Bluearc Capital Management: investment adviser

BACM’s (801-79523) registration with the Securities and Exchange Commission ("SEC") as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended, was approved on April 8, 2014. This registration does not imply any level of skill or knowledge. The principal owner of the Firm is Ronald Zazworsky, Jr. Please see Item 10: Other Financial Industry Activities and Affiliations for a list of all Investment Advisory Affiliates. BACM’s Advisory Services BACM, either directly or through its subsidiaries, provides advisory services to private fund clients and consulting, research, and non-discretionary advisory services to other clients. Advisory clients and clients that are private funds are referred to herein as “Clients”. Clients that are private funds are also referred to herein as “BlueArc Funds”. This brochure may also from time to time refer to investors within the funds as “Fund Investors”. In its capacity as the manager and investment adviser to a BlueArc Fund, the Firm provides management services and investment advice, as applicable, solely to the applicable BlueArc Fund, and not to individual Fund Investors. The descriptions set forth in this brochure of specific advisory services that we offer to our Clients, and investment strategies pursued and investments made by us on behalf of our Clients, including the BlueArc Funds, should not be understood to limit in any way our investment activities. We may offer any advisory services, and, in the case of BlueArc Funds, engage in any investment strategy and make any investment, including any not described in this brochure, that we consider appropriate, subject to each BlueArc Fund’s investment objectives and guidelines. We do not provide investment advisory services to any Client except pursuant to a written advisory agreement. The investment strategies we pursue are speculative and entail substantial risks. Private Funds BACM manages and advises several BlueArc Funds with varying strategies, including private equity, hedge, real estate, and private credit. Each BlueArc Fund includes investment guidelines and parameters as well as specific reporting requirements and accounting guidelines. Each BlueArc Fund is managed to the specific objectives of such BlueArc Fund and are not tailored to the individual needs of the Fund Investors. The descriptions of the BlueArc Funds in this brochure, including the type of investments made and strategies used, fees and expenses charged, risk factors and conflicts of interests that may arise in BACM’s management of such funds and investments are qualified in their entirety by reference to each BlueArc Fund’s formal offering materials (e.g., the BlueArc

Fund’s offering memorandum, memorandum and articles of association, limited partnership agreement or limited liability company agreement, and subscription document) provided to investors in the BlueArc Funds (collectively referred to herein as the “Offering Documents”). Consulting, Research, and Non-Discretionary Advisory Services BSSCM, a relying adviser under common control with BACM, provides consulting, research, and non-discretionary advisory services to a limited number of Clients. Research and analysis of specific assets, along with any recommendations, are guided by the Client’s individual situation, objectives, and criteria. BSSCM consulting, research and non-discretionary services are focused primarily on investments in corporate securities, loans, equity, debt, derivatives and other similar investments in the aviation industry and other related sectors as may be identified by the client’s criteria. Client accounts may or may not be continually supervised, as established in the Client’s particular agreement; however, generally recommended assets purchased by the Client are monitored to ensure previous recommendations remain appropriate. Where BSSCM is not providing continuous supervision to an account, we consider the assets of the account to be assets under advisement rather than a part of our regulatory assets under management. As a part of these services, BSSCM may recommend an investment in a BlueArc Fund; however, clients are under no obligation to invest in any recommended product, including the BlueArc Funds. To date, no BSSCM client has invested in a BlueArc Fund. Agreements to provide consulting, research, and non-discretionary advisory services are entered into on a limited basis, and the related terms and fees are negotiated separately for each case. Assets Under Management As of September 30, 2025, BACM has $2,443,849,185 discretionary assets under management. BACM also has $126,003,422 of assets under advisement.

On certain open-ended funds, BACM also has the ability to charge incentive performance fees in addition to the annual asset management fees. In some cases BACM has historically waived these incentive performance fees. On specific closed-ended funds, BACM has the ability to charge a carried interest in addition to the annual asset management fees. Incentive performance fees and carried interest fees generally range from 5% to 20% and are earned on the net profit of the specific fund. Carried interest may be subject to certain return hurdles and or waterfall payment provisions, as noted the specific BlueArc Fund Offering Documents. Annual asset management fees, incentive performance fees, and carried interest fees are negotiable. More details about these fees can be found in the BlueArc Funds’ offering documents. Additionally, BACM has chosen to waive the management and/or incentive fees charged to Fund Investors who are also BACM employees. In situations where it is determined that certain BlueArc Funds should hold other BlueArc funds that are consistent with the investment objective, the General Partner waives the management fee and carried interest for the existing Fund to ensure no “double-dipping” has occurred. More detailed information about specific fees and expenses that BlueArc Funds may pay is provided in the Offering Documents for each specific fund. With respect to BlueArc Funds, each fund is typically responsible for any reasonable, out-of-pocket fees costs and expenses incurred by BACM related to the management and administration of the funds, such as the following non-exhaustive list of items: • brokerage commissions • custodial fees • bank service fees • administrative expenses • valuation and appraisal expenses • organizational expenses (including the cost of the offering and ongoing sale of fund interests) • costs of winding-up a fund • interest expenses • financing costs • investment-related expenses, including travel and due diligence expenses • risk management expenses • legal and compliance expenses • auditing and tax preparation expenses • accounting and operations expenses (including the cost of accounting software packages) • extraordinary expenses (including litigation, indemnification and contribution expenses)

• taxes • expenses related to unconsummated investments • third party administrator expenses • insurance costs • fees and expenses of sub-advisers • fees and expenses related to lending arrangements • expenses related to the identification, evaluation, due diligence, holding, monitoring, and disposal of underlying investments • cost of software in connection with investments (including fees of third-party software developers) • fees and reimbursable expenses to members of a fund’s Board of Directors • expenses associated with Advisory Boards and meetings of the limited partners • expenses relating to quantitative analysis and software management services • fees and expenses of servicers of specific assets owned by a fund • costs of research, information systems, software and hardware • permissible overhead expenses, as applicable • professional fees relating to investments (including expenses of consultants and experts) • expenses associated with the distribution of reports and notices to investors. Consulting, Research, and Non-Discretionary Advisory Services As stated in Item 4: Advisory Business, BSSCM enters into agreements to provide consulting, research, and non-discretionary advisory services only under limited circumstances. The related terms and fees are negotiated on a case-by-case basis. Fees under these contracts can take on a variety of formats, including flat monthly or annual fee, performance or incentive fees, asset based fees, or any combination thereof. Additionally, various expenses, including but not limited to travel, data services, and software, may be negotiated into the contracts on an ad hoc basis.

Those due diligence points include, but are not limited to, items such as general investment philosophies, nature of the securities that are targeted for investment, diversification of the securities portfolios, leverage amounts of the portfolios, risk exposure levels of the portfolios, analysis of various risk metrics, investment team performance and experience, tenure of the investment team, operational and back-office infrastructure, performance track record and analysis, investment research process, third-party vendors, financial controls, counter-party risks, and other pertinent aspects of the investment strategy and operations. Investing in fund strategies involves varying levels of risk which Fund Investors and clients should be willing to bear. Such risks include, but are not limited to, portfolio team risk, market risk, portfolio selection risk, financing and portfolio leverage risk, operational risk, domestic and global economic risks, credit market risks, real estate risks, legal and regulatory risks, and other risks that generally affect values of publicly-held securities. Investing in private funds involves risk of loss that the investor should be prepared to assume. These losses may include the loss of principal; a reduction in earnings (including interest, dividends and other distributions); and the loss of future earnings. Such risks may also include, without limitation: • concentration risk • credit risk • derivatives risk • equity risk • fixed income risk • foreign investment risk • high yield risk • leveraging risk • liquidity risk • management risk • market risk • new offering with no operating history risk • repurchase policy risks • small and medium capitalization company risk • funds risk • issuer and non-diversification risk A more detailed description of the risks associated with each particular investment strategy is included in the Offering Documents of the respective BlueArc Fund, a copy of which is provided to prospective Fund Investors and should be carefully reviewed prior to investing in the BlueArc Funds.

BAC-MP Fund Management, LLC BlueArc Global Macro Fund Management, LLC BlueArc Alternatives Fund Management, LLC BlueArc Private Investments Management, LLC BlueArc Credit Alternatives Fund Management, LLC BlueArc Real Estate Investments Management, LLC BlueArc Core Alternatives Management, LLC BlueArc Global Alternatives Management, LLC BlueArc Select Equities Management Holdings, LLC BGPCOF GP LLC

BACM is the principal owner of the above-listed management companies. As mentioned previously, BACM, on a non-discretionary basis, may recommend that certain advisory clients meeting applicable requirements consider allocating a portion of their investment assets to the affiliated funds. Our clients are under absolutely no obligation to either consider or make an investment in any of the BlueArc Funds. Where BACM serves as co-investment manager for a BlueArc Fund, the responsibilities of portfolio management for the BlueArc Fund are shared with an unaffiliated investment adviser. BACM, or an affiliated, wholly owned subsidiary of BACM remains responsible for management of all other aspects of the BlueArc Fund, including legal, regulatory, administration, and investor relations. In these relationships, management fees paid by the funds are typically shared between the co-investment managers based on the terms of the Investment Advisory Agreement. Such co-investment manager relationships do not result in additional fees being charged to the BlueArc Funds over and above the fees noted in the BlueArc Fund’s Offering Documents. BACM has a relationship with one or more unaffiliated investment advisors (the “Unaffiliated Advisors”) whereby the Unaffiliated Advisors receives a portion of the management and incentive fees (if applicable) earned by some of the affiliated management companies noted above. These fees are paid to the Unaffiliated Advisors by the affiliated management companies and not the BlueArc Funds. Such agreements do not result in additional fees being charged to the BlueArc Funds over and above the fees noted in the BlueArc Fund’s Offering Documents. Principals or other employees of the Unaffiliated Advisors or other investment advisors where BACM or its affiliates has a relationship may be a Fund Investor in one or more of the BlueArc Funds. To address potential conflicts, such investors do not have any individual preferential treatment compared to other investors in the same fund.

For each of the entities noted above, BACM or a BACM affiliated management company receives compensation. A conflict of interest exists where there is a financial incentive for us to recommend that Clients invest in these funds over funds similar to these because of the additional compensation we or our affiliates receive, when in fact other funds for which we do not receive compensation may be more appropriate or less costly. We address conflicts of interest in several ways. Initially, we strive to disclose any conflict of interest we believe may be material to an investor’s decision-making process. Investors are given the opportunity to review and consent to this information prior to making an investment decision. We have a process in place so our investment decisions, capital allocations, and recommendations for capital allocations have been made only after we have performed what we believe to be thorough due diligence. During this process we consider factors we believe to be relevant for an investment decision, including the nature of the conflicts, the process to mitigate those conflicts, and the appropriateness of the investment. Our team performs ongoing due diligence on all investments to determine whether our Clients should continue holding an investment. We require our advisory affiliates to adhere to our Code of Ethics, conduct periodic reviews of personal and client accounts, conduct annual reviews of our overall compliance program, and have our Chief Compliance Officer (“CCO”) review conflict situations.

On at least an annual basis, all employees are required to provide written acknowledgement of their receipt and understanding of the code of ethics and any amendments thereof. Any violations of BACM’s Code of Ethics are required to be reported promptly to BACM’s CCO. A copy of the Firm's Code of Ethics is available to any client or prospective client upon request. Interest in Client Transactions We may advise Clients on the purchase of the BlueArc Funds. A conflict of interest exists to the extent the total compensation to BACM is increased. There is also a conflict that greater asset levels are likely to attract more investment dollars. Clients who purchase BlueArc Funds pay only the fees and expenses associated with the applicable BlueArc Fund, not for the advice to purchase the BlueArc Fund. A description of the risk factors and fees (management fees and incentive compensation), is set forth in each of the BlueArc Funds respective Offering Documents. Our Clients are informed of our relationship to the BlueArc Funds and clients are not required to purchase funds managed by us. Additionally, an existing BlueArc Fund can invest in other newly formed investment vehicles that have similar investment objectives and in a manner, that is consistent with the existing BlueArc Fund. For these investments, the General Partner waives any management fees and carried interest for the existing Fund that it may have received from the newly formed investment vehicles since these are duplicative and could be considered “double-dipping”. Personal Trading Our employees are permitted to engage in personal securities transactions. These transactions raise potential conflicts of interest if they were to trade in a security that is owned by a Client or considered for purchase or sale to a Client. We have adopted policies and procedures that are intended to address these conflicts of interest. Employees may buy or sell securities only if their personal transactions conform to our written policies. Side Letters BACM can provide more favorable treatment to certain Fund Investors over other Fund Investors in the same Fund. Such arrangements establish rights under, altering, or supplementing the terms of the limited partnership agreements, subscription agreements and offering memorandum of the affected Funds or be unrelated to a Fund. Certain arrangements can be granted to incentivize or permit Fund Investors to invest in a Fund, invest certain amounts, or invest with BACM in the future.

BACM regularly reviews the trades and expenses related to each brokerage account to ensure expenses are reasonable for the activity presented. The brokerage accounts are established via an executed agreement between the applicable BlueArc Fund and Interactive Brokers, LLC. BSSCM does not have authority to open brokerage accounts on behalf of its Clients. Research and Other Soft Dollar Benefits While the BlueArc Funds have the ability to enter into soft dollar arrangements, we do not currently have any such arrangements. Many of the underlying funds in which the BlueArc Funds invest may enter into so-called “soft dollar” arrangements, under which securities firms would provide or pay the costs of certain services, equipment, or other items for the benefit of the fund, the manager, investment manager, the underlying funds’ managers, or one or more of their affiliates, in consideration of the allocation to the firm of portfolio transactions (with resulting commission income or profit) or commissions made on behalf of or with the fund or their underlying funds. The services, equipment, and other items provided or for which payment is otherwise made using such soft dollar and brokerage service arrangements on behalf of the manager, investment manager, the underlying funds’ managers or one or more of their affiliates, may include, without limitation: prime brokerage services; written and oral information and analyses concerning specific securities, companies, or sectors; market, financial, statistical and economic studies and forecasts; proxy voting services; independent pricing services; computer hardware, software and services, and other office equipment and services used in the management of the fund and other client portfolios or for fund or other client portfolio analysis, record keeping or reporting; investment research consulting fees and charges; fees and charges for news wire, data processing, internet service provider, data access line and other communications services; investment manager, fund and manager attorneys’, accountants’, bookkeepers’ and administrators’ fees and expenses; client and investor referrals; offering expenses (including without limitation fees and expenses of attorneys and accountants, filing fees, printing and mailing costs); the fund’s proportionate share of conference and travel expenses related to fund and other client investment research; quotation services; periodical subscription fees; custody, record keeping and similar charges. Any such soft dollar payments would not reduce the amount of the management fees payable to the manager and its designees. Any of these soft dollar arrangements could benefit the fund by reducing expenses or benefit the manager, investment manager, the underlying funds’ managers or one or more of their affiliates without any direct benefit to the fund. The soft dollar arrangements may also provide an incentive to trade more actively to generate balances available to pay eligible expenses. Block Trades Because we execute brokerage transactions on a limited basis as noted above, we do not utilize block trading. Additionally, we do not execute transactions on behalf of the underlying fund investments or on subadvised funds and, therefore, have no control over whether the underlying trades are aggregated or not aggregated. The underlying fund’s offering memorandum and firm brochure of the fund’s investment adviser or sub-adviser contains specific information on whether they aggregate the purchase or sale of securities for client accounts.

Audited financial statements are prepared in accordance with generally accepted accounting principles and are delivered annually to all Fund Investors within 120 or 180 days (in the case of fund-of-funds) of our funds’ fiscal year end. The custodians, brokers, and the underlying funds provide the independent administrator of each BlueArc Fund with regular reports on the assets held on behalf of the respective BlueArc Fund. The administrator calculates the advisory fees, confirms the value of each BlueArc Fund’s account assets with BACM and provides Fund Investors with regular reports regarding their respective investments.

BACM does not have discretion over advisory services provided to Clients outside of the BlueArc Funds it advises. We may only exercise discretion if our Client has provided that authority to us in writing. Upon engaging BACM to manage a specific investment, a comprehensive investment management agreement is executed which includes details of both the account investment objectives and guidelines and the powers of authority delegated to BACM by the Client. If BACM were to recommend an investment outside of the preestablished guidelines included within the investment management agreement, a new agreement shall be sought from the applicable Client(s).

BACM cannot be assured of confidential treatment of the data submitted in connection with the proof of claim, or BACM otherwise believes it is not in the best interests of one or more Clients for BACM to be involved in such a claim. BACM makes these determinations in its sole discretion. As a result, BACM in some cases does not participate in class action securities lawsuits in which it may be entitled to participate. If BACM does participate in a class action securities lawsuit and later receives any recovery amounts, those amounts will be credited to the participating Clients at the time the recovery amounts are received. This may be materially after the relevant conduct alleged in the lawsuit took place and Fund Investors in the relevant Client, have redeemed their interests (to the extent such Client is an open-end Private Fund.). As such, Fund Investors who have already redeemed interests at the time that the recoveries are received by the Client will not receive the benefit of those recoveries.