Standard Investments LLC: investment adviser

The Firm provides discretionary investment advisory services to pooled investment vehicles (each referred to herein as a “Discretionary Fund” and collectively as the “Discretionary Funds”) that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act” and such exempt vehicles, “private funds”). The Discretionary Funds are described in Item 7 below. As the investment adviser of the Discretionary Funds, the Firm identifies opportunities for acquisition, management, monitoring, and disposition of investments of the Discretionary Funds. Investment advice is provided directly to the Discretionary Funds and not to their underlying investors. Investment advice is not subject to the discretion and control of the underlying investors of the Discretionary Funds. Investment advice is subject to the discretion and control of the respective general partners or managing members (referred to herein for simplicity as the “General Partners”) of the Discretionary Funds. Each General Partner is wholly controlled by the Principals and directly or indirectly owned by the Principals individually or by trusts for the benefit of their families. The Firm does not participate in wrap fee programs. Services are provided to the Discretionary Funds, and directly or indirectly to the SPVs (as defined in Item 7 below), in accordance with the Firm’s advisory agreements (each, an “Advisory Agreement” and collectively, the “Advisory Agreements”) and/or the governing documents of the applicable Discretionary Fund (e.g., limited partnership agreements or limited liability company agreements) (each, a “Governing Document”, and collectively the “Governing Documents”). Investment restrictions, if any, for the Discretionary Funds are generally established in the Governing Documents. All purchases, sales, or trading activities of the Discretionary Funds are undertaken by the Firm pursuant to a grant of discretionary authority. The General Partners may, from time to time and in their sole discretion, modify or waive certain terms applicable to one or more Discretionary Fund investors under the Governing Documents including, but not limited to, fee terms, withdrawal terms, and notice requirements.

As the Manager of Winter Properties LLC (“WP LLC”), the Firm provides certain management services to WP LLC for no direct remuneration. WP LLC predominantly holds real property interests and is not a “private fund” or “securities portfolio” for purposes of Form ADV. Non-Discretionary Advice The Firm provides non-discretionary investment advice to private funds and separately managed accounts (“SMAs”) including an SMA that is a charitable organization. Such non-discretionary private fund clients, and SMAs are collectively referred to in this brochure as “Non-Discretionary Clients”). The services provided to the Non-Discretionary Clients include providing research, trade execution, and other post order/trade services. The Firm also provides occasional investment recommendations to one client (the “Advisory Client Relationship”). The Discretionary Funds, together with the Non-Discretionary Clients, the Advisory Client Relationship and WP LLC, are collectively referred to herein as the “Clients”, unless the context dictates otherwise. Assets Under Management As of December 31, 2025, the Firm manages a total of approximately $4,950,162,270 of assets on a discretionary basis and a total of approximately $270,924,500 of assets on a non-discretionary basis.1

Management Fees are paid quarterly in advance and charged and deducted from investors’ capital accounts at an annual percentage rate of such capital accounts, exclusive of any incentive allocation, in accordance with the corresponding Discretionary Fund’s Governing Documents.

1 These totals do not include certain Clients for whom the Firm does not provide continuous supervision and management, nor

does it include managed Client portfolios which are not “securities portfolios” for purposes of Form ADV.

Where the Firm manages both a private fund (a “Parent Fund”) and its subsidiary (a “Sub-Fund”), if such Sub-Fund pays a Management Fee to the Firm, it is calculated based on the assets of the Sub-Fund and is separate from the Management Fee payable to the Firm by the Parent Fund. In such circumstances, the Firm will not receive a Management Fee from the Parent Fund in respect of its interest in the Sub-Fund. The Firm has entered into, and may from time to time in the future enter into, letter agreements or other similar agreements (collectively, “Side Letters”) with one or more investors which provide such investors with additional and/or different rights (including, without limitation, with respect to Management Fees) than are otherwise provided in the Governing Documents of the Discretionary Funds. The Firm has reduced or waived, and may in the future, in its sole discretion, reduce or waive, the Management Fee with respect to any investor, including but not limited to: (i) employees of the Firm; (ii) the General Partners; (iii) the Principals; (iv) certain high net-worth individuals; and (v) certain family members that are related to one or both of the Principals by birth or marriage (“Family Entities”), including trusts, estate vehicles, or other entities formed by or for the benefit of such persons. If an Advisory Agreement is terminated before the end of a billing period (i.e., a quarter), the Firm refunds a pro rata portion of the pre-paid Management Fee for the quarter. The Firm uses an estimated asset value to calculate the Management Fees. To prevent potential overcharges, the Firm takes a percentage discount when calculating the Management Fees. Once the asset value is finalized, the remaining balance of the Management Fee is paid to the Firm. In the event an estimate of asset value used in calculating a Management Fee results in an overcharge to a Discretionary Fund, the overcharged amount will be either (i) reimbursed to the Discretionary Fund or (ii) offset against any outstanding receivable the Firm has from the Discretionary Fund. Certain Discretionary Clients, the Non-Discretionary Clients, and the Advisory Client Relationship do not pay a Management Fee. Other Fees and Expenses With respect to the Discretionary Funds, the Firm will pay out of Management Fees certain overhead expenses in connection with performing investment management services under the Advisory Agreements (including, without limitation, rent, utilities, supplies, secretarial expenses, stationery, charges for furniture, fixtures and equipment, employee benefits including insurance, payroll taxes, and compensation of all personnel). The Discretionary Funds will generally bear all other expenses relating to their operations, as set forth in greater detail in the applicable Governing Documents. Such expenses generally include, among other things: (i) legal, accounting, bookkeeping, tax compliance, auditing, investment-related consulting and other professional expenses; (ii) administration fees; (iii) third-party and out-of-pocket research and market data expenses (including associated travel expenses, regardless of whether the investments are consummated); (iv) interest and fees on loans and other indebtedness; (v) bank service, custodial and similar fees; (vi) expenses related to the purchase, monitoring, sale, settlement, custody or transfer of assets; (vii) fees and expenses relating to systems, software, and portfolio metrics and performance reporting used in connection with the operation of the Discretionary Funds and their investment-related activities; (viii) entity-level taxes; (ix) fees and expenses relating to the offer

and sale of interests in private fund Clients; and (x) fees and expenses relating to disaster recovery services. The Multi-Manager Portfolios (as defined in Item 7 below) pay other fees and expenses similar to those paid by the Discretionary Funds, as described immediately above and as set forth in precise detail in their respective Governing Documents. In addition, the Multi-Manager Portfolios invest in Underlying Funds (as defined below in Item 7) whose managers typically charge: (i) an assetbased fee (that generally ranges from 0% to 2% annually) and (ii) an incentive allocation (that generally ranges from 10% to 20% of net capital appreciation of the investment for the year). The fee rates vary for each such Underlying Fund and in some cases higher rates may apply. As stated previously, the Firm, as the Manager of WP LLC, provides certain management services for no direct remuneration. However, WP LLC will pay to the Firm and/or Standard Management Services LLC, a company controlled by the Principals (“Standard Services”), pursuant to services agreements, certain expenses, costs, and fees, including fractional salary and rent allocations, (collectively, “Reimbursable Expenses”) for non-investment management services including business development; building management; strategic planning; risk management; tax planning, consultation, and advice; corporate finance, financial planning, and fiduciary services; accounting services; legal services; miscellaneous office expenses; information technology; and general management services (collectively, “Operating Services”). The Non-Discretionary Clients will also pay (a) Standard Services for Reimbursable Expenses incurred as a result of Standard Services providing the Operating Services and (b) the Firm for Reimbursable Expenses incurred as a result of the Firm providing certain non-discretionary investment advisory services. Pursuant to various services agreements among Standard Services, a certain Associated Organization (as defined in Item 10 below) and the Firm, the Firm and/or Standard Services will pay for and receive from the Associated Organization, and/or the Firm and/or Standard Services will be paid by and provide to the Associated Organization, Reimbursable Expenses relating to the Operating Services, office space and amenities, technology infrastructure and consultants, and administrative matters. Certain expenses that would otherwise be payable by the Firm may be reduced through the use of “soft” or commission dollars, as discussed in Item 12 below. Please see Item 12 below for a discussion of the Firm’s brokerage practices. The Firm and its supervised persons do not accept compensation or commissions for the sale of securities or other investment products. To the extent that the Firm accrues airline miles or similar benefits in connection with Client-related travel, such benefits would generally be retained by the Firm and would not be credited to a Client. Investments such as mutual funds and exchange-traded funds bear their own management fees and other fees as described in the applicable prospectus. When the Discretionary Funds invest in mutual funds or exchange-traded funds, the Discretionary Funds therefore generally incur two layers of fees: (1) management fees charged by the Firm and other fees directly incurred by the Discretionary Funds, and (2) management fees and other fees assessed by the mutual funds and exchange-traded funds.

If a Client, Associated Organization, and/or the Firm bears responsibility for all or part of a particular expense, the Firm will allocate the expense among all responsible entities in its discretion in a fair and equitable manner, and pursuant to the Firm’s policy.

There are differences in the performance-based fee structure for each Client, which results in potential conflicts of interest that could incentivize the Firm to favor Clients with the most lucrative performance fee structure (e.g., by allocating what are perceived to be the best investment opportunities to the Client(s) with the most lucrative performance fee structure). Generally, and except as may be otherwise set forth in the Governing Documents of such Clients, this conflict is mitigated by the distinct investment strategies of these Clients. Finally, the fact that the Firm or a General Partner receives performance-based fees creates an incentive for the Firm to make investments on behalf of the Clients who are charged performancebased fees that are riskier or more speculative than would be the case in the absence of such compensation. Performance-based compensation earned could also be based in part on unrealized gains that investors in such Discretionary Funds may never realize. The General Partners have reduced or waived, or may in the future in their sole discretion reduce or waive, the performance-based compensation with respect to any investor in a Discretionary Fund.

Interests in the Discretionary Funds are offered only to prospective investors who satisfy the applicable eligibility and suitability requirements for either private placement transactions within the United States or offshore transactions. Each United States investor who participates in one of the Discretionary Funds is required to meet certain suitability and financial qualifications, such as qualifying as an “accredited investor” within the meaning of Rule 501 of Regulation D under the Securities Act and/or a “qualified purchaser” as defined in the 1940 Act. The Firm does not have a minimum size for a Discretionary Fund, but minimum total investment commitments may be established in the future. The Firm also provides (i) non-discretionary investment advice to each of the Non-Discretionary Clients and (ii) occasional investment recommendations to the Advisory Client Relationship. The ultimate beneficial owners or beneficiaries of the Non-Discretionary Clients and the Advisory Client Relationship include individuals, charitable organizations and trusts. The Clients As of the date of this Brochure, the Discretionary Funds include the following vehicles and strategies: Standard Legacy Fund LP (“Standard Legacy Fund”) is an opportunistic investment fund with the flexibility to establish concentrated and less-liquid positions. Standard Legacy Fund may invest across a variety of asset classes, including, but not limited to, U.S. and foreign equity and credit securities. Standard CS Holdings LLC (“Standard CS”) is an opportunistic investment vehicle that typically invests in specialized, less liquid positions. Standard CS may invest across a variety of asset classes, including, but not limited to, U.S. and foreign equity securities. Standard Latitude Master (defined below) is a member of Standard CS. Standard CS has a limited number of co-investors in addition to Standard Latitude Master. Standard Latitude Master Fund Ltd. (“Standard Latitude Master”) is a long-biased investment fund that typically takes long-term, concentrated, strategic positions in public equities. Standard Latitude Master is managed on a tax aware basis and seeks to optimize for long-term capital gains. Standard Latitude Master invests across a variety of instruments, including, but not limited to, U.S. and foreign equity and credit securities, currencies, rates, and derivatives. Standard Latitude Master consists of (a) a “main book,” which includes, among other things, certain cash holdings and liquid public equity investments, and (b) specialized investments through subsidiary special purpose co-investment vehicles, which contain allocations to less liquid assets and certain pooled investment funds including the following (the “SPVs”): •

Standard Advisers Fund LP (“Standard Advisers”) is an SPV fund-of-funds portfolio that invests across an array of underlying alternative investment strategies with both new and established managers; and

•

Standard QOZ Fund LP (“Standard QOZ”) is an SPV that invests substantially all investable capital, directly or through subsidiaries, in “qualified opportunity zone property”. Standard QOZ has co-investors in addition to its beneficial ownership by Standard Latitude Master.

•

Standard Ventures Fund LP (“Standard Ventures”) is an SPV that provides investors with the opportunity to realize long-term capital appreciation from venture capital investments.

The Firm treats the assets of each of the SPVs as assets of Standard Latitude Master. The Class A Interests of Standard Latitude Fund LP (“Standard Latitude Feeder” and, together with Standard Latitude Master, “Standard Latitude”), a parent fund of Standard Latitude Master, reflect the net performance of the “main book” of Standard Latitude Master. The SPVs are elective investments the performance of which is reflected on a standalone basis in other classes of interests of Standard Latitude Feeder. Standard Latitude Feeder invests substantially all of its capital and conducts its investment program and trading activities through Standard Latitude Master. Standard Latitude Feeder also is the sole limited partner of Standard Legacy Fund. As such, Standard Legacy Fund is also a master fund for Standard Latitude Feeder. The performance of Standard Legacy Fund is reflected on a standalone basis in a separately-designated class of interest in Standard Latitude Feeder. The Firm also advises certain Discretionary Clients (the “SWRE Entities”) which are real estate investment vehicles that make debt and/or preferred equity investments in real estate capitalizations throughout the United States, which may include residential, industrial/logistics and mixed-use properties. Standard Latitude Master invests alongside certain SWRE Entities. One SWRE Entity is registered (a) in the Cayman Islands with the Cayman Islands Monetary Authority and (b) in the United Arab Emirates with the Capital Markets Authority. The Non-Discretionary Clients and Standard Advisers (collectively, the “Multi-Manager Portfolios”) primarily invest in hedge funds, separately managed accounts, mutual funds, and private equity funds managed by third-party advisers (for convenience, collectively referred to as “Underlying Funds”). The SMAs generally make securities investments either directly or through Underlying Funds. Two SMAs, Dalbergia Investments LLC (“Dalbergia”) and Standard Industries Technologies LLC (“Standard Tech”), make investments that are strategic to an Associated Organization (as defined in Item 10 below) and its affiliated operating businesses. The Advisory Client Relationship primarily invests in index funds and publicly traded securities. Investment decisions for the Non-Discretionary Clients (other than the Advisory Client Relationship) are at the discretion of an individual related to one of the Principals who is supported by the Chief Accounting Officer (“CAO”). WP LLC is a privately held, vertically integrated real estate investment business engaged in the acquisition, sale, financing, development, management, ownership and operation of real estate assets. The Firm may in the future organize other investment funds, including feeder funds for the Discretionary Funds or parallel funds for the Principals or employees of the Firm, or manage

investment funds or separately managed accounts that may either co-invest with the Discretionary Funds or follow an investment program similar to or different from the Discretionary Funds’ programs. The Firm may in the future establish additional special purpose vehicles or subsidiaries, and the Firm or the Discretionary Funds may in the future invest in or act through such additional special purpose vehicles or subsidiaries.

Standard Legacy Fund Standard Legacy Fund is an opportunistic investment fund with the flexibility to establish concentrated and less-liquid positions. Standard Legacy Fund may invest across a variety of asset classes, including, but not limited to, U.S. and foreign equity and credit securities. The portfolio is constructed based on bottom-up research informed by top-down views of the macroeconomic environment. Standard CS Standard CS is an opportunistic investment vehicle that typically invests in specialized, less liquid positions. Standard CS may invest across a variety of asset classes, including, but not limited to, U.S. and foreign equity securities. The portfolio is constructed based on asset-specific research informed by top-down views of the macroeconomic environment and competitive landscape. Standard Latitude Standard Latitude is a long-biased investment fund that typically takes long-term, concentrated, strategic positions in public equities. Standard Latitude is managed on a tax aware basis and seeks to optimize for long-term capital gains. Standard Latitude may invest across a variety of instruments, including, but not limited to, U.S. and foreign equity and credit securities. The Principals manage the portfolio with the support of a team of investment professionals. The portfolio is constructed based on bottom-up research informed by top-down views of the macroeconomic environment. Standard Latitude has the flexibility to make certain investments through SPVs. Standard Advisers is an SPV which invests in Underlying Funds. Standard QOZ is an SPV which invests in qualified opportunity zone properties. Standard Ventures invests principally in seed and early stage industrial companies.

SWRE Entities The SWRE Entities are real estate investment vehicles that make investments in real estate capitalizations throughout the United States, which may include residential, industrial/logistics and mixed-use properties. They invest solely in debt and/or preferred equity real estate opportunities, and the investment process for each opportunity, in which the Firm believes there is a high likelihood of capital repayment, focuses on comprehensive diligence of the market, the real estate and the sponsorship. The portfolio is constructed based on comprehensive diligence and underwriting, while adhering to specified investment parameters as set forth in the Governing Documents. WP LLC WP LLC is a privately held, vertically integrated real estate investment business engaged in the acquisition, sale, financing, development, management, ownership and operation of real estate assets. WP LLC’s investment process focuses on real estate opportunities in which the Firm believes there is a high likelihood of capital appreciation or the opportunity for platform expansion. The Principals serve as Principals and co-CEOs of WP LLC. Multi-Manager Portfolios The Multi-Manager Portfolios primarily invest in Underlying Funds. The Firm is responsible for evaluating potential underlying third-party investment managers, their private pooled investment vehicles, and separately managed accounts offered by such managers prior to making an investment and periodically thereafter according to the procedures established by the Firm. The Firm’s due diligence process is similarly detailed, though it focuses more on the quality of the third-party advisers and the differentiated aspects of their processes. The Firm provides nondiscretionary investment advice to the Non-Discretionary Clients and occasional investment recommendations to the Advisory Client Relationship. After performing due diligence on a possible investment for the Multi-Manager Portfolios, the Firm will review the offering and determine if the offering would be beneficial and is within the investment guidelines for each Multi-Manager Portfolio. Consideration is also given to the fact that certain Non-Discretionary Clients, through their investments in Standard Latitude Feeder, have exposure to investments made by Standard Advisers. The process of recommending investments for any one of the MultiManager Portfolios is subjective in so much as each Client has a unique risk/reward threshold and liquidity profile, as determined by the ultimate investment decision maker. Given those differences, very few, if any, potential investments would be relevant for all Clients. When there is an investment that might be deemed suitable for multiple Multi-Manager Portfolios, given their respective investment mandates, the CAO will specifically discuss that investment with the relevant decision makers. All assets in the SMAs are solely owned by the respective account holders, who have the right to accept or reject the Firm’s investment recommendations.

Separately Managed Accounts and Advisory Client Relationship The Firm provides non-discretionary investment advice to certain SMAs that primarily invest in single name equities, equity indices, and Underlying Funds. The Principals, in their capacities as the Co-CEOs of each of Dalbergia and Standard Tech, provide final approval for all investments made by Dalbergia and Standard Tech. The investment decisions for all other SMAs are at the discretion of the individual who owns the relevant SMA. Each such SMA account holder is related to one of the Principals and is supported by the CAO. The Firm also makes occasional, nondiscretionary investment recommendations to the Advisory Client Relationship, which relate primarily to index funds and publicly traded securities. The Firm conducts research, provides investment advice and trades securities on a non-discretionary basis on behalf of the SMAs. The SMAs have different investment strategies and timelines than the Discretionary Funds. Therefore, investments suitable for the SMAs will likely not be suitable for the Discretionary Funds. The Firm may place orders for the execution of transactions only upon written direction and/or written approval of the SMA account holder and only with or through such brokers, dealers, or banks the account holder selects. In certain cases when deemed prudent, such as when an SMA account holder is related to one of the Principals, the SMA and its account holder may be required, as a condition to receiving services from the Firm, to refrain from transacting in securities (i) on the Firm’s restricted list or (ii) that are in the Discretionary Funds’ portfolios and reach a specific material beneficial ownership level. Any research costs incurred on behalf of the SMAs are de minimis and are typically absorbed by the Firm. Risks Investing in securities involves a substantial degree of risk of loss. A Client may lose all or a substantial portion of its investments. Investors in the Clients must be prepared to bear the risk of a complete loss of their investments. The risks associated with particular investments include, but are not limited to, the risks described in Appendix A hereto. The Firm may invest in more than one segment of a portfolio company’s capital structure if the opportunity is appropriate relative to risk while monitoring and assessing the variety of scenarios through which a company may emerge from bankruptcy, pursue a liquidation or complete a balance sheet restructuring. The Clients and their investors should recognize the fact that conflicts may arise because portfolio decisions regarding one Client may either harm or benefit the Firm or another Client. For example, when in the best interests of the Discretionary Funds, the Firm will pursue or enforce rights available to creditors with respect to an issuer in which a Discretionary Fund has invested in the debt of such issuer, and those activities may have an adverse effect on the equity holdings of another Discretionary Fund. Each Client will make decisions in its own best interest without regard to the impact on the Firm or the other Client. As a result, prices, availability, liquidity and terms of a Client’s investments may be negatively impacted by the Firm’s activities on behalf of another Client, and transactions for a Client may be impaired or effected at prices or terms that may be less favorable than would otherwise have been the case. With respect to the Discretionary Funds, the Firm has the sole authority to determine how best to deal with conflicts that may arise related to investments in different parts of an issuer’s capital structure. Any actual or potential conflicts are brought to the attention of the Chief Compliance Officer (“CCO”) and/or Operating Committee for appropriate consensus-based resolution.

Force Majeure Portfolio investments may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, etc.). Some force majeure events may adversely affect the ability of a party (including an issuer or asset in which a Client is invested) to perform its obligations until it is able to remedy the force majeure event. These risks could, among other effects, adversely impact the cash flows available with respect to a portfolio investment, cause personal injury or loss of life, damage property, or instigate disruptions of service. In addition, the cost to an issuer of repairing or replacing damaged assets or remediating losses resulting from such force majeure event could be considerable. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally. Additionally, a major governmental intervention into industry, including the nationalization of an industry or the assertion of control over one or more issuers in which a Client is invested, or the imposition of lockdowns or other public health measures in certain scenarios, could result in a loss to Clients. Any of the foregoing may therefore adversely affect the performance of a Client and its investments. Item 9. Disciplinary Information

Finally, the Firm does not recommend or select other investment advisers for the Clients from whom the Firm directly or indirectly receives compensation that could create a material conflict of interest. Related General Partners Affiliates of the Firm serve as the General Partners of the Discretionary Funds. The General Partners (listed in Section 7.A of the Firm’s Form ADV Part 1A) are not separately registered as investment advisers with the SEC. However, all of the General Partners’ investment advisory activities are subject to the Advisers Act and the rules thereunder. In addition, employees and persons acting on behalf of the General Partners are subject to the supervision and control of the Firm (unless otherwise agreed). For a description of material conflicts of interest created by the relationship among the Firm (on the one hand) and the General Partners (on the other hand), please see Item 11 below.

Certain Associated Organizations and Other Relationships The Principals serve as key officers and/or principals of certain other businesses, including but not limited to (a) Standard Services, (b) WP LLC, (c) other entities that may, from time to time, (i) provide the Operating Services and information technology services to the Firm, the Clients, or certain individuals who are or were related to one or both of the Principals by birth or marriage (including trusts, estate vehicles, or other entities formed by or for the benefit of such individuals), several of whom are investors, and/or (ii) share office space with the Firm, and (d) certain affiliates and subsidiaries of the foregoing (collectively, the “Associated Organizations”). The Firm may compensate the Associated Organizations for such services at cost, through hourly fees, or on an annual fixed fee basis. The Clients may be charged for these services. An Associated Organization provides property administration services for certain “qualified opportunity zone” real property. Certain Clients (or subsidiaries thereof) may compensate such Associated Organization for such services through hourly fees or an annual fixed fee. The Associated Organizations do not provide the Firm or the Clients with investment advisory services. If a Client, Associated Organization, and/or the Firm bears responsibility for all or part of a particular expense, the Firm will allocate the expense among all responsible entities in its discretion in a fair and equitable manner.

The Code of Ethics outlines written policies and procedures regarding personal trading by Covered Persons. The personal trading policies and procedures adopted by the Firm restrict personal trading of certain securities and require Covered Persons to seek approval prior to trading in certain securities. The Code of Ethics further requires all COE Persons to comply with applicable U.S. federal securities laws at all times. For purposes of this summary of the Code of Ethics, the terms “employees” and “Access Persons” includes the Principals. This summary of the Code of Ethics is qualified in its entirety by the Code of Ethics of the Firm, which is available to the Clients, prospective clients, and current and prospective investors in the Discretionary Funds, upon request by contacting the Firm at (212) 821-1635 or fundcompliance@standardinvestments.com.

Conflicts of Interest Certain conflicts of interest that may be encountered by a Client include those discussed below, although the discussion below does not necessarily describe all of the conflicts that may be faced by a Client. Other conflicts may be disclosed throughout this brochure and in the Governing Documents of each Client, if any, and these materials should be read in their entirety. The Firm has adopted policies and procedures to address and mitigate conflicts of interest, including those described below. Investments by Clients. If the Firm has multiple open orders to purchase (or sell) an investment for more than one Discretionary Fund, the Firm will endeavor to place combined orders for all such Discretionary Funds. Legacy special situation investments (“SSIs”) in Standard Legacy Fund and the SPVs shall be deemed separate Discretionary Funds solely for purposes of aggregating and allocating orders. The Firm will allocate combined orders (and any associated transaction costs) pro rata based on prior month-end net AUM. If the Firm has multiple open orders to purchase (or sell) an investment for one or more Discretionary Funds and Non-Discretionary Clients, the Firm will endeavor to place combined orders. In the event the Firm places combined orders for one or more Discretionary Funds and Non-Discretionary Clients, the Firm will (i) make all allocation decisions prior to order execution and in accordance with the independent discretion of the Principals and (ii) allocate any associated transaction costs on an ownership position basis. See Item 12 “Aggregation and Allocation of Orders” below for more information regarding the Firm’s policy on aggregating and allocating orders. A Client could be disadvantaged because of activities conducted by the Firm or its affiliates as a result of, among other things: restrictions on trading because the Firm or an affiliate is in possession of confidential or material non-public information; legal restrictions on the combined size of positions which may be taken for all accounts managed by the Firm or its affiliates, thereby limiting the size of the relevant Client’s position; and the difficulty of liquidating an investment for more than one account where the market cannot absorb the sale of the combined positions. Transactions with Affiliates. Section 206 of the Advisers Act regulates principal transactions among an investment adviser and its affiliates, on the one hand, and the clients thereof, on the other hand. Very generally, if an investment adviser or an affiliate thereof proposes to purchase a security from, or sell a security to, a client (what is commonly referred to as a “principal transaction”), the investment adviser or the affiliate must make certain disclosures to the client of the terms of the proposed transaction and obtain the client’s consent to the transaction. The Firm has established certain policies and procedures to comply with the requirements of the Advisers Act as they relate to principal transactions. A cross transaction is a pre-arranged transaction between two different clients both of which are managed by the same adviser. In the event the Clients engage in cross transactions, the Firm will ensure that such transactions are in the best interest of each of the participating Clients and in accordance with the Firm’s policies relating to cross transactions. The Firm will not directly or indirectly receive any commission or other transaction-based compensation for effecting any cross transaction.

Certain employees of the Firm and/or Associated Organizations may from time to time provide Operating Services to the Firm, the Clients, or to certain individuals who are related (or were related) to one or both of the Principals by birth or marriage (including trusts, estate vehicles, or other entities formed by or for the benefit of such individuals) several of whom may be investors. Reimbursable Expenses are allocated to WP LLC (for building management-related Operating Services) and to Non-Discretionary Clients (for family office-related Operating Services). Reimbursable Expenses are primarily comprised of fractional salary allocations without mark-up, fractional rent allocations, and nominal amounts related to miscellaneous office expenses and information technology (at below market rates with no mark-up). The Firm endeavors to conduct market comparisons to ensure that these fractional allocations are reasonable and commensurate with unaffiliated service providers. Discretionary Funds that pay a Management Fee are not allocated Reimbursable Expenses. Standard Legacy Fund has an indirect investment in WP LLC. WP LLC is a privately held, vertically integrated real estate investment management business. The Principals serve as Principals and co-CEOs of WP LLC. WP LLC has certain profit sharing arrangements whereby, based on certain performance hurdles, the Principals, through certain vehicles controlled by the Principals, may receive profit shares and cash distributions. If issued, such profit shares and cash distributions will have a dilutive effect on the allocable value to investors in WP LLC, including Standard Legacy Fund. To avoid any double-charging of fees, the Firm and the General Partner of Standard Legacy Fund have waived the fees with respect to the indirect investment by Standard Legacy Fund in WP LLC. There are other instances when the Principals or the Firm’s investment professionals may hold board of directors or advisory board seats with companies in which the Clients hold positions. Any compensation offered for such services will be received and retained by the relevant Client. Personal Trading. Covered Persons may take action for their personal accounts that may differ from advice given and action taken by the Firm on behalf of the Clients. In addition, Covered Persons may invest in third-party private investment funds that invest in some of the same securities the Firm invests in on behalf of the Clients. Furthermore, from time to time, Covered Persons may have pre-existing investment positions or interests in the same securities recommended to or owned by the Clients. As such, the Firm may purchase or sell for the Discretionary Funds securities of an issuer in which Covered Persons also have a pre-existing position or interest.

In order to help ensure best execution and to oversee other operations of the Firm, the Firm has an Operating Committee. The Operating Committee meets quarterly and is responsible for developing, evaluating and changing, when necessary, the Firm’s order execution practices. The Operating Committee monitors broker-dealers to assess the quality of execution of brokerage transactions effected on behalf of the Firm and the Discretionary Funds based on the Firm’s policies and procedures. Selection of Broker-Dealers The Firm is generally solely responsible for choosing the broker or brokers used for each securities transaction for the Discretionary Funds. In negotiating commission rates and selecting brokerdealers, the Firm will take into account the financial stability and reputation of the particular broker-dealer, the ability to achieve prompt and reliable executions at favorable prices, the operational efficiency with which transactions are effected and the brokerage and research services provided by such broker-dealer, among other factors. Selecting brokers on the basis of considerations which are not limited to applicable commission rates may at times result in higher transaction costs than would otherwise be obtainable. However, the overall cost of doing business with a particular broker is one of the factors considered in selecting the broker-dealer used to execute a particular transaction. Research and Other Soft Dollar Benefits The Firm believes that valuable brokerage and research services can possibly be provided to the Discretionary Funds by brokerage firms effecting transactions for the Discretionary Funds. Accordingly, the Firm does not intend to seek lower brokerage commissions to the extent that doing so might detract from the provision of such brokerage and research services. Brokerage and research services may be either obtained from brokerage firms or paid for by brokerage firms and may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; news, quotation, statistics and pricing services, as well as discussions with research personnel and consultants; software, databases and other technical and telecommunications services utilized in the brokerage execution process and consulting fees in connection with investigating and monitoring potential and existing investments. Research services may include both proprietary research (created or developed by the broker-dealer) and research created or developed by a third party. Research services, whether obtained through commissions arising from a Discretionary Fund’s portfolio transactions or paid for by the Firm and charged to a Discretionary Fund, may be used by the Firm for the benefit of other Discretionary Funds and not strictly the Discretionary Fund that paid for the benefits. With regard to the use of commissions or “soft dollars,” it is the Firm’s intent to stay within the parameters of Section 28(e) of the Securities Exchange Act of 1934, as amended. When the Firm uses brokerage commissions to obtain research or other products or services, the Firm receives a benefit because the Firm does not have to produce or pay for such research, products or services. The Firm may have an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the Discretionary Funds’ interest in receiving the most favorable execution.

Order Routing Credits or Rebates The Firm receives a credit from a third-party service provider for using its electronic order entry system to submit trades for execution using the FIX order routing protocol. The size of the credit depends on the number of brokers with which the Firm has established FIX connections. The Firm can use the credit to acquire other products and services offered through the service provider. The Firm may therefore have an incentive to use this service provider and brokers set up to use the FIX order routing protocol over other available options. This potential conflict would be amplified when the Firm acquires products and services that it would otherwise have to pay to acquire (i.e., expenses that the Discretionary Funds do not pay or could not obtain through soft dollar arrangements as described above). Client or Investor Referrals In selecting or recommending broker-dealers, the Firm does not consider whether the Firm or a General Partner receives client or investor referrals from a broker-dealer or other third party. Directed Brokerage The Firm generally does not have Client-directed brokerage arrangements. Aggregation and Allocation of Orders If the Firm has multiple open orders to purchase (or sell) an investment for more than one Discretionary Fund, the Firm will endeavor to place combined orders (i.e., “bunch”) for all such Discretionary Funds. SSIs and SPVs shall be deemed separate Discretionary Funds solely for purposes of aggregating and allocating orders. In many instances, “bunching” of orders can result in lower commissions, a more favorable net price or more efficient execution than if each Discretionary Fund’s order were placed separately. There may, however, be instances in which order bunching results in a less favorable transaction than a particular Discretionary Fund would have obtained by trading separately. Similarly, when orders are not bunched, there may be circumstances when purchases or sales of portfolio securities for one or more Discretionary Funds will have an adverse effect on other Discretionary Funds. The Firm is not obligated to place all transactions on a “bunched” basis, and in determining whether or not to “bunch” orders the Firm relies on the judgment of certain of its trading personnel as to what course of action is likely to be fair and in the best interests of the relevant accounts on an overall basis. That is, the Firm seeks to avoid putting any Discretionary Fund at an advantage or disadvantage compared to the Firm’s other Discretionary Funds that are buying or selling the same security. Each Discretionary Fund participating in a “bunched” order will participate at the same price as all other participants, and all transaction costs on the order will be allocated to all participating Discretionary Funds pro rata based on prior month-end net AUM. In the event that a Discretionary Fund submits a trade order for a security after a transaction in the same security has already commenced for another Discretionary Fund, all subsequent trades of the security will be allocated among the participating Discretionary Funds pro rata based on prior month-end net AUM. In the event of a partial fill, securities will be allocated pro rata based on prior month-end net AUM.

Non-Discretionary Clients participating in a “bunched” order will participate at the same price as a Discretionary Fund and all transaction costs on the order will be allocated on an ownership position basis. In the event that one or more Discretionary Funds and Non-Discretionary Clients participate in a “bunched” order, each will participate at the same price and all transaction costs on the order will be allocated on an ownership position basis. All trades of the security will be allocated in accordance with the independent discretion of the Principals of the Firm, however, allocation decisions will be made prior to order execution. See Item 11 “Conflicts of Interest” above for more information regarding conflicts of interest related to aggregating or “bunching” orders. There will be circumstances when not all of the Discretionary Funds participate in investment transactions; the level of participation among the Discretionary Funds in parallel investment transactions is not on a pro rata basis; the terms of parallel investment transactions vary among one or more of the Discretionary Funds; one or more of the Discretionary Funds effectively engage in opposite transactions with respect to a particular investment (e.g., one Discretionary Fund acquires a long position in a security while one Discretionary Fund sells or shorts the security); and/or investment transactions among the Discretionary Funds vary in other respects. In such cases, the Firm will seek to allocate trades in a manner using its reasonable business judgment so as to reach the respective investment goals of the Discretionary Funds. Non-parallel and/or nonpro rata investment transactions among the Discretionary Funds will be made at the discretion of the Firm, when (i) deemed appropriate given the differences between the Discretionary Funds involved and/or (ii) deemed appropriate because the target holdings of the particular investment that the Firm has established with respect to the relevant Discretionary Funds differ. Investment and allocation decisions may differ among the Discretionary Funds due to, among other things, investment objectives, investment strategies, investment parameters and restrictions, portfolio management personnel, tax considerations, liquidity considerations, hedging considerations, legal and/or regulatory considerations, asset levels, the timing and size of investor capital contributions and redemptions, cash flow considerations, market conditions, existing exposures to an investee company or security, and other criteria the Firm deems relevant. Since the Multi-Manager Portfolios invest primarily in Underlying Funds, they do not generally invest in the same investment opportunities as the Discretionary Funds. After performing due diligence on a possible investment for the Multi-Manager Portfolios, the Firm will review the offering and determine if the offering would be beneficial and is within the investment guidelines for each Multi-Manager Portfolio. Consideration is also given to the fact that certain NonDiscretionary Clients, through their investments in Standard Latitude Feeder, have exposure to investments made by Standard Advisers. The process of recommending investments for any one of the Multi-Manager Portfolios is subjective in so much as each Client has a unique risk/reward threshold and liquidity profile, as determined by the ultimate investment decision maker. Given those differences, very few, if any, potential investments would be relevant for all Clients. When there is an investment that might be deemed suitable for multiple Multi-Manager Portfolios, given their respective investment mandates, the CAO will specifically discuss that investment with the relevant decision makers.

On a semi-annual basis, the Operating Committee will review and evaluate (i) the suitability of private investments and (ii) the risk assessment findings for third party managers. The Operating Committee will also review proxy voting procedures annually. The Firm’s investment team meets on a more regular basis to discuss specific investment opportunities and decisions. The Operating Committee will also assist the General Partner of one or more SWRE Entities with oversight and supervision of the activities and affairs of such entities and will meet at least annually as required under the Cayman Islands Private Funds Act. The Firm also provides continuous oversight and monitoring services for certain NonDiscretionary Clients and WP LLC. In addition, the CAO provides monitoring and reporting services tailored to the preferences of certain Non-Discretionary Clients. Reporting The Firm provides monthly, quarterly, and/or periodic reports and/or account statements in accordance with the applicable Governing Documents and as may be agreed with particular investors or Clients. The Firm provides for audited financial statements to be delivered to the underlying investors of the Discretionary Funds and WP LLC as described under Item 15 below or as otherwise set forth in the applicable Governing Documents. Account statements for Non-Discretionary Clients and the Advisory Client Relationship are provided directly by their respective qualified custodian(s) as described under Item 15 below or as otherwise set forth in the applicable Governing Documents.

The Firm does not have custody (as defined by the Advisers Act) for the Non-Discretionary Clients or the Advisory Client Relationship, since it does not have the authority to hold, or obtain possession of (directly or indirectly), Client funds or securities. To the extent there is activity, monthly account statements are sent directly to the Non-Discretionary Clients or the Advisory Client Relationship by their respective qualified custodian(s). The Non-Discretionary Clients and the Advisory Client Relationship should carefully review the custodian statements.

However, the Firm reserves the right to abstain on any particular vote or otherwise withhold its vote or consent on any matter if, in the judgment of the Principals, the CCO or the relevant Firm investment professional(s), the costs associated with voting a particular vote outweigh the benefits to the relevant Clients. In the event the Firm receives proxies on behalf of the Non-Discretionary Clients, the relevant Non-Discretionary Client may, at its option, vote in each particular solicitation. Clients that vote their own proxies should receive their proxies or other solicitations directly from their custodians or a transfer agent. If the Firm inadvertently receives proxy voting materials for Clients that vote their own proxies, it will forward such materials to the relevant Clients and instruct the sender to forward such materials directly to the Clients in the future.

From time to time, the Clients may engage unaffiliated investment advisers to manage a portion of Client assets in separately managed accounts (“Managed Account Assets”). Accordingly, the Clients may delegate proxy voting authority, limited to matters arising out of such Managed Account Assets, to such unaffiliated investment advisers. Aside from the Non-Discretionary Clients and the Advisory Client Relationship, investors cannot direct the Firm as to how to vote in a particular solicitation. Conflicts of Interest The Firm and its affiliates engage in a broad range of activities. In the ordinary course of conducting the Firm’s activities, the interests of a Client may conflict with the interests of the Firm, its affiliates, their respective employees, or other Clients. Any conflicts of interest relating to the Firm voting or giving consent with respect to the securities owned by Clients for which the Firm exercises voting authority and discretion (“Voting” or “Votes”), regardless of whether actual or perceived, will be addressed in accordance with these policies and procedures. The Firm’s CCO has the responsibility to monitor Voting decisions for any conflicts of interest. All Voting decisions will require a mandatory conflicts of interest review by the CCO in accordance with these policies and procedures, which will include consideration of whether the Firm or any investment professional or other person recommending how to Vote has an interest in the Vote that may present a conflict of interest. The CCO will use his best judgment to address any such conflict of interest and ensure that it is resolved in accordance with his or her independent assessment of the best interests of the relevant Clients. When the CCO deems appropriate in his sole discretion, unaffiliated third parties may be used to help resolve conflicts. In this regard, the CCO shall have the power to retain independent fiduciaries, consultants, or professionals to assist with Voting decisions and/or to delegate Voting or consent powers to such fiduciaries, consultants or professionals. Additional considerations in the case of possible or perceived conflicts might arise, along with the need for related additional procedures, in the case of Clients subject to ERISA. This summary of the Firm’s voting policies and procedures is qualified in its entirety by the Firm’s voting policies and procedures. The Firm will make information regarding how proxies were voted available upon request to any Client or investor and a copy of the Firm’s voting policies and procedures is available to any Client or investor upon request by contacting the Firm at (212) 8211635 or fundcompliance@standardinvestments.com.