all circumstances. Hildene periodically reviews the use of AI technologies, provides training regarding acceptable use and associated risks, and maintains records and documentation related to approved AI tools, consistent with its recordkeeping obligations. As AI technology and regulatory guidance continue to evolve, Hildene’s use of AI and related policies may change over time.

Third-Party Service Provider Risk. Hildene and the client accounts it manages rely on third-party service providers, including administrators, trustees, custodians, valuation agents, technology vendors, data providers, and other service providers, to support portfolio management, operations, reporting, and risk management. The failure, disruption, error, cybersecurity incident, insolvency, or termination of a key service provider could impair Hildene’s ability to manage client accounts, calculate valuations, execute transactions, or meet regulatory and reporting obligations, and could result in losses, delays, or operational disruptions for clients. Certain services may be difficult to replace on a timely basis or on commercially reasonable terms.

Business Expansion and Organizational Change Risk. Hildene has experienced, and may continue to experience, growth in assets, strategies, affiliated entities, and business lines. In addition, Hildene may engage in strategic transactions or changes to its ownership or organizational structure. Such growth and change may strain resources, introduce operational complexity, or require enhancements to systems, controls, and personnel. There can be no assurance that Hildene will successfully manage these developments without disruption to its investment, operational, or compliance functions.

Discontinuation of LIBOR. The U.S. dollar London Interbank Offered Rate (“LIBOR”), which is commonly used as a reference rate within various financial contracts (any such rate, a “Reference Rate”), ceased publication after June 30, 2023 (the one-week and two-month tenors of U.S. dollar LIBOR ceased to be published after December 31, 2021). The Alternative Reference Rates Committee (the “ARRC”) convened by the Board of Governors of the Federal Reserve System (“FRB”) recommended certain SOFR term rates as the replacement (in commercial loan agreements) for U.S. Dollar LIBOR. The ARRC’s recommendations are consistent with replacements proposed under the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”), which became effective in March 2022, and the final rule implementing the LIBOR Act adopted by the FRB, which became effective in February 2023. The FRB also recommended certain SOFR-based replacements for derivative transactions. The Secured Overnight Financing Rate (“SOFR”) is a secured, risk-free rate, where LIBOR was an unsecured rate reflecting counterparty risk, and certain of the recommended replacement rates proposed by the ARRC and under the LIBOR Act included a credit spread adjustment to address this difference. However, in new issue transactions (i.e., transactions not transitioning from London interbank offered rates) a market practice developed to absorb the credit spread adjustment as part of the pricing spread over the applicable benchmark rate, as opposed to indicating a credit spread adjustment as a separate item (for example, as an adjustment to a SOFR-based benchmark rate) within the applicable benchmark rate. Investors should expect that investments will be made in SOFR-based contracts, or contracts utilizing different Reference Rates. Considered in their entirety, the impacts of the discontinuation of U.S. Dollar LIBOR on financial markets generally and on the specific investments in SOFR-based contracts may adversely affect performance.

Catastrophe Risks. Clients may be subject to the risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes and other natural

disasters; war, terrorism and other armed conflicts; cyberterrorism; major or prolonged power outages or network interruptions; and public health crises, including infectious disease outbreaks, epidemics and pandemics. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which Hildene clients invest (or has a material negative impact on the operations of Hildene or the client’s service providers), the risks of loss can be substantial and could have a material adverse effect on the client and its investments.

Board Participation. Hildene employees serve as directors of certain portfolio investments of clients and, as such, have duties to persons other than the investing client. Although holding board positions could be important to a client’s investment strategy, these positions can also impair Hildene’s ability to sell the applicable asset due to the duties imposed on board members or the receipt of material nonpublic information in connection with the position. Hildene may be subject to claims it would not otherwise be subject to as an investor, including claims of breach of duty of loyalty, securities claims and other director related claims. Should Hildene or its employees receive compensation for a board position, that compensation will be paid to the relevant clients.

Risks Associated with the Insurance Industry Generally. Certain clients currently have, and may continue to have, significant exposure to fixed annuity products. While increased fixed annuity product sales may contribute favorably to growth, the performance of such products is sensitive to interest rate fluctuations and spreads. Were interest rates to fall, the performance and value of the fixed annuity products would ordinarily be expected to decline. Reinsurance contracts and products issued by insurance companies are subject to mortality, morbidity, and lapse risk, which may cause the value of investments to be less than otherwise expected if less favorable than the rates that were used in pricing an insurance contract.

Reinsurance Transactions. Reinsurance transactions may include financial instruments, the returns on which are linked to mortality risks or other performance-based measures of a portfolio of insurance policies. A reinsurer is dependent on the original underwriting decisions made by the ceding company and therefore is subject to the risk that the ceding company may not have adequately evaluated the risks that are being reinsured, such that the premiums may not adequately compensate for the risks assumed or the losses incurred. In connection with its investment diligence process related to reinsurance transactions, Hildene may rely on models and analysis performed by third parties, including actuaries. Actual loss experience can materially differ from that generated by such models. These models rely on various assumptions, some of which are subjective and some of which vary between the different risk modeling firms. The loss probabilities generated by such models are not predictive of future events or of the magnitude of losses that may occur. Actual frequency of events and their attendant losses could materially differ from those estimated by such models, which could result in significant losses.

Insurance/Reinsurance Industry is Highly Regulated. The insurance industry (including reinsurance) is highly regulated and certain Hildene accounts, through any investment in a reinsurance business, are indirectly subject to significant legal restrictions, which may have a material adverse effect on the reinsurance business, financial condition, results of operation, liquidity, cash flows, and prospects. Failure to obtain or maintain licenses and/or other regulatory approvals as required for the operation of reinsurance investment(s) may have a material adverse effect on the reinsurance business, financial condition, results of operation, liquidity, cash flows and prospects, which, in turn, would negatively impact certain Hildene accounts’ investments.

Investments involving insurance and reinsurance entities are subject to regulatory capital, reserving, liquidity, and rating agency requirements. Changes in assumptions regarding mortality, morbidity, lapse rates, interest rates, or policyholder behavior, as well as changes in regulatory or rating agency frameworks, could adversely affect capital adequacy, liquidity, or profitability and may constrain investment flexibility or require additional capital contributions. Conflicts of Interest Involving Affiliate-Managed CDOs. Various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of HCM, in its role as investment manager of private funds and separate accounts, and HCMC, in its role as collateral manager of CDOs, including the HCMC CDOs. HCM and its affiliates own, or advise private funds and separate accounts that own, equity and/or debt securities issued by CDOs for which HCMC acts as collateral manager. Furthermore, HCMC HoldCo and its subsidiaries are wholly owned direct and indirect subsidiaries of certain HCM clients and HCM principals and employees. HCMC is entitled to fees for its services and such fees will be indirectly borne by clients to the extent the clients invest in HCMC CDOs. HCM and HCMC will endeavor to resolve any conflicts in a manner that HCM and HCMC deem equitable under the facts and circumstances. In addition, various potential and actual conflicts of interest may also arise from the overall advisory, investment and other activities of HCM, in its role as investment manager of private funds and separate accounts, and HSA, in its role as collateral manager or collateral servicer of the HSA CDOs (together with the HCMC CDOs, the “Affiliate-Managed CDOs”). Various clients managed by HCM, including certain private funds and separate accounts, own equity and/or debt securities issued by the HSA CDOs. HCM and HSA will endeavor to resolve any conflicts in a manner that HCM and HSA deem equitable under the facts and circumstances. Such potential and actual conflicts of interest involving Affiliate-Managed CDOs include, but are not limited to, the following:

Material Non-Public Information. In its role as collateral manager or collateral servicer of an AffiliateManaged CDO, a CM Affiliate and personnel working on its behalf (“CM Personnel”) may be exposed to material, non-public information (“MNPI”) relating to one or more Affiliate-Managed CDOs or the assets constituting collateral therein. To address the compliance risk of MNPI, Hildene has implemented procedures to prevent the dispersion of MNPI relating to Affiliate-Managed CDOs to individuals involved in making investment decisions for clients. However, if Hildene determines that these controls are insufficient to prevent such dispersion, the client may be prohibited from trading in certain Affiliate-Managed CDOs or certain of the assets constituting collateral therein during “black out” periods while CM Personnel have access to such MNPI.

Voting and Corporate Actions relating to Affiliate-Managed CDOs and Collateral. In circumstances where votes are required from the securityholders of an Affiliate-Managed CDO (e.g., in connection with the optional redemption of an Affiliate-Managed CDO), a potential conflict of interest may arise between a client, on the one hand, and one or more private funds, separate accounts or other clients or accounts managed by HCM or its CM Affiliates (including proprietary accounts of HCM or its affiliates) (collectively, “Other Hildene Accounts”), on the other hand, if, for example, a client holds securities of an Affiliate-Managed CDO that are of a different class than the class of securities held by Other Hildene Accounts in the same Affiliate-Managed CDO. Additionally, Affiliate-Managed CDOs may hold securities of an issuer in its underlying collateral pool (the “Collateral”) that are of a different class or type than the class or type of securities of the

same issuer held by a client either directly or indirectly through a CDO, including another AffiliateManaged CDO. This would potentially result in the client being senior or junior to an AffiliateManaged CDO in the capital structure of such entity, which could mean that in a workout or other distressed scenario, an Affiliate-Managed CDO might be adverse to the client, and might recover all or part of its investment while the client might not. In such circumstances, to the extent possible, HCM and its CM Affiliates will attempt to vote such securities held by each of their clients in a manner that serves the best interests of such client.

Certain Matters Relating to Collateral. Collateral held by an Affiliate-Managed CDO may be acquired prior to the securitization of such CDO in cross trades from one or more Other Hildene Accounts. A CM Affiliate may also direct an Affiliate-Managed CDO to dispose of Collateral in cross trades between the CDO and one or more Other Hildene Accounts, in accordance with applicable legal and regulatory requirements, and as permitted by the governing documents of the CDO and such Other Hildene Accounts. Additionally, if a client directly owns the same class and type of securities of an issuer that are also held by an Affiliate-Managed CDO as Collateral, HCM or the applicable CM Affiliate may determine it is in the best interest of the client to dispose of such securities at the same time, or at a different time, as the CDO. In such cases, HCM and/or its CM Affiliates may have a conflicting division of loyalties and responsibilities. Under certain circumstances, HCM or a CM Affiliate may determine it is appropriate to avoid such conflicts by selling Collateral at a fair value that has been calculated pursuant to Hildene’s valuation procedures to Other Hildene Accounts or to a third-party. Hildene may engage in cross trades of Collateral at any time that it believes such transaction to be fair to the Affiliate-Managed CDO and to the Other Hildene Accounts involved in such transaction, subject to the governing documents of such CDO and of such Other Hildene Accounts. Additionally, in the event an Affiliate-Managed CDO sells Collateral at an auction, liquidation or redemption sale (each, a “Sale”), HCM or a CM Affiliate may wish to bid on such collateral on behalf of Other Hildene Accounts. If a CM Affiliate is involved in a Sale process in its capacity as collateral manager or collateral servicer, and is provided information regarding bid levels, this may unfairly advantage the Other Hildene Accounts over third parties seeking to acquire the Collateral. Hildene will endeavor to prevent any bid-level information from being exchanged between CM Personnel involved in the Sale process and Hildene’s personnel involved in bidding on Collateral, if such information would potentially advantage the Other Hildene Accounts in the Sale process; provided, however, that nothing shall be deemed to restrict HCM or its CM Affiliates from exercising any rights of first offer or final refusal contained in any Affiliate-Managed CDO’s governing documents with respect to the Sale of Collateral by such Affiliate-Managed CDO.

Investing in Different Levels of the Capital Structure. HCM or its CM Affiliates may from time to time invest a client’s assets in different parts of the capital structure of the same issuer in which Other Hildene Accounts are invested. For example, HCM or its CM Affiliates may invest a client’s assets in equity securities of an issuer in which Other Hildene Accounts provide financing to or hold the debt obligations of. Alternatively, HCM or its CM Affiliates may invest a client’s assets in the subordinated debt obligations of an issuer while other clients invest in more senior debt obligations of such issuer, or vice versa. Various potential and actual conflicts of interest may arise from such circumstances. For example, if any such issuer becomes insolvent or suffers financial distress, decisions about what action should be taken in a troubled situation may need to be made, including, without limitation, (i) whether or not to enforce claims or other remedies, (ii) whether or not to advocate or initiate a restructuring or liquidation inside or outside of bankruptcy, and the terms of any work-out or restructuring, (iii) how to vote on a creditors’ committee or restructuring committee, and (iv) how to exercise shareholders’ voting rights with respect to such issuer.

There may be a conflict between the interests of such client and the Other Hildene Accounts insofar as such issuer may be unable to satisfy the claims of all classes of its creditors and security holders. There may also be a conflict between the interests of such client and the Other Hildene Accounts with respect to negotiating investment terms on behalf of each such entity. Under such circumstances, the interests of such client and such Other Hildene Account will not always be aligned, which will give rise to conflicts of interest, or the appearance of such conflicts of interest. Actions taken for Other Hildene Accounts might therefore be adverse to those taken for the client, or vice versa. HCM and its CM Affiliates will take actions and make decisions on behalf of both the client and any such Other Hildene Accounts, and will attempt to resolve any and all conflicts of interest in a fair and equitable manner and in accordance with any requirements in applicable client governing documents; however in certain circumstances, any such resolutions may adversely affect the client. Such potential and actual conflicts of interest arising from clients holding in different parts of the capital structure of a CDO issuer include, but are not limited to, the following:

Investments in CDO Securities. HCM may invest in CDO debt securities (“CDO Debt”) and/or CDO equity securities (“CDO Equity”), including CDO securities issued by Affiliate-Managed CDOs. In addition, HCM or its CM Affiliates may determine it is in the best interests of Other Hildene Accounts to invest in CDO Debt and/or CDO Equity of the same CDOs, including AffiliateManaged CDOs. The holders of CDO Equity will rank behind all of the creditors, whether secured or unsecured and known or unknown, of the CDO issuer, including, without limitation, the holders of CDO Debt. Consequently, the CDO Equity of the CDO issuers will be subject to the greatest risk of loss, will be the first part of the capital structure of the related CDO issuer to incur losses and will be directly affected by any losses or delays in payment on the related Collateral. CDO Equity, in general, does not bear a stated rate of interest but is entitled to receive residual distributions on each payment date if and to the extent proceeds received during the previous payment period exceed what is needed for the CDO to pay expenses and current interest on its debt, as well as maintain the required level of subordination and certain required ratios of assets-to-liabilities and expected interest proceeds to current interest obligations for each tranche of CDO Debt. Such distributions to the holders of the CDO Equity of excess current proceeds are subordinate to all other obligations of the CDO on each payment date. In addition, upon the maturity or redemption of CDO Debt, any additional Collateral proceeds that remain after full repayment of all CDO liabilities are distributed to the holders of CDO Equity.

Events of Default. If a client were to invest in CDO Debt of a CDO in which one or more Other Hildene Accounts hold CDO Equity, or if Other Hildene Accounts were to invest in CDO Debt of a CDO in which such client holds CDO Equity, the interests of such client and such Other Hildene Accounts may be adverse if an event of default occurs with respect to such CDO. For example, if any Other Hildene Account were to invest in more senior tranches of CDO securities than the client, such Other Hildene Account would have priority over the client in the capital structure of such CDO, and in a distress or workout scenario such Other Hildene Account could recover on its investment while the client might not. If the client holds CDO Equity, the client would not have any creditors’ rights against the CDO issuer and would not have the right to determine the remedies to be exercised under the CDO indenture. Additionally, holders of the most senior CDO Debt, which may include Other Hildene Accounts, may have consent rights in respect of amendments and CDO manager removal rights in connection with certain events. This situation would present numerous other conflicts or the appearance of conflicts, and could result in the client declining to act in furtherance of its economic interests.

Mandatory Redemption of Senior Tranches of CDO Debt. In some cases, cash flows from the Collateral that otherwise would have been paid to the holders of any related CDO Debt and the related CDO Equity will be used to redeem the related CDO senior tranches, potentially including those held by Other Hildene Accounts. This could result in a deferral, reduction or elimination of the interest payments, principal repayments or other payments made to the client.

Optional Redemption of CDO Securities. An optional redemption of CDO Debt or CDO Equity held by Other Hildene Accounts could require the collateral manager or collateral servicer of the related CDO to liquidate Collateral more rapidly than would otherwise be preferable, which could negatively affect the realized value of the items of Collateral sold, and which in turn could adversely impact the holders of any related CDO Debt, and/or the holders of the related CDO Equity.

Collateral Sales. From time to time, HCM and/or its CM Affiliates determines it is in the best interests of the client and/or one or more Other Hildene Accounts to direct and/or to participate in the Sale of Collateral by a CDO, including Affiliate-Managed CDOs. Sales of Collateral may occur as the result of a mandatory or optional redemption of CDO securities or an event of default with respect to the CDO securities, subject in each case to the governing documents of the CDO. From time to time, HCM and/or its CM Affiliates may determine it is in the best interests of the client and/or Other Hildene Accounts to cause a Sale by directing the redemption of CDO securities or the liquidation of a CDO. In addition, a CM Affiliate may be required by the governing documents of an Affiliate-Managed CDO to periodically conduct auctions of Collateral, which may result in an auction sale of such Collateral subject to the requirements of the applicable governing documents.

Application of Sale Proceeds. The proceeds of a Sale by a CDO (“Sale Proceeds”) are distributed to holders of the securities issued by such CDO in accordance with the priority of payments contained in the CDO’s governing documents (the “Priority of Payments”). In accordance with such Priority of Payments, Sale Proceeds may be used by the CDO to pay for its expenses, including collateral management fees, and Sale Proceeds received by an Affiliate-Managed CDO may be directed pursuant to the Priority of Payments to pay collateral management or collateral servicing fees to a CM Affiliate of the Manager. Following a successful Sale of CDO Collateral, after the application of the proceeds from the CDO assets to pay senior classes of CDO Debt and the fees, expenses, and other liabilities payable by the CDO issuer pursuant to the Priority of Payments, there may not be any funds remaining to make distributions to the holders of subordinate CDO Debt and CDO Equity. HCM or a CM Affiliate may bid on behalf of its clients on Collateral offered for Sale by CDOs, including Affiliate-Managed CDOs. If HCM or a CM Affiliate successfully bids for its client on Collateral of a CDO, and if Other Hildene Accounts own securities issued by such CDO, the proceeds paid by the client in exchange for such Collateral may ultimately be directed to such Other Hildene Accounts pursuant to the CDO’s Priority of Payments. Additionally, if HCM or a CM Affiliate successfully bids for its client on Collateral of an Affiliate-Managed CDO, the proceeds paid by the client in exchange for such Collateral may be used to pay collateral management or collateral servicing fees, including previously accrued but unpaid collateral management fees, to a CM Affiliate in accordance with the Priority of Payments.

Risk Retention Compliance. From time to time, Hildene and/or its affiliates, as well as a client, may directly or indirectly own a portion of securities issued in connection with a securitization in order to comply with legal, regulatory or tax requirements, including risk retention. Any securities held

for risk retention compliance purposes (“Risk Retention Securities”) may be required to be retained by its owner for the term of the securitization and may be subject to other restrictions, including restrictions on hedging and financing. In the event Hildene and/or its affiliates, own, directly or indirectly, any Risk Retention Securities alongside a client, any or all of the conflicts of interest set forth herein with respect to Other Hildene Accounts and Affiliate-Managed CDOs may apply in such circumstances. There is no limitation or restriction on CM Affiliates with regard to acting as collateral manager or collateral servicer (or in a similar role) to other CDO issuers or other parties or persons. This and other future activities of HCM and/or its CM Affiliates may give rise to additional conflicts of interest. Investors in private funds or separate accounts managed by HCM and CDOs managed by HCMC or HSA should refer to the offering memoranda, organizational documents and/or investment management or collateral management agreements relating to their investments with Hildene for further description of the risks associated with such investment. Investors should be prepared to bear the risk of loss of some or all of their investment with HCM, HCMC or HSA. Insurance and Reinsurance Conflicts of Interest. Hildene Insurance Accounts’ investments generally will be made on terms determined to be arm’s length market terms (based on terms negotiated with third-party investors or terms that Hildene otherwise determines to be consistent with arm’s length market terms). However, Hildene Insurance Accounts’ investments in debt securities and/or instruments will result in Hildene Insurance Accounts and other Hildene accounts being invested in different levels of an issuer’s capital structure. These situations will give rise to conflicts of interest and potential adverse impacts on Hildene Insurance Accounts and/or such other Hildene accounts, which are described in more detail (including as to the manner in which Hildene will manage these situations) in “Investing in Different Levels of the Capital Structure” above. Principals and employees of HCM indirectly own approximately 51% of the common equity of Hildene Re, and as a result, HCM is, or could be perceived to be, able to exercise significant influence over matters requiring shareholder approval relating to Hildene Re’s business, including approval of significant corporate transactions, appointment of members of Hildene Re’s management, election of directors, approval of the termination of Hildene Re’s IMA and determination of Hildene Re’s corporate policies. Particular Hildene personnel are also directors of certain Hildene Insurance Account clients. HCM has the ability to invest Hildene Re’s assets across other accounts managed by Hildene, and as a result, HCM may grant Hildene Re certain preferential terms, including reduced management fee and performance-based fees (including carried interest) that are lower than those applicable to other Hildene accounts, access to co-investment opportunities and other preferential terms, which, in each case, will not be subject to “most favored nation” treatment by other Hildene accounts. Certain transactions (such as, for example, cross trades or other transactions involving a Hildene account, on the one hand, and a Hildene Insurance Account, on the other hand, or the provision of financing or other transactions between Hildene clients, on the one hand, and a Hildene Insurance Account, on the other hand) present conflicts of interest. There will not necessarily be third parties involved in any such transaction in order to seek to ensure, among other things, that the terms of such participation by Hildene Insurance Accounts will reflect customary or market terms.

From time to time, HCM will be required to effect reinsurance settlement payments between or among different Hildene Insurance Accounts pursuant to reinsurance treaties and/or related documents between such accounts. Such settlement payments could be made in cash or through an asset-in-kind payment. Such reinsurance settlement payments or other transfers that are made in connection with or pursuant to a reinsurance treaty and/or related documents are not considered cross trades by HCM for purposes of the Advisers Act, even if HCM assists in the selection of assets to be so transferred and calculating the price at which such assets are transferred. HCM will transfer such assets using statutory carrying value for purposes of insurance company statutory reporting on the assets held in certain Hildene Insurance Accounts. Because HCM uses valuation policies and procedures for Hildene Insurance Accounts that may differ in certain respects from the policies used for other clients, asset transfer prices and other valuations determined by HCM on behalf of Hildene Insurance Accounts could differ from asset transfer prices and other valuations prepared by HCM in respect of the same assets held by other clients. Mortgage Origination Transactions. Certain private funds and accounts managed by HCM may hold direct or indirect ownership interests in entities engaged in the origination of mortgage loans or other credit assets. From time to time, HCM-managed funds or accounts that do not hold a direct or indirect ownership interest in such entities may purchase mortgage loans or similar assets directly from such originators. In these circumstances, the purchaser may be able to acquire such assets pursuant to rate-lock arrangements and at pricing based on the agreed upon rate sheets, which may differ from prices available in the secondary market and may, in certain market conditions, be more favorable to the purchasing fund or account, including where another Hildene‑managed fund or account holds a direct or indirect ownership interest in the originator. These arrangements present conflicts of interest, as HCM may have an incentive to allocate investment opportunities, structure transactions, or establish commercial terms in a manner that benefits one client, fund, or affiliated entity over another. HCM seeks to manage these conflicts through its fiduciary obligations, internal policies and procedures, and a good faith determination that any such transactions are effected on terms that Hildene believes to be fair and reasonable under the circumstances and consistent with applicable governing documents and regulatory requirements. There can be no assurance, however, that conflicts will be resolved in a manner that is favorable to all clients or investors. Material Conflicts of Interest Relating to Other Investment Advisers. HCM has entered into a strategic relationship with Leucadia Asset Management (“Leucadia”), a division of Jefferies Financial Group Inc., whereby Leucadia: (i) will invest in one or more funds managed by HCM; (ii) serves as a placement agent for the funds; and (iii) has a revenue sharing arrangement with HCM. In connection with its investment in HCM, Leucadia has been granted certain rights, including (a) consent rights, (b) certain reporting, notice and information access rights, (c) periodic consultation meetings with HCM, (d) certain transfer rights, (e) certain “most favored nation” rights and (f) indemnification. Notwithstanding the rights enumerated above, Leucadia does not participate in the day-to-day management of HCM or its clients, or the day-today selection, structuring, management, or disposition of any of its clients’ investments. Various potential and actual conflicts of interest may arise from HCM’s relationship with Leucadia. HCM will endeavor to resolve any conflicts in a manner that HCM deems equitable under the facts and circumstances As described in Item 4, on December 8, 2025, it was announced that Jefferies will acquire a 50% interest in HoldCo. In connection with this transaction, Jefferies will exchange its existing revenue share in HCM's asset-management business, a portion of its interest in a Hildene-managed private fund and $340 million in cash for a 50% interest in HoldCo. Subject to customary closing conditions, including receipt of required regulatory and client approvals, the transaction is expected to close in the second quarter of 2026. Upon closing, the existing Leucadia strategic relationship, including the revenue sharing arrangement described above, will be superseded by the terms of the HoldCo transaction. Jefferies' 50% ownership of HoldCo may

give rise to additional conflicts of interest, including potential conflicts relating to Jefferies' other business activities, its role as a financial intermediary, and its ability to influence matters relating to HoldCo and its subsidiaries, including HCM and HSA. HCM will endeavor to resolve any conflicts arising from its relationship with Leucadia and Jefferies in a manner that HCM deems equitable under the facts and circumstances. Side Letters. In accordance with common industry practice, HCM and/or a client’s General Partner may from time to time enter into side letters or other similar agreements with certain investors (without the approval of any other investors) in connection with their admission to such client. These side letters or other similar agreements may grant investors specific rights, benefits or privileges (including, without limitation, discounts to management fees, performance allocations and/or performance hurdles, more favorable liquidity, reporting or access to information, minimum investment amounts, co-investment opportunities, notices of certain events or other investment terms). These rights, benefits or privileges are not always made available to all investors nor in some cases are they required to be disclosed to other investors.

Hildene Advisors, LLC (“HADV”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of certain feeder funds of HOF and HOF II and TruPS Co-Invest Fund; Hildene Private Credit Fund I GP, LLC (“HPCFGP”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of HPCF and HPCF Rated Fund; Hildene Asset Based Credit Fund II GP, LLC (“HABCGP II”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of HABC II and HABC II Rated Fund, Bryant Park Credit Fund I GP, LLC (“BPCFGP I”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund I, LP; Bryant Park Credit Fund II GP, LLC (“BPCFGP II”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund II, LP; Bryant Park Credit Fund III GP, LLC (“BPCFGP III”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund III, LP; Bryant Park Credit Fund IV GP, LLC (“BPCFGP IV”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund IV, LP; Orchard Park Credit Fund I GP, LLC (“OPCFGP I”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Orchard Park Credit Fund I, LP; and Hildene Trapeza Manager, Inc. (“HTMI”), a Delaware corporation and an affiliate of HCMC I, serves as the manager of certain Trapeza CDOs for which HCMC I serves as collateral manager. Each of HCMC I, HCMC II, HCMC III, Taberna Europe and HSA is currently registered with the SEC as a relying adviser of HCM. None of HADV, HPCFGP, HABCGP II, BPCFGP I, BPCFGP II, BPCFGP III, BPCFGP IV, OPCFGP I or HTMI is registered or licensed in any capacity with any regulatory body, nor do they conduct any activities other than serving as the general partner or manager, as the case may be, of certain private funds and CDOs managed by HCM and HCMC, respectively. In August 2022, HCM created and received regulatory approval for a Cayman Islands-domiciled Class BIII insurance company named Hildene Re SPC, Ltd. HCM, HCMC and HSA do not have any other financial industry affiliations material to its advisory business. HCM, HCMC and HSA do not recommend other investment advisers to clients or receive any compensation from other investment advisers. Certain private funds managed by HCM and certain CDOs managed by HCMC and/or HSA may have common investors. Affiliate and Shared Services From time to time, Affiliated Entities may provide Affiliate Services to, and in turn, receive compensation for such Affiliate Services from, an HCM client. In addition, from time to time, HCM may provide Shared

Services to, and in turn, receive compensation for such Shared Services from, a client, which compensation shall be in addition to its investment management fee. Affiliate Services and Shared Services may include providing consulting, actuarial, financial and other services to HCM clients and/or its clients’ portfolio companies. HCM may face a potential conflict of interest in determining the fees for or costs of such Affiliate Services and/or Shared Services that will be charged to the relevant client. The terms of any agreement entered into in connection with any Affiliate Services or Shared Services, including any fees and expenses paid or received by HCM or its Affiliated Entities, will be determined by HCM in good faith on a case-by-case basis based on what it believes to be reasonable or customary at such time. In making such determination, HCM may seek to obtain benchmarking data regarding rates charged or quoted by third party service providers for similar services, or regarding the costs or expenses that are borne by comparable companies to maintain similar services in-house. In other circumstances, HCM may charge its or its Affiliated Entity’s respective costs for providing such Shared Services or Affiliate Services to the client, including, without limitation, an applicable portion of the compensation paid to its employees providing such services. Any such related compensation will be paid, reimbursed, or otherwise borne by the client, and a portion of the overhead related to such employees may also be allocated to such client. The rate paid for such employees may exceed the applicable market rate. Unless otherwise required by a client’s governing documents, these types of arrangements will not require client, director of advisory committee consent (as applicable) and such rates will not be subject to approval by any of the foregoing. Prior to entering into any Affiliate Services or Shared Services arrangement, HCM will make a good faith determination that such arrangement is in the best interests of the relevant client.

The Code holds individuals to the highest standards of ethical conduct and places upon them a duty to act for the client’s benefit as well as to place the financial interests of HCM’s clients ahead of their own interests at all times. The Code also sets forth trading restrictions and/or prohibitions on certain types of securities for personal accounts, requires mandatory pre-clearance in respect of personal trades conducted in certain types of securities, and mandates reporting of initial holdings information upon employment and periodic transaction reporting thereafter for access persons of Hildene. HCM reviews these reports to ensure compliance by employees with HCM’s policies and procedures regarding personal trading activities. Participation or Interest in Client Transactions HCM and/or its principals and affiliates on occasion own, buy and/or sell securities which HCM recommends to its clients, subject to the personal trading limitations noted above. Such transactions may also include trading in securities in a manner that differs from or is inconsistent with advice given to clients. HCM employees may have a direct or indirect ownership interest in a client, as well as an indirect ownership interest in certain relying advisers from which they are entitled to receive management fees and/or performance-based fees. HCM recognizes that potential conflicts arise from such transactions and has taken reasonable measures to mitigate such conflicts. Additionally, HCM occasionally permits certain investors to participate directly along with investments made by a private fund managed by HCM. If, in such event, HCM later determines that it will sell any such investments for the relevant private fund, clients holding the same position will be contacted to give them an opportunity to sell concurrently with such fund. Certain affiliates of HCM serve as general partner, managing member or investment adviser to pooled investment vehicles which HCM recommends to its clients. In particular, if HCM determines that it is in a client’s best interest, HCM recommends from time-to-time that its clients invest in Hildene- managed private funds as well as securities issued by the HCMC CDOs or HSA CDOs, for which affiliates of HCM serve as the collateral manager, collateral servicer and/or managing member. HCMC receives collateral management fees and may in certain cases receive performance fees from the HCMC CDOs, as described in Items 5 and 6 above. Other than with respect to the HITR CDOs and HCOMF, HSA does not currently charge any fees in respect of the services it provides to any of the HSA CDOs.

From time-to-time, HCM engages in transactions in which it causes one of its clients to purchase securities or other instruments from, or sell securities or other instruments to, other clients managed by HCM and/or its affiliates (“cross trades”). HCM and/or its principals or affiliates also engage in principal transactions with clients (“principal transactions”) from time-to-time, subject to the client’s prior written consent and after full disclosure to the client of HCM and/or its principals’ or affiliates’ interest in the transaction. HCM and/or its affiliates will not take brokerage commissions or otherwise be compensated for effecting these cross trades or principal transactions. If utilized, HCM intends that cross trades and principal transactions will, to the best of HCM’s ability, reflect the fair value of the asset or other instrument being purchased or sold. In determining such fair value, HCM will typically rely on the most recent month-end quotations obtained from market makers, dealers or pricing services for cross transacted assets; provided, however, that if HCM obtains reliable information (e.g., through HCM’s trading activity in an asset) to indicate that the fair value of an asset has changed after the most-recent valuation date but before the execution date of a principal or cross transaction involving the asset, HCM may in its discretion (i) revise the valuation, upwards or downwards as the case may be, to reflect the new pricing information if HCM determines that the most-recent month-end valuation is no longer reflective of the asset’s fair value or (ii) to the extent practicable, obtain one or more third party quotes of the asset as of the transaction date or a recent date thereto. Prior to effecting any cross trade or principal transaction, HCM will make a good faith determination that the transaction is in the best interests of the relevant clients.

In placing portfolio transactions and negotiating commission rates, HCM will seek to obtain the best execution for its clients where possible; provided, however, that many of HCM’s portfolio transactions occur in the OTC marketplace, where HCM may not have the ability to compare or evaluate different broker-dealers in respect of a particular portfolio transaction. In reviewing best execution, HCM may take into account the following factors: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (ii) the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; (iii) the financial strength, integrity and stability of the broker; (iv) the reputation of the broker; (v) the firm’s risk in positioning a block of securities; (vi) efficiency of execution and error resolution; (vii) the quality, comprehensiveness and frequency of available research services considered to be of value; and (viii) the competitiveness of commission rates in comparison with other brokers satisfying HCM’s other selection criteria. HCM is authorized to pay higher prices for the purchase of securities from or accept lower prices for the sale of securities to brokerage firms that provide it with such investment and research information or to pay higher commissions to such firms if HCM determines such prices or commissions are reasonable in relation to the overall services provided. Research services furnished by brokers may include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. HCM is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services required to be performed by HCM, and HCM’s fees charged to clients are not reduced as a consequence of the receipt of such supplemental research information. Research services provided by broker/dealers used by HCM clients may be utilized by HCM or its affiliates (including other investment funds managed by such persons) in connection with their other investment activities. Since commission rates in the United States are negotiable, HCM’s selection of brokers on the basis of considerations which are not limited to applicable commission rates may at times result in HCM’s clients being charged higher transaction costs than they could otherwise obtain. Use of “Soft Dollars” The term “soft dollars” refers to the receipt by an investment manager of products and services provided by brokers, without any cash payment by the investment manager, based on the volume of brokerage commission revenues generated from securities transactions executed through those brokers on behalf of the investment manager’s clients. Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), provides a “safe harbor” to investment managers with respect to potential liability for violating their duty to obtain best execution for a client’s securities transactions in circumstances in which such managers use soft dollars generated by their advised accounts only for purposes of obtaining

investment research and brokerage services (i) that provide lawful and appropriate assistance to the investment manager in the performance of investment decision-making responsibilities and (ii) where the commissions paid are reasonable in relation to the value of the services provided. HCM does not currently, and does not in the future intend to, engage in any soft dollar transactions. In the event that HCM does engage in any soft dollar transactions, it will not engage in any such transactions other than with respect to products and services which fall within the Section 28(e) safe harbor or where such products or services would otherwise be chargeable to its clients pursuant to the relevant fund offering documentation or separate account advisory contract. Client Referrals HCM may direct some of its clients’ brokerage business to brokers who refer prospective investors to HCM. Because such referrals, if any, are likely to benefit HCM but will provide an insignificant (if any) benefit to HCM’s clients, HCM will have a conflict of interest with its clients when allocating such clients’ brokerage business to a broker who has referred investors to HCM. To prevent HCM’s clients’ brokerage commissions from being used to pay investor referral fees, HCM will not allocate its clients’ brokerage business to a referring broker unless HCM determines in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to such clients. Aggregation of Orders HCM will at times determine that certain securities are suitable for acquisition by more than one account, possibly including Affiliated Accounts, and may aggregate purchase or sale orders for client accounts. The aggregation or blocking of transactions typically allows an adviser to execute transactions in a more timely, equitable, and efficient manner and seeks to reduce overall commission charges to accounts. HCM’s policy is to aggregate transactions where possible and when advantageous to the accounts participating in such transactions. When HCM is placing bids for securities in certain OTC markets in which it and its clients invest, it may routinely aggregate orders into a single bid due to timing constraints and other practical considerations. From time to time, HCM participates in auctions or bid solicitations in which HCM bids to acquire securities in its capacity as investment adviser on behalf of its clients. In such instances, HCM will generally place a single bid for securities based upon the aggregate number of securities that HCM seeks to acquire on behalf of all of its clients. HCM will allocate any securities acquired in such auction or pursuant to such bid solicitation among accounts for whom such securities are suitable in accordance with its trade allocation policy described below, with such allocation determined upon acquisition of the relevant securities (rather than at the time of the relevant bid). Any transaction costs arising from an aggregated transaction will be shared on a pro rata basis by participating accounts, based upon the assets allocated to each such account in accordance with HCM’s trade allocation policy. HCM may aggregate transactions for clients and Affiliated Accounts, subject to HCM’s policy to place client account allocations first. Allocation of Trades When HCM aggregates orders, HCM will seek to allocate investments among clients, including Affiliated Accounts, on a fair and equitable basis over time based on the following factors: (i) diversity of the accounts’

investment objectives; (ii) differences in the accounts’ investment guidelines and investment restrictions; (iii) differences in the accounts’ risk tolerances and return targets; (iv) differences in the accounts’ existing portfolio holdings and related balancing and diversification concerns; (v) differences in the accounts’ relative sizes; (vi) differences in the accounts’ available investment resources (including the timing of capital contributions and withdrawals) and side pocket constraints; (vii) differences in the accounts’ liquidity requirements; (viii) differences in the accounts’ investment time horizons; (ix) tax considerations; and (x) such other factors as HCM may determine to be relevant at the time of allocation. In addition, HCM may take into account settlement costs in making allocation determinations. For example, if the amount of a security that would be allocated to a particular account would be small in view of the factors described above, and if HCM determines in its discretion that the settlement costs associated with making such allocation would outweigh the benefits of such allocation due to the small amount of securities proposed to be allocated, HCM may elect not to make an allocation to such account. Allocations may be made among accounts in a manner that is not pari passu if such allocation is determined to be reasonable by HCM in accordance with the factors described above. Allocations based on these factors will result in differences in invested positions and securities held among clients, and consequently in performance. HCM shall endeavor to afford each account fair and equitable treatment in allocating trades among accounts, provided that allocations shall first be made to HCM’s clients for whom allocation would be appropriate in light of the factors described above, in such amounts as may be appropriate in accordance with such factors, prior to making any allocation to any Affiliated Accounts. To the extent relevant, HCMC and HSA adhere to the foregoing brokerage practices in connection with their respective management of the HCMC CDOs and HSA CDOs.

More frequent reporting may be provided as requested by a client or investor. Investors in HCM-managed private funds and separately managed accounts receive monthly or quarterly account statements from the accounts’ administrator or custodian. Audited financial statements are typically provided to investors in private funds managed by HCM on an annual basis. Investments held by CDOs or CDO warehouses are periodically reviewed by investment professionals of HCMC and/or HSA, as applicable. This review primarily focuses on an analysis of each investment’s financial performance, a review of each investment’s capital structure and a review of each investment’s industry prospects. Individual CDO deal metrics are also periodically reviewed. Investors in CDOs receive monthly or quarterly reports from the account’s trustee, which are reviewed for accuracy by CM Personnel.

Neither HCMC nor HSA receives any economic benefits from any person not a client of HCMC or HSA, as the case may be, in exchange for providing advisory services.

Investors are urged to carefully review such statements. Additionally, the private funds undergo an audit on an annual basis by an independent public accountant that is both registered with and subject to regular inspection by the Public Company Accounting Oversight Board. In respect of such private funds, HCM provides audited financial statements of each fund to the investors in the fund within 120 days of the end of the fund’s fiscal year. Investors are urged to carefully review such audited financial statements. Neither HCMC nor HSA currently maintain custody of any client’s funds or securities.

HSA’s discretion may be limited pursuant to the terms and conditions of the applicable advisory relationship, provided that the restrictions are essentially consistent with HSA’s investment process. HSA has discretionary authority, pursuant to the applicable transaction documents, over the investment and reinvestment of certain assets held in an Insurance-Wrapped Vehicle’s premium reserve accounts in connection with certain structured finance transactions for which HSA serves as collateral servicer. Such discretion is exercised subject to the terms of the governing documents, including applicable investment guidelines, eligibility criteria, and other contractual limitations. The applicable indentures for CDOs managed by HCMC and HSA, including the HCMC CDOs and the new issue HSA CDOs, place significant restrictions on HCMC and HSA’s ability to buy and sell collateral debt securities on behalf of the CDOs once warehouse operations have ceased and a securitization transaction has occurred (and, in the case of HCOMF, the reinvestment period has ended). These indentures generally restrict HCMC and HSA during such periods from selling collateral debt securities on behalf of a CDO unless such securities have experienced specified credit deterioration, ratings downgrades, or events of default.

HCM may determine to abstain from voting a proxy or a specific proxy item when it concludes that the potential benefit of voting is outweighed by the cost or when it is not in the client’s best interest to vote. In many instances, the disparate interests of HCM’s clients may make it difficult for HCM to determine a manner in which to vote and, in those circumstances, HCM may abstain from voting. However, if HCM does vote, HCM shall vote in a manner it believes to be consistent with the interests of its clients and shall not subordinate client interests to its own, or subordinate one client’s interest to another client’s. HCMC and HSA’s CDO investments are primarily comprised of various tranches of debt securities. Generally, the holders of these investments are not entitled to vote on corporate matters, however, to the extent relevant, HCMC and HSA will adhere to the foregoing voting practices in connection with its management of CDOs. In furtherance of Hildene’s goal to vote proxies in the best interests of clients, Hildene follows procedures designed to identify and address material conflicts that may arise between Hildene’s interests and those of its clients before voting proxies on behalf of such clients. In the event a material conflict of interest is identified, certain methods may be used to resolve the conflict, including (i) disclosing the conflict to the client and obtaining its consent before voting; (ii) suggesting to the client that it engage another party to vote the proxy on its behalf; or (iii) such other method as Hildene deems appropriate under the circumstances, given the nature of the conflict. Clients may obtain a copy of Hildene’s proxy voting policies and procedures upon request to the email address on the cover of this brochure. Hildene maintains records of each proxy form or corporate action as voted for its clients.