Twin Oaks Partners: investment adviser

For further description of Oaktop’s investment objectives, strategies and associated risks please see Item 8, Method of Analysis, Investment Strategies and Risk of Loss. Oaktop does not tailor advisory services to the individual needs of the Funds’ underlying investors and does not accept investor-imposed investment restrictions. As of December 31, 2025, Oaktop has a total of approximately $1,234,900,000 in regulatory assets under management, all on a discretionary basis. Oaktop does not manage any assets on a non-discretionary basis. Oaktop was established in February 2012 and is the successor General Partner of Twin Oaks, L.P. (established February 1991) and Twin Oaks QP, L.P. (established January 2000). Oaktop is owned by Robert F. Moriarty and Timothy E. Moriarty.

Oaktop will pay normal operating expenses incurred for day-to-day administrative services provided to the Funds including overhead and expenses related to the analysis of potential investments. The Funds will pay all expenses in connection with custodial fees, audit fees and other overhead costs. The Funds will also incur brokerage and other transaction costs. Please refer to Item 12, Brokerage Practices of this brochure for a

discussion of Oaktop’s brokerage practices.

Funds involve risk of loss, and investors in the Funds should have the ability to sustain the loss of their entire investment. There is no assurance that the performance of Oaktop or the Funds will equal or exceed any past performance. While prospective investors should review the risk disclosures set forth in full in the applicable Fund’s offering materials or separate account documentation, the following are certain material risks with respect to investments in the Funds. These risks are qualified in their entirety for a particular Fund by the risks set forth in such Fund’s private placement memorandum, other offering materials, or governing documents. • Risk of Loss: Investing in securities involves a certain amount of risk of loss that investors should be prepared to bear. Questions regarding these risks and/or increased costs may be directed to Oaktop and its management. • Long-Term Investment: Investments in the Funds are not intended to be short-term investments but, if warranted, short term gains may be realized. • Reliance on Issuer Company Management: While it is the intent of Oaktop to invest in companies with proven operating management in place, there can be no assurance that such management will continue to operate successfully. • Illiquidity: Investments in the Funds represent highly illiquid investments and should only be acquired by investors able to commit capital for an indefinite period of time. Investors will not be permitted to transfer their interests in the Funds without the written consent of the General Partner, which may be withheld in its sole discretion, and the satisfaction of certain other conditions, including compliance with applicable securities laws. • Short Sales: Short selling, or the sale of securities not owned by the Funds, necessarily involves certain additional risks. Such transactions expose the Funds to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and in the case of equities, without effective limits. There is the risk that the securities borrowed by the Funds in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a "short squeeze" can occur, wherein the Funds might be compelled, at the most disadvantageous time, to replace borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. • Leverage: While the use of certain forms of leverage can substantially improve the return on invested capital, such use may also increase the adverse impact to which the portfolio of the Funds may be subject. Borrowings will usually be from prime brokers and will typically be secured by the Funds’ securities. Under certain circumstances, a prime broker may demand

an increase in the collateral that secures the Funds’ obligations, and if the Funds were unable to provide additional collateral, the prime broker could liquidate assets held in the account to satisfy the Funds’ obligations. Liquidation in that manner could have extremely adverse consequences. In addition, the amount of the Funds’ borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on the Funds’ profitability. In an unsettled credit environment, the Adviser may find it difficult or impossible to obtain leverage for the Funds. Since leveraging their assets may be an integral part of the investment strategy of the Funds, in such an event the Funds could find it difficult to implement their strategies. In addition, any leverage obtained, if terminated on short notice by the lender, could result in the Adviser being forced to unwind positions quickly and at prices below what the Adviser deems to be fair value for the positions. • Small Cap Securities: At any given time, the Funds may have significant investments in stocks of smaller and sometimes newer issuers which may be more volatile and speculative than the stocks of larger issuers. Smaller companies tend to have limited resources, product lines and market share. As a result, their share prices tend to fluctuate more than those of larger companies. Their shares may also trade less frequently and in limited volume, making them potentially less liquid. The price of small company stocks might fall regardless of trends in the broader market. • Options Risk: Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. Because option premiums paid or received by an investor are small in relation to the market value of the investments underlying the options, buying and selling put and call options can result in large amounts of leverage. As a result, the leverage offered by trading in options could cause an investor's asset value to be subject to more frequent and wider fluctuations than would be the case if the investor did not invest in options. • Risk of Inadequate Return: The returns on a particular Fund’s investments, if any, may not be commensurate with the degree of risk of an investment in such Fund. Investors should have the ability to sustain the loss of their entire investment. • Multiple Fees and Expenses: Investors in a Fund will pay certain fees (as described in Item 5, “Fees and Compensation”), and expenses of such Fund. This will result in greater expense and less potential for return on investment than if such fees were not charged or such expenses incurred. Similarly, investors may pay Carried Interest to a Fund’s General Partner in connection with an investment. • Future Legislative and Regulatory Actions: New laws and regulations, changing regulatory schemes, and the burdens of regulatory compliance with respect to the Funds,

Oaktop, or any related entity may have a material negative impact on the performance of the Funds and portfolio companies. Such legislation and regulations may, directly or indirectly, (i) require Oaktop to provide reports and other disclosure to investors, counterparties, creditors, and regulators, (ii) cause Oaktop to alter its management of the Funds, including for the purposes of avoiding increased regulatory burdens, (iii) limit the types and structures of the investments available to the Funds including limitations on the use of leverage, or (iv) otherwise change or restrict the operations of the Funds. • Funds Not Registered: The Funds are not registered under the Investment Company Act or any other U.S. federal or state securities laws or the laws of any other jurisdiction. The Investment Company Act provides certain protections to investors and imposes certain restrictions on registered investment companies, which will not be applicable to the Funds. • Cybersecurity Risk: The Funds and their service providers may be subject to operational and information security risks resulting from cybersecurity attacks. Cybersecurity attacks include theft or corruption of data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, or various other forms of cybersecurity breaches. Cybersecurity attacks affecting the Funds or their service providers may adversely impact the Funds. For instance, cybersecurity attacks may interfere with the processing or execution of Fund transactions, cause the release of confidential information, including private information about limited partners, subject the Funds or the Adviser to regulatory fines or financial losses, or cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which the Funds may invest. These risks could result in material adverse consequences for such issuers and may cause the Funds’ investments in such issuers to lose value. • Pandemic Outbreaks: Disease outbreaks that affect local economies or the global economy may materially and adversely impact our investment portfolios and/or our business. These types of outbreaks have the potential to cause severe decreases in core business activities such as manufacturing, purchasing, tourism, business conferences and workplace participation, among others. These disruptions also have the potential to lead to instability in the marketplace, including market losses and overall volatility. In the face of such instability, governments may take extreme and unpredictable measures to combat the spread of disease and mitigate the resulting market disruptions and losses. In the event of a pandemic or an outbreak, there can be no assurance that we or our service providers will be able to maintain normal business operations for an extended period of time or will be able to retain the services of key personnel on a temporary or long-term basis due to illness or other reasons. The full impact of a pandemic or disease outbreak is unknown, which could result in a high degree of uncertainty for potentially extended periods of time.

The following factors may alleviate, but will not eliminate, conflicts of interest among the Funds and Oaktop’s Related Accounts: • Oaktop will not make or sell any of the Funds’ investments or take any action unless it believes that such action is considered solely from the viewpoint of the Funds and is beneficial for the Funds; and • Where an investment opportunity is suitable for both the Funds and any Related Accounts, the Funds will take precedence over the Related Accounts in the allocation of trades. As required by Rule 204A-1 of the Investment Advisers Act of 1940, Oaktop has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the firm. The Code of Ethics describes the firm's fiduciary duties and obligations to clients and sets forth the Firm’s practice of supervising the personal securities transactions of employees who maintain access to Fund information. Related persons of Oaktop provide services individually and as trustees to trusts, LLCs, individuals, limited partnerships, and friends. Such services may be similar to services

rendered to the Funds. Oaktop and its related persons do not give preferential treatment to any of these groups over the Funds in the allocation of investment opportunities. The Firm collects and maintains records of securities holdings and transactions made by employees. The Firm reviews the personal trading practices of its employees to identify and resolve any potential or realized conflicts of interest. A copy of Oaktop's Code of Ethics is available upon request.

In these arrangements, the broker‑dealers make research available to Oaktop with the expectation that Oaktop will execute client brokerage transactions through them. This practice is commonly referred to as the use of "soft dollars," whereby an investment adviser uses client brokerage commissions to obtain research or other services that benefit the adviser’s investment decision-making. Although Section 28(e) of the Securities Exchange Act of 1934 provides a "safe harbor" permitting advisers to use client commissions to obtain eligible research and brokerage services under certain conditions, Oaktop does not maintain any formal soft‑dollar arrangements or written commitments with any broker‑dealer. Although our receipt of research does not reduce our normal independent research activities, it enables us to avoid the additional expenses that we might otherwise incur if we were to pay for the research directly or attempt to independently develop comparable information. This gives us an incentive to select or recommend a broker-dealer based on our interest in receiving the research, rather than on the Funds’ interest in receiving most favorable execution. However, best execution remains our primary consideration when making trading decisions, and we always strive to ensure that the Funds’ interests in receiving the most favorable execution are prioritized. Trade Aggregation: When a trade is placed for more than one account at the same time, we will aggregate or block trade when we believe this will result in more favorable execution.

Trade Allocation: If an order is aggregated, the order will be allocated in accordance with the pre-trade allocation specified. If the trade is partially filled, the order is allocated on a pro rata basis in proportion to the intended pre-trade allocation. Each account will receive the same price and commission.

This general policy should not be interpreted as a pre-determination, however, to vote in favor of the issuer’s management, as we will review all proxies in accordance with the general fiduciary principles we adhere to. With respect to nonrecurring or extraordinary matters, we will vote on a case-by-case basis in accordance with the goals of achieving a Fund’s stated objectives. Oaktop has engaged a proxy advisory service to facilitate the execution of its proxy voting process. The service operates in accordance with Oaktop’s standing instructions to vote with management and does not provide voting recommendations that influence decision-making. Oaktop periodically reviews the proxy advisory firm’s processes to ensure they align with its proxy voting policies and the Funds’ interests. The proxy advisory firm pre-populates each Funds’ votes with Oaktop’s voting guidelines and automatically submits the votes. Prepopulation and automated voting generally occur prior to the submission deadline for proxies to be voted at the shareholder meetings, and Oaktop relies on the proxy advisory firm to ensure soliciting materials that are received close to the submission deadline are incorporated into voting recommendations and the Funds’ votes. Should a situation arise where Oaktop believes voting in a manner other than the agreed upon standing instructions, or abstaining from a vote, is in the best interest of the Funds, Oaktop will exercise its discretion to vote or abstain accordingly. Oaktop monitors proxy voting decisions for any conflicts of interests, regardless of whether they are actual or perceived. In addition, Oaktop performs its tasks relating to the voting of proxies with the first priority to the economic interests of the Funds. If at any time Oaktop becomes aware of any potential or actual conflict of interest or perceived conflict of interest regarding the voting policies and procedures or any particular vote on behalf of any Fund, the firm will notify the Chief Compliance Officer. If any Oaktop Principal is pressured or lobbied either from within or outside of the firm with respect to any particular voting decision, he will notify the Chief Compliance Officer. Oaktop will use its best judgment to address any such conflict of interest and ensure that it is resolved in the best interest of the Funds. Oaktop may cause any of the following actions to be taken in that regard: •

vote the relevant proxy in accordance with the vote indicated by the Firm’s proxy voting guidelines; or

•

vote the relevant proxy as an exception, provided that the reasons behind the voting decision are in the best interest of the Funds, are reasonably documented, and are approved by the Chief Compliance Officer.

The General Partner determines whether the Funds will participate in class action settlements or opt out to pursue separate recoveries and is responsible for completing and submitting any required claims, maintaining related documentation, and receiving settlement proceeds. The Adviser may engage a third‑party vendor to assist with tracking and filing class action claims. The Funds generally do not seek to serve as lead plaintiff in class actions, as the associated costs typically outweigh any incremental benefits. A copy of Oaktop's Proxy Voting Policies and Procedures and information about how Oaktop voted the Funds’ securities is available to investors upon request and can be obtained by contacting us at the telephone number listed on the cover page of this document.