Poplar Point Capital Management LLC: investment adviser

Client Investment Objectives/Restrictions Investments for the Fund are managed in accordance with the Fund’s specific investment objectives, strategies and restrictions. Investments are not tailored to the individualized needs of any particular investor in the Fund (each, an “Investor”). Investors may not impose restrictions on investing in certain securities or certain types of securities. Poplar Point typically does not tailor its services to the individual needs of the SMA, but manages the account according to the investment guidelines and strategy selected by the client. 4.D. Wrap-Fee Programs Poplar Point does not participate in any wrap fee programs. 4.E. Assets under Management As of December 31, 2025, Poplar Point had $110,119,933 in regulatory assets under management. All assets are managed on a discretionary basis.

Poplar Point receives a management fee from the SMA which is paid quarterly in arrears. The management fee is equal to 1% (per year) of the SMA’s assets under management. The management fee is adjusted for inflows to or outflows from the SMA during the quarter. Performance-Based Compensation The Fund’s general partner, Poplar Point Capital GP LLC, is entitled to receive an annual performance-based allocation equal to 10% of the net capital appreciation credited to each Investor in the Fund, subject to a high water mark. The performance allocation, if any, is generally calculated and determined as of December 31st of each year, but may be calculated on other dates, such as upon the termination of the Fund and the final liquidation of its assets. If an Investor withdraws on a date other than December 31st, the performance allocation will be calculated with respect to the actual change in net capital appreciation through and including the date of withdrawal. Poplar Point is entitled to receive an annual performance-based fee of 15% of any outperformance relative to the SMA’s benchmark index, net of any management fees. If the client withdraws on a date other than December 31st, the performance-based fee will be calculated through the date of withdrawal. Any performance-based compensation complies with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).

5.B. Direct Billing of Advisory Fees Management fees and performance allocation charged for the Fund are deducted directly from the Fund’s assets. Poplar Point sends an invoice to the SMA client for applicable fees and does not deduct fees from the SMA account. 5.C. Other Non-Advisory Fees Management fees and the performance allocations are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that are incurred by the client. Item 12 of this Brochure describes the factors Poplar Point considers in selecting broker-dealers for transactions and determining the reasonableness of their compensation (e.g., commissions). The Fund pays its own operating expenses, including but not limited to: investment expenses such as brokerage commissions, trade execution data and services, clearing and settlement charges, custodial fees, bank service fees, interest expense, and extraordinary expenses; legal expenses; professional fees relating to investments, including consultants and experts; travel expenses related to investigating investment opportunities; accounting and bookkeeping expenses; audit and tax preparation expenses; fees and out-of-pocket expenses of any service company retained to provide accounting, investor, administrative or custodial services for the Fund; and data and information services expenses. The Fund will also bear the organizational expenses of the partnership and any expenses incurred in connection with the offer and sale of limited partnership interests, including printing costs, marketing and legal fees and expenses of the partnership and the general partner and other expenses of the offering of such interests. 5.D. Advance Payment of Fees As noted in Item 5.A. above, the management fee charged to the Fund is paid quarterly in advance. Investors who are permitted by the General Partner of the Fund to contribute capital on a date other than the first day of a fiscal quarter are charged a prorated management fee for that fiscal quarter with respect to such contribution on the date such contribution is made. Investors who are permitted by the General Partner of the Fund to withdraw capital on a date other than the last day of a fiscal quarter do not receive a refund of the management fee paid in advance for that fiscal quarter.

5.E. Compensation for Sale of Securities or Other Investment Products Neither Poplar Point nor its supervised persons accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

Poplar Point will primarily invest in, and sell short, securities and commodities including equity, listed debt, bank debt, exchange-traded funds (ETFs), options, other derivative securities and foreign currencies. Poplar Point may engage in margin trading, options trading, hedging and other strategies that may magnify both positive and negative returns.

Poplar Point’s goal is to maximize investment returns on a risk-adjusted basis. Poplar Point intends to run a concentrated investment strategy focusing on purchasing securities trading below intrinsic value and underpinned by primary research to ascertain the intrinsic value of investments. Poplar Point will focus primarily on smaller market capitalization equity securities, debt securities and derivative securities. Many of the investment techniques and activities described above are high-risk activities that could result in substantial losses under certain circumstances. Investing in securities involves the risk of loss of some or all of an investment. Clients and underlying investors should be prepared to bear that risk. 8.B. Material Risks of Investment Strategies There is no guarantee that the investment strategies of Poplar Point will be successful. The success of the strategies may be adversely affected by general economic and market conditions such as market fluctuation, interest rates, availability of credit, inflation rates, changes in laws and political circumstances. These factors may affect the level and volatility of security pricing and the liquidity of certain investments. The following material risks are related to Poplar Point’s investment strategy: Concentration Risk. A significant portion or a majority of the client’s investments may be concentrated in only a few securities, industries, countries or geographic regions or may be concentrated in other ways. This concentration may cause a proportionately greater loss than if the client’s investments were more diversified because the failure of one or a limited number of investments could have a materially adverse effect on the client. Management Risk. Judgments about the value and potential appreciation of a particular security may be wrong and there is no guarantee that individual securities will perform as anticipated. The value of an individual security can be more volatile than the market as a whole and Poplar Point’s approach may fail to produce the intended results. Market Risk. The value of equity securities will decline from time-to-time due to daily fluctuations in the securities markets. Stock prices change daily as a result of many factors, including developments affecting the condition of both individual companies and the market in general. The price of a stock may even be affected by factors unrelated to the value or condition of its issuer, such as changes in interest rates, national and international economic and/or political conditions and

general equity market conditions. In a declining stock market, prices for all companies may decline regardless of their long-term prospects. Catastrophic Events Risk. The value of securities may decline as a result of various catastrophic events, such as pandemics, natural disasters, and terrorism. Losses resulting from these catastrophic events can be substantial and could have a material adverse effect on Poplar Point’s business and the client. Options Trading. Trading options is highly speculative and may entail risks that are greater than investing in other financial instruments. Prices of options are generally more volatile than prices of other financial instruments. In trading options, Poplar Point speculates on market fluctuations of the underlying financial instrument (e.g., a security, an index, a commodity, exchange rate or other instrument), while only investing a small percentage of value relative to its client's potential exposure. Short Sales. Short selling, or the sale of securities not owned by clients, necessarily involves certain additional risks. Such transactions expose the client to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed 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 Poplar Point 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. In addition to entering into short sales both for speculative purposes, as Poplar Point may cause its clients to do from time to time, and depending on market conditions, Poplar Point may cause the client to engage in short selling in connection with hedging such clients' existing long and short positions. Hedging activities may involve taking short positions related to particular portfolio positions as well as short positions intended to hedge broader exposures or particular identified risks at an overall portfolio level. Turnover. Poplar Point may invest the client’s assets on the basis of certain shortterm market considerations. The turnover rate within the client’s investments may be significant, potentially involving substantial brokerage commissions and fees. Leverage. Poplar Point may utilize leverage on behalf of the client by borrowing without limitation and using various lines of credit and other forms of leverage, including swaps and repurchase agreements. In addition, due to liquidity of

certain investments, leverage may be a significant tool that Poplar Point may employ to pursue its investment objectives. While leverage presents opportunities for increasing total return, it also may generate increased losses beyond what might result without the use of leverage and may magnify any losses in periods where securities held by the client are falling in price. Additionally, because Poplar Point’s investment strategy for the client includes both long and short positions, leverage can create a scenario where both long and short positions suffer substantial capital losses. The client’s margin borrowings and short positions generally will be secured by cash and securities held in the client’s brokerage accounts, and the use of short-term margin borrowings results in certain additional risks to the client. Accuracy of Public Information. Poplar Point selects investments on the basis of information and data filed by issuers with various government regulators or made publicly available by the issuers or through publicly available sources other than the issuers. Although Poplar Point evaluates this information and data, Poplar Point cannot confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information may not be available. 8.C. Material Risks of Securities Used in Investment Strategies Investments in the types of securities Poplar Point selects may be more volatile than the overall market. Security values may fluctuate based on events such as technological developments, government regulation, competition and outbreaks of war or terrorist acts that are beyond Poplar Point’s control. The following risks are associated with the types of securities that are traded by Poplar Point: Equity Risk. The prices of equity securities fluctuate based on overall market and economic conditions. In addition, individual securities rise and fall based on changes in the issuer’s financial condition. As a result, equity investments risk a loss of all or a substantial portion of the investment. Short Positions. A short sale involves the sale of a security that the client does not own in the expectation of purchasing the same security (or a security exchangeable for such security) at a later date at a lower price. To make delivery to the buyer, the client must borrow the security, and is obliged to return the security to the lender, which is accomplished by a later purchase of the security. A profit or a loss results from a short sale if the price of the security decreases or increases, respectively, between the date of the short sale and the date on which the short position is covered, i.e., the security to replace the borrowed security is

purchased. A short sale involves the theoretically unlimited risk of an increase in the market price of the security that would result in a theoretically unlimited loss. Foreign Investments. Poplar Point may invest the client’s assets in non-U.S. securities, including securities denominated in non-U.S. currencies. Such investments pose currency exchange risks (including blockage, devaluation and non-exchangeability) as well as a range of other potential risks including, depending on the country involved, expropriation, confiscatory taxation, political or social instability, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding non U.S. companies which may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those applicable to U.S. markets. Further, foreign securities markets may not be as liquid as U.S. markets. Transaction costs of investing outside the U.S. are generally higher than in the U.S., including the cost of converting foreign currency to dollars, the payment of fixed brokerage commissions on some foreign exchanges and the imposition of transfer taxes or transaction charges by foreign governments and exchanges. Less government supervision and regulation of exchanges, brokers and issuers generally exist abroad than in the U.S., and it is more difficult to take appropriate legal action in non U.S. courts. In addition, non U.S. markets have different clearance and settlement procedures from U.S. markets. Some foreign markets have at times failed to keep pace with transaction volume, thereby creating substantial delays and settlement failures that could adversely affect the client’s performance. Derivatives and Swaps; Counterparty Risks. Poplar Point may invest the client’s assets in complex derivative and swap instruments which seek to modify or replace the investment performance of particular securities, commodities, currencies, interest rates, indices or markets on a leveraged or unleveraged basis. These instruments generally have counterparty risk and may not perform in the manner Poplar Point expects, thereby resulting in significant unanticipated loss or gain. These investments are all subject to additional risks that can result in substantial or total loss of all or part of an investment, in particular, interest rate and credit risk volatility, world and local market price and demand, and general economic factors and activity. Derivatives may have very high leverage embedded in them that could substantially magnify market movements and result in losses greater than the amount of the investment. Some of the markets in which Poplar Point may effect derivative transactions may be “over the counter” or “inter-dealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as they are members of “exchange based” markets. This exposes the client to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of the

counterparty’s credit or liquidity problems. Delays in settlement may also result from disputes over the terms of the contract (whether or not bona fide) since such markets may lack the established rules and procedures for swift settlement of disputes among market participants found in “exchange based” markets. These factors may result in losses due to adverse market movements while replacement transactions are executed or otherwise. Such “counterparty risk” is present in all swaps, and is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the client has concentrated its transactions with a single or small group of counterparties. The client is not restricted from dealing with any particular counterparty or from concentrating any or all of its transactions with one counterparty. Moreover, the client has no internal credit function which evaluates the creditworthiness of its counterparties. The ability of the client to transact business with any one or number of counterparties, the lack of any meaningful and independent evaluation of such counterparties’ financial capabilities and the absence of a regulated market to facilitate settlement may increase the potential for losses by the client. 8.D. Risks Associated with Investment in a Private Fund Regulatory Oversight. The Fund is not registered as an investment company under the Investment Company Act of 1940 and, therefore, will not be entitled to the various protections afforded by the Act with respect to the Fund’s investments. Limited Right of Withdrawal. Generally, withdrawals may only be made by an Investor at the end of any calendar quarter, subject to restrictions based on time of investment as described in the Fund’s offering documents. Withdrawals also generally require not less than 60 days’ prior written notice to the Fund’s general partner, as described in the Fund’s offering documents. Exceptions to the process may be processed by the General Partner at its discretion. For further information regarding the risk factors and conflicts of interest with respect to the Fund, please refer to the Fund’s offering documents.

Recommendations of Securities and Material Financial Interests Poplar Point and its related persons do not recommend to clients, or buy or sell for client accounts, securities in which Poplar Point or a related person has a material

financial interest, such as buying or selling, as a principal, securities to or from clients; acting as a general partner in a partnership in which Poplar Point solicits client investments; or acting as an investment adviser to an investment company that Poplar Point recommends to clients. 11.C. Personal Trading Poplar Point has adopted the Code to ensure that personal investing activities by Poplar Point’s employees are consistent with Poplar Point’s fiduciary duty to its clients. In order to avoid potential conflicts that could be created by personal trading by Poplar Point employees, the Code restricts the purchase and sale by employees for their own accounts. All employees are required to pre-clear with the Chief Compliance Officer any personal securities transaction in specified securities, including IPOs and limited offerings. All employees are required to submit quarterly personal securities transactions and annual holdings reports for review by the Chief Compliance Officer, who will, in turn, review these reports for trading conflicts. 11.D. Timing of Personal Trading In order to avoid potential conflicts that could be created by personal trading by Poplar Point employees, the Code restricts the purchase and sale by employees for their own accounts of any covered security within a specific time before or after the execution of a transaction in any such security for clients.

the ability to fulfill the order in a timely manner;

the broker-dealer’s clearance and settlement capabilities;

the broker-dealer’s trade error rate and ability or willingness to correct errors;

the timing of the transaction, taking into account market prices and trends;

the reputation, experience and financial stability of the brokerdealer; and

the quality of service rendered by the broker-dealer in other transactions.

Research and Other Soft Dollar Benefits Poplar Point does not currently maintain any arrangements where it receives products and services from brokers in connection with client securities transactions. Should Poplar Point enter into any arrangements or receive products or services on an ongoing basis from broker/dealers it would limit the use of any “soft dollars” to services that constitute brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934. Brokerage for Client Referrals Poplar Point does not consider whether it or any related person receives client referrals from a broker-dealer in selecting broker-dealers. Directed Brokerage Poplar Point does not accept directed brokerage. Trade Errors When a trade error occurs, Poplar Point will reasonably determine how to correct the error. Documentation of any errors made will be maintained by Poplar Point. 12.B. Aggregation of Orders

If Poplar Point determines to buy or sell the same security on behalf of more than one client, Poplar Point may, but is not obligated to, place an aggregated order in order to obtain best execution. Poplar Point’s policy is to seek to allocate trades in a manner that treats all clients fairly over time. Generally, when more than one client trades in the same security on the same day, orders will be determined for each client at the beginning of the day and trades will be allocated pro rata according to the size of the order should an order be partially filled. At times, additional orders may arise during the day for one of the clients in which case, additional allocations will be made only to the participating client. Participating accounts shall receive the weighted average execution price for the day and shall pay the commission, fees and charges on a pro rata basis or on such other basis deemed fair and equitable by Poplar Point for days when all trades are being split between accounts. In situations where opportunities are too limited for all accounts to participate (even on an allocated basis), Poplar Point will make every reasonable effort to allocate such trades fairly and equitably over time based on an assessment of relative expected efficiencies and in view of the different investment objectives, leverage, risk parameters and current positions of the accounts, including any provisions in the client’s governing documents that address allocation of opportunities. This assessment may be made (i) solely in light of the specific investment under consideration or (ii) in the context of the client’s overall holdings and available capital. In situations that Poplar Point does not aggregate trades, it may result in higher costs or less favorable execution.

The clients’ investments are reviewed on an ongoing basis and may be reviewed specifically with regard to certain factors such as cash flows or in response to market conditions. 13.C. Content and Frequency of Reports Investors in the Fund receive written reports, including a monthly statement of net asset value from the Fund’s administrator, a quarterly letter discussing results, and annual, audited financial statements. Poplar Point will provide the SMA with written quarterly reports for the accounts as soon as reasonably possibly, but not later than five business days, after the end of each quarter. The report will discuss market valuation and performance.

The statement is a formal report on the assets held in the account and transactions in the account. Clients are urged to carefully review such statements and compare them to the account statements or other reports that we provide. Our performance reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.

Investments for the Fund are managed in accordance with the Fund’s investment objectives, strategies and restrictions, and are not tailored to the individualized needs of any particular Investor in the Fund. Therefore, Investors should consider whether the Fund meets their investment objectives and risk tolerance prior to investing. Information about the Fund can be found in its offering documents, which are available to current and qualified prospective Investors only through Poplar Point. Poplar Point has discretion over the SMA. The SMA is managed in accordance with the client’s investment guidelines and objectives. The SMA grants Poplar Point discretion through the execution of attorney-in-fact. Poplar Point has the authority to implement investment strategies without prior consultation with the client.

If a conflict may exist which cannot be otherwise addressed, Poplar Point may choose one of several options including “echoing” or “mirroring” voting the proxies in the same proportion as the votes of other proxy holders that are not Poplar Point clients. A copy of Poplar Point’s proxy voting policies and procedures and records of how Poplar Point voted are available upon request.