Kopernik Global Investors, LLC: investment adviser

Kopernik’s principal owner is Kopernik Holdings, LLC. Mr. Iben is the principal owner of Kopernik Holdings, LLC. Kopernik is organized to ensure a culture of client success. In an effort to ensure alignment with our clients, our senior professionals have meaningful investment in our investment funds, most employees have some investment in our funds, we are 100% employee-owned (through Kopernik Holdings, LLC), most of our employees have an ownership stake, and all employees are eligible to participate in the success of Kopernik. As of June 30, 2026, Kopernik managed over $9.70 billion in regulatory assets under management. In addition to the regulatory assets under management listed above, Kopernik advised an additional $206.87 million in advisory only services assets (please refer to Item 4.B. for a description of advisory only services). B. Description of Advisory Services Kopernik implements its global investment strategies through an active, fundamentals-based, valueoriented process. Kopernik’s investment discipline seeks to identify potential investments that trade at significant discounts to their intrinsic value (as determined by Kopernik’s analysis). For investment strategies that permit short positions, Kopernik will short securities of companies that Kopernik believes are overvalued by the market, with an emphasis on securities selling at significant premiums to their intrinsic values (as determined by Kopernik’s analysis). Kopernik typically invests in equity securities, with large, mid- or small capitalizations, but may invest in other securities such as bonds, commodities, currencies, derivatives and other financial instruments. Kopernik invests in securities issued by companies domiciled in developed markets as well as emerging and frontier markets. For additional information regarding Kopernik’s investment strategies, please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Kopernik provides investment advisory services to three main types of clients: (i) registered investment companies, (ii) institutional asset management clients: separately managed accounts, unregistered investment companies, a bank collective investment trust, and other collective investment vehicles,

and (iii) other advisors (on a sub-advisory basis). Kopernik offers separately managed accounts to pension plans, charitable organizations, educational institutions, high net worth individuals, trusts, estates, corporations and other business entities, banks and thrift institutions, insurance companies, foreign sovereigns and domestic governmental entities. For additional information regarding Kopernik’s clients, please refer to Item 7 - Types of Clients. Kopernik’s investment decisions and advice with respect to each investment vehicle (“Fund”) or account it manages are subject to that Fund’s or account’s investment objectives and guidelines, as set forth in its offering documents or investment management agreement. Services for Registered Investment Companies Subject to the supervision of each client’s board of directors or trustees, Kopernik provides management and certain related administrative services necessary for the operation of registered investment company clients, including Kopernik Global All-Cap Fund and Kopernik International Fund. Kopernik’s responsibilities include, without limitation, investment advisory services, research services, recommending and placing of orders for the purchase and sale of securities for registered investment company client portfolios (based on the investment objectives and guidelines of each client), working with custodians, transfer and pricing agents, accountants, auditors, underwriters and other persons, and furnishing reports, evaluations and analysis on a variety of subjects. Institutional Asset Management Services Kopernik provides asset management and related services to the institutional market. Kopernik manages separately managed accounts for institutional investors, unregistered investment funds and other collective investment vehicles. The strategies, policies, and procedures governing these accounts and collective investment vehicles are generally similar, but not necessarily identical, to those of Kopernik’s registered investment company clients. Kopernik currently provides investment advisory services to a number of privately-offered unregistered investment funds (collectively, the “Kopernik Private Funds”). Securities of the Kopernik Private Funds are offered to eligible investors exclusively on a private placement basis. The Kopernik Private Funds include the following open-end funds: Kopernik Global All-Cap Fund, LP and Kopernik Global Unconstrained Fund, LP, which are both Delaware limited partnerships, and Kopernik Global All-Cap Offshore Fund, Ltd. and Kopernik Global Unconstrained Offshore Fund, Ltd., which are Cayman Islands exempted companies. Kopernik Global All-Cap Fund, LP and Kopernik Global AllCap Offshore Fund, Ltd. invest in Kopernik Global All-Cap Master Fund, LP. Similarly, Kopernik Global Unconstrained Fund, LP and Kopernik Global Unconstrained Offshore Fund, Ltd. invest in Kopernik Global Unconstrained Master Fund, LP. In addition, Kopernik advises the Kopernik Global Long-Term Opportunities Fund, LP, which is organized as a Guernsey limited partnership and

Kopernik Global Long-Term Opportunities Fund, Limited, a Guernsey Non-Cellular Company, which invests in Kopernik Global Long-Term Opportunities Fund, LP. Kopernik provides investment advisory services to funds in the Kopernik Global Collective Investment Trust (collectively, the “CITs”) including the Kopernik Global All-Cap CIT and Kopernik International CIT, which are available only to certain eligible plans and exempt from registration under the Investment Company Act of 1940. The portfolios are offered by SEI Trust Company, the trustee, based on investment advice of Kopernik, the trust investment adviser. Sub-Advisory Services Kopernik provides sub-advisory services to other investment advisers, which may include those located outside the United States and those with large sub-advisory fund platforms. The strategies and policies and procedures governing these mandates are currently similar to those of Kopernik’s Global All-Cap Strategy. Kopernik also acts as sub-adviser to Kopernik Global All-Cap Equity Fund (the “UCITS”), a sub-fund (portfolio) of Heptagon Fund ICAV, which is an investment company operating pursuant to the European Union’s UCITS (Undertakings for Collective Investment in Transferable Securities) Regulations. Advisory Only Services Kopernik provides advisory only services whereby Kopernik delivers, to a third-party, model investment portfolios where Kopernik provides a list of recommended investments and weightings for consideration by the client. Kopernik is not responsible for arranging or effecting the purchase or sale of the recommended investments and model weightings, nor does Kopernik control the implementation of investment decisions. C. Availability of Customized Services for Clients For separately managed accounts, Kopernik tailors its investment advisory services to the specific needs of clients. A client may select an investment strategy with existing, standard investment guidelines and request reasonable restrictions on the management of its account. If Kopernik agrees to those restrictions, it will manage the account in accordance with the revised investment guidelines. Kopernik will not be able to accommodate proposed investment restrictions that are onerous or incompatible with Kopernik’s standard investment strategies and investment philosophy, and Kopernik may decline to accept or terminate client accounts with such restrictions. D. Wrap Fee Programs Not Applicable. Kopernik does not participate in any wrap fee programs.

Registered investment company fees, and the terms of any waiver, are disclosed in the applicable Fund prospectus. Kopernik currently assesses annual management fees of approximately 90 basis points for its registered investment company clients, Kopernik Global All-Cap Fund and Kopernik International Fund. Kopernik has agreed to reduce its fees and/or reimburse expenses in order to keep the Total Annual Fund Operating Expenses from exceeding certain levels, as contractually agreed upon by Kopernik. Investment management agreements between Kopernik and registered investment company clients may be terminated at any time on specified notice, without the payment of any penalty, by the board of directors or trustees of the investment company. The agreements automatically terminate in the event of their assignment. Separate Account Fees The standard fee schedules charged by Kopernik for separate accounts are based on a percentage of the quarterly or average monthly net assets of each account and vary by strategy and mandate. The minimum account size for a separately managed account is generally not less than $25 million. Standard fees shown below may be replaced with a different base fee and may add a performance fee. Performance-based fees create an incentive to favor those accounts over non-performance fee accounts. See Item 6 – Performance-Based Fees and Side-By-Side Management for additional information on how Kopernik seeks to address this potential conflict. Generally, fees for separately managed accounts are billed quarterly, but the exact timing of billing and payment for separately managed accounts is negotiable.

Strategy of Account

Management Fee*

Investment Minimum*

Global All-Cap

25 bps, subject to a performance fee $25 million which may include a lock-up period; or First $50 million 80 bps Next $100 million 75 bps Next $100 million 70 bps Next $100 million 65 bps Over $350 million 60 bps with no performance fee.

Global Unconstrained

25 bps, subject to a performance fee $25 million which may include a lock-up period.

Global Long-Term Opportunities

50 bps, subject to a performance fee which includes a lock-up period

International

25 bps, subject to a performance fee $25 million which may include a lock-up period; or

$50 million

First $50 million 80 bps Next $100 million 75 bps Next $100 million 70 bps Next $100 million 65 bps Over $350 million 60 bps with no performance fee. Global Opportunities

25 bps, subject to a performance fee $25 million which may include a lock-up period; or First $50 million 80 bps Next $100 million 75 bps Next $100 million 70 bps Next $100 million 65 bps Over $350 million 60 bps with no performance fee.

* Subject to Kopernik’s discretion. Kopernik offers no assurance that any particular fee, or other terms, will be the same for all clients or investors. Global All-Cap has soft closed to new investors effective April 30, 2026. Private Fund Fees Kopernik acts as an investment adviser to the Kopernik Private Funds and deducts fees for its services from each Fund’s assets at a disclosed rate. Fees for such services are summarized below and are set

forth in more detail in the applicable private placement memorandum. Fees and compensation paid to Kopernik or its affiliates by these funds are deducted from the assets of the applicable Fund. With certain exceptions, such as for partial periods, management fees for the Kopernik Private Funds are deducted on a monthly basis and paid to the Adviser quarterly. Incentive compensation, if any, is accrued monthly, and crystallizes and is paid annually, or upon withdrawal. Unregistered investment funds may have higher expenses than large separate accounts because the funds have certain administrative and fund expenses, and expense levels involve other considerations such as structuring, regulatory reporting, and external costs, that do not necessarily exist for separate accounts. However, specific expenses may be affected by the nature of the separate account or Fund, risks to the advisory firm, and strategic or other commercial considerations. Unregistered investment funds each have their own investment guidelines, as described in their offering materials, have periodic or otherwise limited opportunities for admissions and withdrawals, and will typically have minimum investment levels of at least $1 million, which may be waived in Kopernik’s discretion. Kopernik has created several “feeder” funds, whose primary purpose is to invest in a “master” investment fund. Investors in each feeder fund pay the expenses associated with maintaining both the feeder fund and, indirectly, a portion of the expenses associated with the master fund, as set forth in the private placement memorandum or other relevant offering document and/or applicable governing or operating agreement. Strategy of Private Fund

Annual Management Fee*

Investment Minimum**

Global All-Cap#

25 bps, based on the class of interests, subject to a performance fee which may include a lock-up period; or

$1 million

First $50 million 75 bps Next $100 million 70 bps Next $100 million 65 bps Over $250 million 60 bps with no performance fee. Global Unconstrained

25 bps, based on the class of interests, subject to a performance fee which may include a lock-up period.

$1 million

Global Long-Term Opportunities##

50 bps, subject to a performance fee which includes a lock-up period

$1 million

* Subject to Kopernik’s discretion. Kopernik offers no assurance that any particular fee, or other terms, will be the same for all clients or investors. ** Investment Minimums may be waived in Kopernik’s discretion.

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Global All-Cap has soft closed to new investors effective April 30, 2026. Global Long-Term Opportunities is not accepting new investments effective December 31, 2025.

Management and performance fees, and lock-up provisions for certain classes of interests, are described in more detail in the applicable private placement memorandum for a Fund. The management fee and performance fee applicable to a particular investor is subject to Kopernik’s discretion, and the funds may offer additional classes of the funds or additional newly-formed funds that offer different fee rates and other terms. Additionally, Kopernik may choose to waive all or a portion of a Kopernik Private Fund’s fees at its sole discretion. Kopernik Collective Investment Trust A Trustee Fee for each Kopernik CIT is disclosed in the trust’s offering documents for the relevant share class and comprises (i) the normal operating fees and expenses of the Kopernik CIT; (ii) compensation to the Trustee (SEI Trust Company) for the fiduciary services provided by the Trustee; and (iii) compensation to Kopernik for the investment advisory and administrative services provided by Kopernik to the CIT. Generally, the Trustee Fee for the CIT is currently between 95 and 90 basis points of assets under management, depending upon the particular share class. Kopernik receives a portion of the Trustee Fee for the investment advisory and administrative service provided by Kopernik to the CIT. Sub-Advisory Fees Sub-advisory fees or fees otherwise payable to Kopernik by another investment adviser are generally determined between Kopernik and the investment adviser of the account for which Kopernik will serve as sub-adviser. These fees are based on a percentage of assets under management and may also include a performance-based fee. Kopernik expects sub-advisory fees to be similar to those of separately managed accounts, but they can be higher or lower for various reasons such as an increase or decrease in administrative burdens, size of asset base, any effect on investment processes, or strategic or other commercial considerations of both Kopernik and the other investment adviser. Negotiated Fees From time to time, Kopernik enters into fee arrangements that, in light of a particular investor’s special circumstances or other factors, can result in fee schedules that differ from the standard fee schedules described above. Such circumstances may include, without limitation, a pre-existing relationship; service levels; special investment guidelines; Kopernik’s level of assets at time of investment; whether a new account is expected to grow rapidly; the number of different accounts and total assets under management for that client (and its affiliates); and other circumstances or factors that Kopernik deems relevant. Kopernik may choose to waive all or a portion of a client’s fees, including the fees of a

Kopernik Private Fund, at its sole discretion. Additionally, accounts of Kopernik employees and affiliates are generally managed without a management or performance fee. Securities Valuation Kopernik’s fee is calculated based upon the value of a client’s portfolio. Kopernik has the ability to recommend the value of securities and other financial instruments (“Securities”) that are difficult to price, and in such cases has an incentive to select the highest potential price for those securities, although a lower price might also be reasonable. To mitigate that potential conflict, Kopernik maintains a Valuation Committee responsible for overseeing the valuation process, including the valuation services provided by SEI Global Services, Inc. These services may include, but are not limited to, obtaining prices for positions in Client Portfolios, fair valuations, performance, and/or NAV calculation for Kopernik Client Portfolios. If the Valuation Committee determines that there is no market value for a Security, or that the market value does not accurately represent fair value for the Security, then the Valuation Committee must follow specific steps and procedures to calculate the fair value of the Security which may include inputs and methodologies provided by, among others, thirdparty independent pricing agents, independent broker dealers and or Kopernik’s own personnel (including investment personnel). B. Clients’ Fees and Expenses Beyond Management Fees Clients, rather than Kopernik, bear transaction costs related to buying and selling Securities. In addition, clients incur certain other charges such as charges imposed by custodians, brokers (including brokerage commissions, dealer markups and other expenses incurred in the acquisition or disposition of Securities), distributors, and other third parties such as for custodial fees, bank service fees, clearing and settlement charges, withholding and transfer fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, other fees and taxes on brokerage accounts and Securities transactions, and professional fees and expenses (including, without limitation, expenses of legal counsel, accountants, consultants and experts) relating to Securities. Funds may bear other expenses, typically disclosed in the applicable offering documents. Accounts that permit use of margin or short sales of Securities or other borrowing will incur interest on margin accounts and other indebtedness; costs, including interest expense and commitment fees, connected to selling Securities short; and borrowing charges on Securities sold short. When a fund or account invests in other investment companies and pooled vehicles such as mutual funds and exchange traded funds, the fund or account bears a proportionate share of expenses charged by the investment company or pooled vehicle in which it invests. The charges, fees and commissions discussed above are exclusive of and in addition to Kopernik’s management fee, and Kopernik does not receive any portion of these commissions, fees, and costs. Kopernik also will use “soft dollars” generated by client transactions to pay for brokerage (i.e. effecting securities transactions) and research products and services (i.e., advice, analysis and reports) for clients,

consistent with Kopernik’s best execution and soft dollar policy and with Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”). See Item 12 – Brokerage Practices for more information on the Firm’s use of soft dollars. Investors in Kopernik funds will bear all of the expenses set forth above, plus the following additional expenses to the extent permitted under the applicable prospectus or offering documents: third-party fund administrator fees and expenses; pricing costs; fund accounting and recordkeeping expenses; acquired fund fees, legal, accounting, audit and tax preparation expenses; expenses of partnership, company or investor meetings, corporate licensing fees; organizational and offering expenses; costs of filing reports with regulatory bodies; costs of the maintenance of insurance premiums; compensation paid to sub-advisors; other similar expenses; and any extraordinary expenses (including, without limitation, extraordinary litigation expenses and extraordinary consulting expenses). Depending on the class of mutual fund shares, investors in Kopernik-managed mutual funds also pay Rule 12b-1 distribution and/or servicing fees and sales loads.

C. Additional Compensation and Conflicts of Interest Kopernik does not accept compensation, such as brokerage commissions, for the sale of securities or other investment products. Our employees are eligible to earn an account referral bonus for referring a potential client or investor to Kopernik. Kopernik’s management determines whether an employee’s involvement was significant enough to warrant this bonus. Certain employees may not be eligible for an account referral bonus due to a conflict of interest or other reasons determined by Kopernik’s management.

To further ensure consistency among accounts, Kopernik generally prohibits its portfolio managers from simultaneously holding a long position in one account and holding the same Security short in another account with the same investment objective or strategy. Contrary positions may be permitted in circumstances where a client has instructed the investment adviser to hold a legacy position (e.g., a Security with a low-cost basis) or otherwise with approval, which may be granted on an ongoing basis. Accounts with different objectives or employing different strategies can result in different investment decisions based on the individual needs of the relevant client account. For those client relationships that involve Kopernik providing a model investment portfolio to the client (also referred to as “Advisory Only Services”), there is no mechanism and no responsibility to ensure consistency among these Advisory Only Services clients and other Kopernik Clients for whom Kopernik has full investment discretion. The recommendations made in the model investment portfolio provided to the client generally reflect recommendations being made by Kopernik to, or investment advisory decisions made for, similarly situated discretionary clients of Kopernik. As such, it is possible that, depending on the particular circumstances surrounding an order, Kopernik discretionary clients may receive prices that are more favorable than those received by the Advisory Only Services clients. Furthermore, the timing or nature of any action taken by Kopernik with respect to Advisory Only Services may differ compared to Kopernik discretionary clients. In limited circumstances, Kopernik holds the same securities in its own proprietary corporate account as its client accounts. In this limited circumstance, Kopernik may choose to divest the security in order to manage its exposure to certain investments and may otherwise make different investment decisions and take other actions with respect to their proprietary accounts than those made for client accounts. Kopernik faces a conflict of interest as it will have income or other incentives to favor its own account.

In addition, Kopernik may provide advisory or sub-advisory services to additional unaffiliated open-end or closed-end investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”), collective investment trusts, separate accounts, and foreign collective investment funds, including, but not limited to, other UCITS funds.

The selection process is distinguished by industry specialization and fundamental analysis. Each of Kopernik’s research analysts continually evaluates companies within his or her coverage universe based upon a variety of both qualitative and quantitative criteria. Quantitative measures include price-to-earnings, price-to-book value, price-to-sales, price-to-net-present value, price-to-free cash flow, expectations of sustainable dividend payout, and price-to-liquidation/replacement value. Qualitative analysis assists the research team in producing an understanding of franchise quality, management strength, corporate strategy, barriers-to-entry, shareholder value orientation, industry supply and demand dynamics, and the company’s competitive advantage versus its peers operating in the same industry. Kopernik also integrates Environmental, Social and Governance (“ESG”) principles consistent with our overall investment approach (see Environmental, Social and Governance section below for further details). In addition, prior to investing in a company, Kopernik considers how liquid the Security is, both in the local market and in the U.S. if that company has an American or Global Depositary Receipt. Kopernik’s research process involves analyzing corporate filings (including annual reports, prospectuses, and other SEC or non-U.S. governmental or stock exchange filings), performing company visits, and speaking with various levels of company management, suppliers, competitors, customers and others to better understand the investment opportunities. Analysts attend conferences regularly and also utilize sell-side research information and analysis, including expert networks, on a limited basis. Kopernik regularly monitors newspapers, magazines, industry and trade journals, and other publications. Kopernik’s investment approach is highly collaborative. Investment professionals generally meet each business day as a team, or in smaller teams, to vet ideas and discuss portfolio holdings. During these meetings, analysts propose new investment ideas, present in-depth analysis on companies and industries, provide updates on existing portfolio holdings, and recommend appropriate investment ideas. Kopernik’s investment meetings elicit group input and rigorous debate and help ensure a consistent due-diligence process in selecting Securities.

Strategies Kopernik provides the following investment strategies in separately managed accounts and as investment adviser to collective investment funds, including, but not limited to, private funds, mutual funds, CITs, and UCITS, subject to each fund’s investment guidelines and restrictions. Strategy

Description

Global All-Cap

The Global All-Cap strategy seeks capital appreciation by investing in companies located throughout the world, including emerging and frontier markets, which Kopernik believes are trading at a significant discount to risk-adjusted intrinsic value.

Global Unconstrained

The Global Unconstrained strategy seeks absolute returns by taking long and short positions in companies located throughout the world, including emerging and frontier markets. Long positions are believed to be trading at a significant discount to risk-adjusted intrinsic value. Short positions are believed to be trading at a significant premium to risk-adjusted value. This strategy may also use margin.

Global Long-Term Opportunities

Global Long-Term Opportunities, a global crossover strategy, seeks long-term positive real returns by investing in companies located throughout the world, including emerging and frontier markets, which Kopernik believes are trading at a significant discount to their risk-adjusted intrinsic values. In conjunction with its public equity investments, the strategy also invests in real assets including, but not limited to, commodities, natural resources, and streams and/or royalties. This includes low liquidity securities which may consist of smaller capitalization companies, non-publicly traded companies, and companies that have a smaller percentage of total common shares outstanding that are freely traded (or “free float”).

International

The International strategy seeks long-term capital appreciation by investing in mid- to large-cap equities across developed, emerging, and frontier markets (domiciled outside of the U.S.) which Kopernik believes are trading at significant discounts to their riskadjusted intrinsic values. The strategy may invest up to 15% of its assets in U.S. domiciled businesses that have significant business activities outside the United States, as determined by Kopernik. Generally, the strategy does not invest in issuers with market capitalizations below $2 billion, as measured at time of purchase. The Global Opportunities strategy seeks capital appreciation by investing in small / mid- to large-cap equities across the world including emerging and frontier markets, which Kopernik believes

Global Opportunities

are trading at a significant discount to their risk-adjusted intrinsic values. Generally, the strategy does not invest in issuers with market capitalization below $3 billion, as measured at time of purchase. None of the foregoing investment strategies is designed or anticipated to track the performance of any specific benchmark. Additional Information Concerning Kopernik Strategies Each of the above strategies may invest in a variety of Securities. Each strategy may invest in common and preferred stocks, convertible securities, rights and warrants received in connection with securities held in the portfolio, debt secured by mortgages or other assets, debt securities issued by foreign and supranational issuers, debt secured by loans and other fixed income securities, real estate investment trusts (“REITs”), ETFs, swap agreements, options, forward contracts, structured notes and other financial instruments. Debt may be rated below investment grade (i.e., high yield). Securities of companies with all market capitalizations may be included in the portfolio (subject to strategy guidelines), including small-to-mid capitalization companies. Some of these securities could give rise to unrelated business taxable income from time to time. Potential investors should consult their tax advisors regarding the tax implications of such investments. Subject to applicable investment guidelines, a portion of a strategy’s assets will be invested in nondollar denominated securities of non-U.S. issuers and in dollar-denominated equity securities of nonU.S. issuers that are either listed on a U.S. stock exchange or represented by depositary receipts that may or may not be sponsored by a domestic bank. Strategies may also invest in warrants and securities convertible or exchangeable for equity securities such as convertible bonds. Again, subject to applicable guidelines, each strategy may use derivatives, specifically options, index options, interest rate caps, collars, futures contracts, options on futures contracts, and forward non-U.S. currency exchange contracts. In addition, strategies may invest in derivatives such as swaps, including interest rate swaps, total return swaps, swaptions, credit default swaps and non-U.S. currency swaps, as well as other derivatives, such as participatory notes and equity-linked securities. Strategies may write (sell) call options or buy put options on an index, or on some or all of the stocks or other securities they invest in, as well as using call spreads or other types of options. A strategy may invest in stock index futures contracts, options on stock indices, and options on stock index futures. In addition, forward contracts may be used. Investments in these types of investments are not suitable for all investors as they are speculative and carry a high degree of risk. Subject to and depending upon applicable investment guidelines, each strategy may also invest, if eligible, in Rule 144A Securities, Regulation S (Reg S) Securities, private placements, or other Securities that lack liquidity or a readily assessable market value. Each strategy may hold Securities that become illiquid after purchase due to market or other conditions. Private placements pose greater

liquidity risks than publicly traded securities. Mutual funds and UCITS managed or sub-advised by Kopernik are subject to specific statutory or regulatory limitations on illiquid Securities and Kopernik will abide by those stricter liquidity requirements. Although the open-end Kopernik Private Funds are not subject to any specific restrictions on the amount of assets that they may invest in illiquid Securities, Kopernik will selectively invest in such Securities and considers the liquidity of a Security in weighing the risks against the potential for profit presented by a particular investment opportunity for those Funds. In closed-end funds and separate accounts managed by Kopernik, Kopernik may invest a larger portion of client assets in illiquid Securities, subject to applicable investment guidelines. The Global Unconstrained Strategy may use leverage to take advantage of market opportunities. The use of leverage increases buying power. The strategy may borrow money from banks or brokerage firms, purchase securities on margin, as well as finance positions and lend funds through repurchase and reverse repurchase agreements. Kopernik’s strategies emphasize active management of a portfolio in order to take advantage of opportunities in the financial markets. As a result, turnover and brokerage commission expenses may exceed those of other portfolios of comparable size. Cash balances in Kopernik portfolios are a residual of the investment process. Kopernik may invest in longer-term debt instruments. The strategies may invest their excess funds in short-term investments, including U.S. or other Government securities, money market funds, commercial paper, certificates of deposit and bankers’ acceptances. Environmental, Social, and Governance (ESG) Practices Kopernik takes an active approach to addressing corporate governance and fulfilling its fiduciary duties. Rather than passively avoiding certain companies, we prefer to engage companies, where possible, to promote positive change in their treatment of Environmental, Social, and Governance (ESG) issues. We do not do this for altruistic reasons; rather, we believe such practices manage risk and increase shareholder value over the long term. As stewards of capital, we look to invest in companies that can deliver favorable risk-adjusted returns on a sustainable basis. Our investments must meet our stringent value-oriented investment guidelines. It is our belief that sound ESG practices are important in maintaining and growing the intrinsic value of the underlying business. Our philosophy on corporate sustainability and ESG practices is consistent with our overall investment approach, stemming from the conviction that the companies in which we invest should act ethically and in the best interest of all corporate stakeholders across the value chain, including the following: employees, customers, suppliers, the environment, community members, the government, and shareholders. It seems intuitive that companies that practice these values are more

likely to attract and retain top-notch employees, loyal and satisfied customers, and welcoming communities. They are less likely to encounter opposition and appropriations. In 2018, Kopernik signed on to the United Nations-supported Principles for Responsible Investment (PRI), a leading global network for investors who are committed to integrating ESG considerations into their investment practices and ownership policies. We believe in their goal of increasing transparency and specifically requesting that companies maintain publicly available reporting on ESG policies.

B. Material, Significant or Unusual Risks Relating to Investment Strategies. The following risk factors do not purport to be a complete list or explanation of the risks involved in Kopernik’s investment strategies. These risk factors include those risks Kopernik believes to be material, significant or unusual and relate to significant investment strategies or methods of analysis employed by Kopernik. The risks, as listed below, do not appear in any particular order of importance. Market Risk. The risk that the price of equity securities may decline in response to general market and economic conditions or events. The value of the equity securities may decline over short or extended periods of time. Any stock is subject to the risk that the stock market as a whole may decline in value, thereby depressing the stock’s price. Equity markets tend to be cyclical, with periods when prices generally rise and periods when prices generally decline. Foreign equity markets tend to reflect local economic and financial conditions, and therefore, trends often vary from country to country and region to region. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. Any such impact could adversely affect the prices and liquidity of the securities and other instruments in which Kopernik invests on its clients’ behalf, which in turn could negatively impact the performance of client accounts and cause losses in client accounts. Equity Risk. Equity securities include public and privately issued equity securities, common and preferred stocks, convertible securities and depositary receipts. Common stock represents an equity or ownership interest in an issuer. Preferred stock provides a fixed dividend that is paid before any dividends are paid to common stock holders, and which takes precedence over common stock in the event of a liquidation. Like common stock, preferred stocks represent partial ownership in a company, although preferred stock shareholders do not enjoy any of the voting rights of common stockholders. Also, unlike common stock, a preferred stock pays a fixed dividend that does not fluctuate, although the company does not have to pay this dividend if it lacks the financial ability to do so. The value of securities convertible into equity securities, such as convertible debt, is also affected by prevailing interest rates, the credit quality of the issuer and any call provision. Depositary receipts risk is discussed below. Investments in equity securities in general are subject to market risks that may cause their prices

to fluctuate over time. Any such impact could adversely affect the prices and liquidity of the securities and other instruments in which Kopernik invests, which in turn could negatively impact fund or account performance and cause losses for Kopernik clients. An investment in a portfolio of equity securities may be more suitable for long-term investors who can bear the risk of these share price fluctuations. Since it purchases equity securities on behalf of its clients, Kopernik’s portfolios are subject to the risk that stock prices will fall over short or extended periods of time. Historically, the equity markets have moved in cycles, and the value of clients’ equity securities may fluctuate drastically from day to day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. Actual or threatened war or armed conflicts, acts of terrorism, social or political unrest, the imposition of tariffs and other restrictions on trade, sanctions, government defaults, government shutdowns, and other facts could affect the securities market. In addition, the impact of any epidemic, pandemic, or natural disaster, or widespread fear that such events may occur, could negatively affect the global economy, as well as the economies of individual countries, the financial performance of individual companies and sectors, and the markets in general in significant and unforeseen ways. Any such impact could adversely affect the prices and liquidity of the securities and other instruments in which Kopernik invests, which in turn could negatively impact portfolio performance and causes losses in client accounts. These factors contribute to price volatility, which is the principal risk of investing with Kopernik. Company Risk. The risk that the issuer’s earnings prospects and overall financial position will deteriorate, causing a decline in the security’s value over short or extended periods of time. Foreign Securities—Foreign securities are securities issued by non-U.S. issuers. Investments in foreign securities may subject Kopernik clients to investment risks that differ in some respects from those related to investments in securities of U.S. issuers. Such risks include future adverse political and economic developments, possible imposition of withholding taxes on income, possible seizure, nationalization or expropriation of foreign deposits, possible establishment of exchange controls or taxation at the source or greater fluctuation in value due to changes in the exchange rates. Foreign issuers of securities often engage in business practices different from those of domestic issuers of similar securities, and there may be less information publicly available about foreign issuers. In addition, foreign issuers are, generally speaking, subject to less government supervision and regulation and different accounting treatment than are those in the U.S. Foreign branches of U.S. banks and foreign banks may be subject to less stringent reserve requirements than those applicable to domestic branches of U.S. banks. The value of the Kopernik’s clients’ investments denominated in foreign currencies will depend on the relative strengths of those currencies and the U.S. dollar, and the Kopernik’s clients may be affected favorably or unfavorably by changes in the exchange rates or exchange or currency control regulations between foreign currencies and the U.S. dollar. Changes in foreign currency exchange rates also may

affect the value of dividends and interest earned, gains and losses realized on the sale of securities and net investment income and gains, if any. Such investments may also entail higher custodial fees and sales commissions than domestic investments. Investments in emerging and frontier markets can be considered speculative, and therefore may offer higher potential for gains and losses than investments in developed markets of the world. With respect to an emerging or frontier market country, there may be a greater potential for nationalization, expropriation or confiscatory taxation, political changes, government regulation, social instability or diplomatic developments (including war) which could affect adversely the economies of such countries or investments in such countries. The economies of developing countries generally are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange or currency controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade.

In addition to the risks of investing in emerging and frontier market country debt securities, investments in government or government-related securities of emerging and frontier market countries and restructured debt instruments in emerging and frontier markets are subject to special risks, including the inability or unwillingness to repay principal and interest, requests to reschedule or restructure outstanding debt, and requests to extend additional loan amounts. Kopernik may have limited recourse in the event of default on such debt instruments. Periodic U.S. Government restrictions on investments in issuers from certain foreign countries may result in Kopernik having to sell such prohibited securities at inopportune times. Such prohibited securities may have less liquidity as a result of such U.S. Government designation and the market price of such prohibited securities may decline, which may cause Kopernik’s clients to incur losses. Given the increasing interdependence among global economies and markets, conditions in one country, region or market might adversely affect financial conditions or issuers in other countries, regions or markets. For example, on January 31, 2020, the United Kingdom (the “UK”) formally withdrew from the European Union (the “EU”) (commonly referred to as “Brexit”). Following a transition period, the UK and the EU signed a post-Brexit trade agreement governing their future economic relationship on December 30, 2020. This agreement became effective on a provisional basis on January 1, 2021 and formally entered into force on May 1, 2021. While the full impact of Brexit is unknown, Brexit has already resulted in volatility in European and global markets. The effects of Brexit on the UK and EU economies and the broader global economy could be significant, resulting in negative impacts, such as business and trade disruptions, increased volatility and illiquidity, and potentially lower economic growth of markets in the UK, EU and globally, which could negatively impact the value of Kopernik’s client investments. Brexit could also lead to legal uncertainty and politically divergent national laws and regulations while the new relationship between the UK and EU is further defined and the UK determines which EU laws to replace or replicate. Additionally, depreciation of the British pound sterling and/or the euro in relation to the U.S. dollar following Brexit could adversely affect investments denominated in the British pound sterling and/or the euro, regardless of the performance of the investment.

In addition, on February 24, 2022, Russian military forces invaded Ukraine, significantly amplifying already existing geopolitical tensions among Russia, Ukraine, Europe, NATO, and the West. Following Russia’s actions, various countries, including the U.S., Canada, the UK, Germany, and France, as well as the EU, issued broad-ranging economic sanctions against Russia. The sanctions consist of the prohibition of trading in certain Russian securities and engaging in certain private transactions, the prohibition of doing business with certain Russian corporate entities, large financial institutions, officials and oligarchs, and the freezing of Russian assets. The extent and duration of the war in Ukraine and the longevity and severity of sanctions remain unknown, but they could have a significant adverse impact on the European economy as well as the price and availability of certain commodities, including oil and natural gas, throughout the world. These sanctions, and the resulting disruption of the Russian economy, may cause volatility in other regional and global markets and may negatively impact the performance of various sectors and industries, as well as companies in other countries, which could have a negative effect on the performance of Kopernik client accounts, even if a Kopernik client account does not have direct exposure to securities of Russian issuers. Whether or not Kopernik invests in securities of issuers located in Europe or with significant exposure to European issuers or countries, these events could negatively affect the value and liquidity of Kopernik’s investments due to the interconnected nature of the global economy and capital markets. Similarly, armed conflict between Israel and Hamas and other militant groups in the Middle East and related events could cause significant market disruptions and volatility. This conflict could disrupt regional trade and supply chains, potentially affecting U.S. businesses with exposure to the region. Additionally, the Middle East plays a pivotal role in the global energy sector, and prolonged instability could impact oil prices, leading to increased costs for businesses and consumers. These and any related events could significantly impact Kopernik’s performance and the value of an investment in a Kopernik client account, even if the Kopernik client account does not have direct exposure to affected issuers. Investments in China. China is an emerging market, and as a result, investments in securities of companies organized and listed in China may be subject to liquidity constraints and significantly higher volatility, from time to time, than investments in securities of more developed markets. China may be subject to considerable government intervention and varying degrees of economic, political and social instability. These factors may result in, among other things, a greater risk of stock market, interest rate, and currency fluctuations, as well as inflation. Accounting, auditing and financial reporting standards in China are different from U.S. standards and, therefore, disclosure of certain material information may not be made, may be less available, or may be less reliable. It may also be difficult or impossible for Kopernik to obtain or enforce a judgment in a Chinese court. In addition, periodically there may be restrictions on investments in Chinese companies. For example, on November 12, 2020, the President of the United States signed an Executive Order (the “November 2020 Executive Order”) prohibiting U.S. persons from purchasing or investing in publicly-traded securities of companies identified by the U.S. Government as “Communist Chinese military companies” or in instruments that are derivative of, or are designed to provide investment exposure to, those companies. In addition, on August 9, 2023, the President of the United States signed an Executive Order (the “August 2023 Executive Order” and, together with the November 2020 Executive Order, the “Executive Orders”) directing the U.S. Department of the Treasury (the “Treasury”) to promulgate regulations requiring notification of, or restricting, investments in China in certain categories of national security technologies, including semiconductors and microelectronics, quantum information, and certain artificial intelligence

technologies. Concurrent with the August 2023 Executive Order, the Treasury issued an Advance Notice of Proposed Rulemaking which contemplates the possibility that the regulations adopted would not apply to investments made by collectively offered fund. These regulations have not yet been proposed or adopted by the Treasury and their scope and impact therefore are unclear, but if they were adopted in a way that applies to a collectively offered fund, the regulations could adversely affect the fund’s ability to make certain outbound investments. The universe of securities affected by the Executive Orders can change from time to time. As a result of an increase in the number of investors looking to sell such securities, or because of an inability to participate in an investment that Kopernik otherwise believes is attractive, a Kopernik client account may incur losses. Certain securities that are or become designated as prohibited securities may have less liquidity as a result of such designation and the market price of such prohibited securities may decline, potentially causing losses to a Kopernik client account. In addition, the market for securities of other Chinese-based issuers may also be negatively impacted, resulting in reduced liquidity and price declines. Correlation Risk. The risk that global events will cause the U.S. and non-U.S. markets to move in the same direction, reducing or eliminating the benefit of international diversification. U.S. and non-U.S. markets often rise and fall at different times or by different amounts due to economic or other developments particular to a given country or region. Thus, investing in both U.S. and non-U.S. markets may lower portfolio volatility. Currency Risk. Accounts normally will be denominated in U.S. dollars. However, many investments may be denominated in non-U.S. currencies. In addition, some or all of the underlying assets of collateralized securities held may consist of loans or other instruments of obligors in countries other than the United States, and consequently may be denominated in currencies other than the U.S. dollar. Changes in the rates of exchange between the U.S. dollar and other currencies could have a material adverse effect on the performance of investments. A strong U.S. dollar relative to other currencies will adversely affect the value of securities or instruments denominated in non-U.S. currencies and hinder performance. In addition, a particular foreign country may impose exchange controls, devalue its currency and/or take other measures relating to its currency which could adversely affect investors. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. Finally, clients may incur costs in connection with conversions between various currencies. Although Kopernik may have the ability to hedge currency risk associated with a portion of investments denominated in currencies other than the U.S. dollar, it may not do so. Style Risk. The risk that securities selected using either a growth investing or a value investing style may be out of favor in the marketplace for various periods of time. Kopernik’s strategies are managed according to a value investment style. Investors holding value investing style securities may experience declines in the value of their portfolios. In addition, although Kopernik believes in value investing,

securities believed to be undervalued are subject to the risks that: (1) the issuer’s potential business prospects are not realized; (2) their potential values are never recognized by the market; and (3) due to unanticipated or unforeseen problems associated with the issuer or industry, they were appropriately priced (or over-priced) when acquired. Volatility. The risk that the value of Securities may fluctuate significantly over a short period of time. Investors should understand that the results of a particular period will not necessarily be indicative of results in future periods. Changes in the degree of volatility of the market from Kopernik’s expectations may produce material losses. Portfolio Turnover Rate Risk. A strategy that engages in active and frequent trading of portfolio Securities will have a correspondingly higher “portfolio turnover rate.” A high portfolio turnover rate will generally result in (1) greater brokerage commission expenses and (2) higher amounts of realized investment gain potentially subject to the payment of taxes. None of the Kopernik strategies are subject to a specific limitation on portfolio turnover, and although Kopernik seeks to hold securities for substantial periods of time, securities may be sold at any time such sale is deemed advisable for investment or operational reasons. Credit Risk. The risk that a decline in an issuer’s financial position may prevent it from making principal and interest payments on fixed income securities when due. Credit risk relates to the ability of an issuer of a fixed-income security to pay principal and interest on the security on a timely basis and is the risk that the issuer could default on its obligations, thereby causing the value of the investment to be materially impaired. Default Risk. The risk of default by the issuers of debt securities. Investments may consist of instruments that are low rated or unrated. Emerging and frontier markets debt securities may consist of instruments that are generally considered to have a credit quality rated below investment grade by internationally recognized credit rating organizations such as Moody’s and Standard & Poor’s. Noninvestment grade securities (i.e., rated Ba1 or lower by Moody’s or BB+ or lower by Standard & Poor’s) are speculative with respect to the issuer’s capacity to pay interest and repay principal in accordance with the terms of the obligations and involve significant risk exposure to adverse conditions. To the extent that any issuers default upon their obligations, the rate of return on investment will be adversely affected. Interest Rate Risk. The risk that the value or yield of fixed-income securities may decline if interest rates change. In general, when prevailing interest rates decline, the market value of fixed-income securities (particularly those paying a fixed rate of interest) tends to increase. Conversely, when prevailing interest rates increase, the market value of fixed-income securities (particularly those paying a fixed rate of interest) tends to decline. Depending on the timing of the purchase of a fixed-income security and the price paid for it, changes in prevailing interest rates may increase or decrease the security’s current yield. Interest rate risk is generally lower for shorter-term investments and higher for

longer-term investments: the longer the maturity of a bond, the greater the bond’s price sensitivity to changes in interest rates. Deflation Risk. The risk that prices throughout the economy decline over time, which may have an adverse effect on the market valuation of companies, their assets and revenues. Deflation may also have an adverse effect on the creditworthiness of issuers and may make issuer default more likely, which may result in a decline in the value of a portfolio. Inflation Risk. The risk that the value of assets or income from investments will be worth less in the future as inflation decreases the value of money. As inflation increases, the real value of an account and distributions can decline. Concentration/Diversification Risk. Subject to applicable investment guidelines, the risk that a strategy may be invested in a limited number of issuers, industries, sectors, countries, or regions. If a relatively high percentage of assets are invested in the securities of a limited number of issuers then certain economic, political or regulatory occurrences may adversely affect the portfolio more than a more diversified portfolio. Counterparty Risk. The risk that counterparties may encounter financial difficulties, fail, or otherwise become unable to meet their obligations. The strategies may invest in securities and derivatives that have institutional counterparties, including brokerage firms and banks; client assets may also be entrusted for custodial and prime brokerage purposes to such counterparties. Any such development could cause damaging losses, or even complete loss, of investors’ capital. Trading Suspensions. The risk that the United States, other governments, and each U.S. and non-U.S. Securities exchange may suspend or limit trading in Securities. Such a suspension might render it impossible for Kopernik to liquidate certain positions promptly and, accordingly, could cause portfolio losses. Short Selling. The Global Unconstrained strategy engages in the short-selling of Securities in addition to taking long positions. Short-selling is the selling of Securities the seller does not own. Short sales may only be maintained if the Securities can be borrowed. If the Security cannot remain borrowed, the portfolio could be required to cover the short sale at a loss or at an inopportune time. If Securities are sold short, the obligation to deliver such Securities can be fulfilled with borrowed securities. A portfolio would only profit from such a practice if it could fulfill its obligation to the lender of the Securities by repaying the lender with Securities which it has purchased at a price lower than the price received for the short sale. If the price of a Security that has been sold short increases, there is no limit to the loss that could be incurred in covering a short sale. Leverage; Interest Rates. The Global Unconstrained strategy may use leverage, including borrowing to buy Securities on margin or make other investments. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss.

A portfolio may also be leveraged by entering into reverse repurchase agreements whereby it effectively borrows funds on a secured basis by “selling” its interests in investments to a financial institution for cash and agreeing to “repurchase” such investments at a specified future date for the sales price paid plus interest at a negotiated rate. The Global Unconstrained strategy may also enter into arrangements to secure leverage whereby substantially all of its capital may be used for margin or collateral deposits. If the value of the portfolio’s investments falls below the margin or collateral level required by a lender, additional margin or collateral deposits would be required. If the portfolio were unable to satisfy any margin or collateral call by a lender, such lender could liquidate the portfolio’s position in some or all the investments that may be in the account at such lender and cause the portfolio to incur significant losses. The failure to satisfy a margin or collateral call, or the occurrence of other material defaults under financing agreements may trigger cross-defaults with other brokers, lenders, clearing firms or other counterparties, multiplying the adverse impact to a portfolio. In addition, because the use of leverage will cause a portfolio to enjoy the benefits of positions worth significantly more than its aggregate capital, the amount that the portfolio may lose in the event of adverse price movements will be high in relation to the amount of its capital. In the event of a sudden decrease in the value of a Global Unconstrained portfolio’s assets, that portfolio might not be able to liquidate assets quickly enough to satisfy its margin or collateral requirements. In that event, the portfolio may become subject to claims of financial intermediaries that extend credit. Such claims may exceed the value of the assets of the portfolio. The banks and brokerdealers that provide financing to the portfolio can apply discretionary margin, haircut, financing and collateral valuation policies. Changes by banks and dealers in any of the foregoing may result in large margin or collateral calls, loss of financing and forced liquidations of positions at disadvantageous prices. There can be no assurance that any Global Unconstrained portfolio will be able to secure or maintain adequate financing. Margin interest rates tend to fluctuate with interest rates generally, and the Global Unconstrained strategy is at risk that interest rates generally, and margin interest rates in particular, will increase, thereby increasing a portfolio’s expenses. The Global Unconstrained portfolio will bear the foregoing risks by employing leverage. Liquidity of Investments. The risk that investments will be long-term in nature and may require years before they are suitable for sale. Realization of value from such investments may be difficult in the short-term or may have to be made at a substantial discount compared to other freely tradable investments. Portfolios may be limited in their ability to liquidate or redeem investments to meet redemption requests or to pay expenses or fees. Illiquid Securities involve the risk that Kopernik will not be able to sell the investment in a timely way or at a fair price. Strategies may invest in illiquid Securities, including, but not limited to certain Rule 144A Securities, Regulation S (Reg S), or other private placements. These Securities may lack liquidity or a readily assessable market value. Strategies may also hold Securities that become illiquid after purchase due to market or other conditions, and as such, may continue to hold the illiquid security. Investments in illiquid Securities may restrict a

strategy’s ability to dispose of investments in a timely fashion and for a fair price and may impede Kopernik’s ability to take advantage of market opportunities. Distress Investing. From time to time political, economic and/or financial crises may occur in various countries and financial markets. In connection with such events, illiquidity and volatility in financial markets may significantly increase and prices of Securities may decline to values Kopernik deems significantly below their intrinsic value. Kopernik may seek to capitalize directly or indirectly on opportunities created by these distressed conditions. There is no assurance that Securities purchased in connection with such crises will recover. Access to Information. Kopernik selects investments on the basis of information and data filed by issuers with various government regulators or made directly available to Kopernik by the issuers or through sources other than the issuers. Although Kopernik evaluates all such information and data and seeks independent corroboration when it considers it is appropriate and reasonably available, Kopernik is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available because certain information may be considered proprietary or otherwise confidential. Some issuers may also provide information that is not accurate and such information may be relied upon by Kopernik. These difficulties make it more difficult for investments to be evaluated and for the value of securities to be accurately determined. Furthermore, Kopernik may not always be able to reallocate client assets in response to market changes because information about the particular investments may not be readily available at all times. Special Risks of Cyber Attacks. As with any entity that conducts business through electronic means in the modern marketplace, Kopernik, and its service providers, may be susceptible to operational and information security risks resulting from cyber attacks. Cyber attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized monitoring, release, misuse, loss, destruction or corruption of confidential information, unauthorized access to relevant systems, compromises to networks or devices that Kopernik and its service providers use to service its operations, operational disruption or failures in the physical infrastructure or operating systems that support Kopernik and its service providers, or various other forms of cyber security breaches. Cyber attacks affecting Kopernik or any other of its intermediaries or service providers may adversely impact Kopernik’s clients and shareholders, potentially resulting in, among other things, financial losses or the inability to transact business. For instance, cyber attacks may impact the release of private shareholder information or confidential business information, impede trading, subject Kopernik to regulatory fines or financial losses and/or cause reputational damage. Kopernik may also incur additional costs for cyber security risk management purposes designed to mitigate or prevent the risk of cyber attacks. Such costs may be ongoing because threats of cyber attacks are constantly evolving as cyber attackers become more sophisticated and their techniques become more complex. Similar types of cyber security risks are also present for issuers of securities in which Kopernik may invest, which could result in material adverse consequences for such issuers and may cause the investments in such companies to lose value. There can be no assurance that Kopernik,

its service providers, or the issuers of the securities in which Kopernik invests will not suffer losses relating to cyber attacks or other information security breaches in the future. Specific Risks of Certain Investments In addition to the general investment risks listed above, the strategies may make investments or use investment techniques that may create certain risks; some, but not all, of these risks are summarized below. The risks, as summarized below, do not appear in any particular order of importance. Small Capitalization and Mid-Capitalization Companies. Each strategy may, to the extent consistent with its investment policies, invest in small and mid-capitalization companies. Investments in small and mid-capitalization companies involve greater risk and portfolio price volatility than investments in larger capitalization stocks. Among the reasons for greater price volatility of these investments are the less certain growth prospects of smaller firms and the lower degree of liquidity in the markets for such securities. Small and mid-capitalization companies may be thinly traded and may have to be sold at a discount from current market prices or in small lots over an extended period of time. In addition, these securities are subject to the risk that during certain periods the liquidity of particular issuers or industries, or all securities in particular investment categories, will shrink or disappear suddenly and without warning as a result of adverse economic or market conditions, or adverse investor perceptions, whether accurate or not. In connection with the lack of market liquidity, a strategy may incur losses if it is required to effect sales at a disadvantageous time and only then at a substantial drop in price. Small and mid-capitalization companies include “unseasoned” issues that do not have an established financial history; often have limited product lines, markets or financial resources; may depend on or use a few key personnel for management; and may be susceptible to losses and risks of bankruptcy. Small and mid-capitalization companies may be operating at a loss or have significant variations in operating results; may be engaged in a rapidly changing business with products subject to a substantial risk of obsolescence; may require substantial additional capital to support their operations, to finance expansion or to maintain their competitive position; and may have substantial borrowings or may otherwise have a weak financial condition. In addition, these companies may face intense competition, including competition from companies with greater financial resources, more extensive development, manufacturing, marketing, and other capabilities, and a larger number of qualified and managerial personnel. Transaction costs for these investments are often higher than those of large capitalization companies. Investments in small and mid-capitalization companies may be more difficult to price precisely than other types of securities because of their characteristics and lower trading volumes. These risks may be heightened with respect to emerging and frontier market countries since political turmoil and rapid changes in economic conditions are more likely to occur in these countries. Depositary Receipts Risk. American Depositary Receipts (“ADRs”) are dollar-denominated depositary receipts typically issued by a U.S. financial institution that evidence an ownership interest in a security or pool of securities issued by a foreign issuer. ADRs are listed and traded in the U.S.

Global Depositary Receipts (“GDRs”) are similar to ADRs but represent shares of foreign-based corporations generally issued by international banks in one or more markets around the world. ADRs and GDRs are subject to the risks associated with investing directly in foreign securities, which are described below. In addition, investments in ADRs and GDRs may be less liquid than the underlying shares in their primary trading markets and GDRs, many of which represent shares issued by companies in emerging or frontier markets, may be more volatile. Depositary receipts may be sponsored or unsponsored. Holders of unsponsored depositary receipts generally bear all the costs associated with establishing unsponsored depositary receipts. In addition, the issuers of the securities underlying unsponsored depositary receipts are not obligated to disclose material information in the U.S., and, therefore, there may be less information available regarding such issuers, and there may not be a correlation between such information and the market value of the depositary receipts. Depositary receipts are subject to many of the risks associated with investing directly in foreign securities, including, among other things, political, social and economic developments abroad, currency movements, and different legal, regulatory and tax environments. There is no guarantee that a financial institution will continue to sponsor a Depository Receipt, or that a Depository Receipt will continue to trade on an exchange. Depository Receipts may be delisted by the issuer, exchange or pursuant to regulatory action. Preferred Securities. Preferred securities are subordinated to bonds and other debt instruments in a company’s capital structure and therefore will be subject to greater credit risk than those debt instruments. Preferred securities generally will decline in price or fail to make dividend payments when due because the issuer of the security experiences a decline in its financial status. Certain preferred securities carry provisions that allow an issuer under certain circumstances to skip distributions (in the case of “non-cumulative” preferred securities) or defer distributions (in the case of “cumulative” preferred securities). In certain circumstances, an issuer may redeem its preferred securities prior to a specified date in the event of certain tax or legal changes or at the issuer’s call, and the investor may not be able to reinvest the proceeds at comparable rates of return. Preferred securities typically do not provide any voting rights, except in cases where dividends are in arrears for a specified number of periods. Convertible Securities. Convertible securities generally offer lower interest or dividend yields than non-convertible fixed-income securities of similar credit quality because of the potential for capital appreciation. The market values of convertible securities tend to decline as interest rates increase and, conversely, to increase as interest rates decline. In the event of a liquidation of the issuing company, holders of convertible securities would be paid before that company’s common stockholders. As a result, an issuer’s convertible securities generally entail less risk than its common stock. However, convertible securities rank below debt obligations of the same issuer in order of preference or priority in the event of a liquidation or reorganization and are typically unrated or rated lower than such debt obligations. Different types or subsets of convertible securities may carry further risk of loss.

Options. The strategies may engage from time to time in various types of options transactions. An option gives the purchaser the right, but not the obligation, upon exercise of the option, either (1) to buy or sell a specific amount of the underlying security at a specific price (the “strike” price or “exercise” price), or (2) in the case of a stock index option, to receive a specified cash settlement. To purchase an option, the purchaser must pay a “premium,” which consists of a single, nonrefundable payment. Unless the price of the securities interest underlying the option changes and it becomes profitable to exercise or offset the option before it expires, the purchaser may lose the entire amount of the premium. The purchaser of an option runs the risk of losing the entire investment. Thus, a portfolio could incur significant losses in a relatively short period of time. The ability to trade in or exercise options also may be restricted in the event that trading in the underlying securities interest becomes restricted. Options trading may also be illiquid in the event that the portfolio’s assets are invested in contracts with extended expirations. The strategies may purchase and write put and call options on specific securities, on stock indexes or on other financial instruments and, to close out its positions in options, may make a closing purchase transaction or closing sale transaction. Writing (selling) call options on some or all of an account’s holdings creates additional risks. By writing covered call options on the securities, an account will give up the opportunity to benefit from potential increases in the value of the securities above the exercise prices of the options but will continue to bear the risk of declines in the value of the securities. The premiums received from the options may not be sufficient to offset any losses sustained from the volatility of the securities over time. A strategy may purchase put options or index put options to protect against a significant market decline over a short period of time. Energy Securities. Energy and natural resources companies are especially affected by developments in the commodities markets, the supply of and demand for specific resources, products and services, the price of oil and gas, exploration and production spending, government regulation, economic conditions, international political developments, energy conservation efforts and the success of exploration projects. If a strategy focuses on investments in these companies, those investments may present more risks than if the portfolio was broadly diversified over numerous industries and sectors of the economy. Precious Metals and Mining Securities. Securities of foreign and U.S. companies principally engaged in the exploration, mining, development, fabrication, processing, marketing, or distribution of (or other activities related to) metals or minerals are subject to the risk of sharp price volatility of metals or minerals. This risk applies whether the particular metals or minerals are precious and rare (such as gold and diamonds) or base and common (such as nickel and zinc). Investments related to metals or minerals may fluctuate in price significantly over short periods because of a variety of global economic, financial, and political factors. These factors include: economic cycles; changes in inflation or expectations about inflation in various countries; interest rates; currency fluctuations; metal sales by governments, central banks, or international agencies; investment speculation; resource availability; commodity prices; fluctuations in industrial and commercial supply and demand; 0T

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government regulation of the metals and materials industries; and government prohibitions or restrictions on the private ownership of certain precious and rare metals and minerals. High Yield Securities. High yield, or below investment grade securities, may be more susceptible to real or perceived economic conditions than investment grade securities. In addition, the secondary trading market for below investment grade securities may be less liquid. High yield securities generally have more volatile prices and carry more risk to principal than investment grade securities. Unrated Securities. The strategies may invest in fixed-income securities that do not have a grade or rating by a rating agency. In connection with such securities, Kopernik will seek to determine whether the default probability and financial strength characteristics of the securities are comparable to those of issuers of securities rated investment grade quality. Kopernik will consider information from industry sources, as well as its own quantitative and qualitative analysis, in making such a determination. However, there is no assurance that such a determination will be correct or that an unrated security will not default. Investment Companies. The strategies may invest in the securities of other investment companies, which can include open-end funds (including but not limited to ETFs), closed-end funds and unit investment trusts, subject to limits that may apply to those types of investments. Investing in another investment company may involve the payment of substantial premiums above the value of such investment company’s portfolio securities. As a shareholder of an investment company, the portfolios would be subject to its ratable share of that investment company’s expenses, including its advisory and administration expenses. Derivative Instruments. The strategies may use derivative instruments (including futures contracts, options on futures contracts and over the counter instruments) to trade or to hedge. Derivatives can be highly leveraged and quite volatile. When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative instrument and the underlying investment sought to be hedged (such as a currency) may prevent the user from achieving the intended hedge effect or expose it to the risk of loss. In addition, derivative instruments may not be liquid in all circumstances, so that in volatile markets a holder may not be able to close out a position without incurring a loss. For example, daily limits on price fluctuations and speculative position limits imposed by futures exchanges on which a portfolio may trade may prevent prompt liquidation of positions, subjecting it to the potential of greater losses. In some cases, such derivatives may be traded in markets that have limited liquidity, making it difficult or impossible for the execution of trades at a desired price and may expose a strategy to the risk of counterparty non-performance or failure. To the extent that a strategy engages in transactions in futures contracts and options on futures contracts, the profitability of such transactions will depend to some degree on the ability of Kopernik to analyze correctly the futures markets, which are influenced by, among other things, changing supply and demand relationships, governmental policies, commercial and trade programs, world political and economic events and changes in interest rates.

Moreover, investments in derivative instruments involve additional risks including, without limitation, leverage (margin is usually only 2-15% of the face value of the contract and exposure can be nearly unlimited). The CFTC and futures exchanges have established limits referred to as “speculative position limits” on the maximum net long or net short position that any person may hold or control in certain derivate instruments. Some of the instruments in which a strategy’s assets may be invested may be traded in markets in which performance will be the responsibility only of the individual counterparty and not of an exchange or clearinghouse. In these cases, the assets will be subject to the risk of the inability of, or refusal by, the counterparty to perform with respect to such contracts. There is the possibility that institutions, including brokerage firms and banks with whom a portfolio does business, will encounter financial difficulties that may impair the operational capabilities or the capital position of the portfolio. There can be no assurance that a derivative strategy, if employed, will be successful. Because many derivatives have a leverage or borrowing component, adverse changes in the value or level of the underlying asset, reference rate or index can result in a loss substantially greater than the amount invested in the derivative itself.

Private Placements and Restricted Securities. Kopernik may invest in restricted securities (securities with limited transferability under the securities laws) acquired from the issuer in “private placement” transactions. Private placement securities are not registered under the Securities Act of 1933, as amended (the "Securities Act”), and are subject to restrictions on resale. They are eligible for sale only to certain qualified institutional buyers and are not sold on a trading market or exchange. While private placement securities offer attractive investment opportunities otherwise not available on an open market, because such securities are available to few buyers, they are often both difficult to sell and to value. Certain investments may be placed in smaller, less seasoned, issuers that present a greater risk due to limited product lines and/or financial resources. The issuer of privately placed securities may not be subject to the disclosure and other investor protection requirements of a public trade. Additionally, Kopernik could obtain material non-public information from the issuer of such securities that would restrict Kopernik’s ability to conduct portfolio transactions. Private placed securities can usually only be resold to other qualified institutional buyers, or in a private transaction, or to a limited number of purchasers, or in limited quantities after they have been held for a specific period of time and other conditions are met pursuant to an exemption from registration. Kopernik and its clients may incur more cost in the disposition of such securities because of the time and legal expense required to negotiate a private placement. Because of the limited market, Kopernik may find it difficult to sell the securities when they find it advisable to do so and, to the extent such securities are sold in private negotiations, they may be sold for less than the price for which they were purchases or less than their fair market value. General Market and Geopolitical Risk. Geopolitical events, such as war (including ongoing armed conflict between Ukraine and Russia in Europe, Israel and Hamas in the Middle East, and

the United States and Iran in the Middle East), terrorism, social unrest, government defaults, government shutdowns, economic uncertainty, sanctions or the threat of sanctions, trade disputes with key trading partners and the imposition of associated tariffs, natural and environmental disasters, the spread of infectious illness, widespread disease or other public health issues such as pandemics and epidemics (including those caused by COVID-19), and/or systemic market dislocations (including due to events outside of such countries or regions), have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on the U.S. and world economies and markets generally. Whether or not Kopernik invests in securities of issuers located in countries impacted by such events, these and other events could negatively affect the value and liquidity of Kopernik’s clients’ investments due to the interconnected nature of the global economy and capital markets, which in turn could negatively impact Kopernik’s performance and cause losses for the strategy’s investments.

registered representatives of ACA Foreside to facilitate the marketing of such funds, provide ongoing training of representatives and review private fund advertising. B. Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Adviser Registration Status Kopernik is not registered as, and does not have any intention to register as, a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Kopernik is currently exempt from registration as a commodity pool operator and commodity trading advisor. C. Material Relationships and Arrangements Kopernik has arrangements that are material to its advisory business or its clients with related persons who are registered or private investment companies and general partners of private funds. Kopernik acts as investment adviser to the Kopernik Global All-Cap Fund and Kopernik International Fund, each a series of the Advisors’ Inner Circle Fund II, a registered investment company. Kopernik is affiliated with the following sponsors or general partners of private funds: Kopernik Global All-Cap GP, LLC; Kopernik Global Unconstrained GP, LLC; and Kopernik Global Long-Term Opportunities GP, LLC. Kopernik advises a number of private funds that are affiliates of the Firm, including: Kopernik Global All-Cap Fund, LP; Kopernik Global All-Cap Offshore Fund, Ltd.; Kopernik Global All-Cap Master Fund, LP; Kopernik Global Unconstrained Fund, LP; Kopernik Global Unconstrained Offshore Fund, Ltd.; Kopernik Global Unconstrained Master Fund, LP; Kopernik Global Long-Term Opportunities Fund, LP; and Kopernik Global Long-Term Opportunities Fund, Limited. Kopernik and its personnel may have a financial incentive to recommend Kopernik Global All-Cap Fund, Kopernik International Fund, and Kopernik Private Funds to clients and prospective clients

irrespective of client suitability. However, Kopernik does not recommend or otherwise use its investment discretion to cause clients or prospective clients to invest in Kopernik Global All-Cap Fund, Kopernik International Fund or Kopernik Private Funds, and the same investment strategies offered by those funds are also offered in other Kopernik products and services. Potential investors in the Private Funds must also complete subscription booklets and agreements which are intended to determine whether an investment in the Private Funds is appropriate for such investors. D. Material Conflicts of Interest Relating to Other Investment Advisers Kopernik does not recommend or select other investment advisers for its clients.

Kopernik has fiduciary obligations to clients; Kopernik and its access persons have a duty at all times to place the interests of its clients first and to avoid actual or potential conflicts of interest;

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Access persons must comply with all applicable laws, rules, regulations, and policies;

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Αccess persons (and certain household members) must make periodic reports of their personal securities transactions and holdings;

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Access persons (and certain household members) must conduct their personal securities transactions in a manner that avoids an actual or potential conflict of interest or any abuse of trust and responsibility;

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Access persons may not use knowledge about current or pending client or portfolio transactions for the purpose of personal profit;

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Information concerning clients (including former clients) must be kept confidential, including the client’s identity, holdings, and other non-public information, except where permitted by the client.

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Access persons may not give or receive gifts or participate in entertainment beyond the parameters set forth in the Code to avoid the appearance of favoritism or impropriety;

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Access persons may not engage in outside business activities that create potential conflicts of interest or interfere with their work responsibilities; Access persons may not make political contributions that are prohibited by Rule 206(4)-5 of the Advisers Act; and

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Access persons are encouraged to report in good faith what he/she believes to be a material violation of law or policy through its whistleblower policy.

All access persons must acknowledge the terms of the Code initially upon hire and annually or when the Code is materially amended.

Clients and prospective clients may request a copy of the Code (which contains more detail on Kopernik’s specific policies and procedures) by contacting Kopernik at the address or telephone number listed on the first page of this document. Personal Trading Conflicts of Interest Kopernik faces potential conflicts of interest with respect to personal securities trading. The Code seeks to ensure that personal securities transactions, activities and interests of access persons will not interfere with (i) making decisions in the best interest of clients and (ii) implementing such decisions while, at the same time, allowing access persons to invest for their own accounts where appropriate. Access persons and their household members generally are able to invest in securities that may also be purchased or held by client accounts and must generally pre-clear all transactions involving a security covered under the Code. Clearance will not be granted if the personal transaction is in close proximity to client trading activity. In addition, access persons must generally provide duplicates of all trade confirmations, account statements and other brokerage account reports to Kopernik for review. Access persons who are securities analysts or who otherwise recommend securities for client accounts are subject to more stringent restrictions on personal trading, including preclearance approval by a CoChief Investment Officer for any proposed investment that is not on the Kopernik Approved List; longer minimum holding periods; a limit on the number of trades initiated in a one-year period; and prohibitions on trading in certain equity securities. Under the Code, certain classes of securities (e.g., mutual funds, ETFs, and money market funds) have been designated as exempt transactions, based upon a determination that these transactions would not materially interfere with clients’ best interests. Because the Code in some circumstances permits access persons to invest in or hold the same securities as clients, there is still a possibility that access persons might benefit from market activity by a client in a security held by an access person. Kopernik’s access persons can take action for their own accounts that differ from, conflict with or be adverse to advice given or action taken for clients. Potential conflicts also arise due to the fact that Kopernik and its personnel have investments in some Funds but not in others or may have different levels of investments in the various Funds. Kopernik seeks to mitigate such conflicts by requiring prior clearance of certain personal securities transactions and reviewing employees’ personal brokerage statements for potential conflicts. Employee Investments Kopernik encourages its employees to invest in the portfolios offered to clients, including portfolios that are offered through collective investment vehicles. In most cases, employees invest at a discounted advisory fee or no fee. These investments pose a risk that employees with influence over investment decisions will favor the portfolios in which they have a personal interest. Although Kopernik employees own or have a significant position or percentage interest in Kopernik-managed funds or accounts, the Code’s restrictions and prohibitions on securities transactions, such as pre-clearance, do

not apply to those funds or accounts. However, such accounts are subject to the Firm’s investment allocation policy (discussed further below), which seeks to ensure, among other things, that such funds or accounts are not unduly favored by Kopernik. Allocation of Investment Opportunities Kopernik manages investments on behalf of a number of clients. Kopernik’s investment strategies are likely to overlap and there may be not enough of a particular Security for all clients to invest in that Security. It is the policy of Kopernik to allocate investment opportunities among all clients fairly, to the extent practicable and in accordance with each client’s applicable investment strategies, over time through a systematic process of transaction aggregation and allocation. Kopernik will have no obligation to purchase or sell a Security for, enter into a transaction on behalf of, or provide an investment opportunity to any client solely because Kopernik purchases or sells the same Security for, enters into a transaction on behalf of, or provides an opportunity to any other client if, in its reasonable opinion, such Security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client. Each investment allocation decision is based on a number of factors. Kopernik takes into account, among other considerations, (a) whether the risk-return profile of the proposed investment is consistent with the objectives of the client, considered (i) solely in light of the specific Security under consideration or (ii) in the context of each client’s overall holdings; (b) the potential for the proposed Security to create an imbalance in a client’s portfolio; (c) liquidity needs of the clients; (d) potential tax consequences; (e) legal or regulatory restrictions; (f) client guidelines and investment objectives; (g) the need to re-size risk in a client’s portfolio; and (h) the client’s cash position, particularly when the client has a substantial amount of investable cash (e.g., during a “ramp-up” period). Such considerations can result in allocations among clients on other than a strict pro rata basis. In addition, Kopernik may allocate to client accounts that specialize in investments in a limited set of sectors, regions, industries or markets greater than their pro rata share of any investments in such sectors, regions, industries or markets. In certain circumstances, Kopernik may exclude specific accounts, including certain Kopernik Private Funds, from aggregated trades where inclusion would result in disproportionate execution costs, operational inefficiencies, or where brokerage arrangements could impair Kopernik’s ability to achieve best execution. Where trades are not included in an aggregated order, accounts may receive prices/execution that are more or less favorable than those obtained for other accounts which could affect performance returns. It is also possible that some trades will not be completed as originally directed and trades may be subject to potential adverse price movements, particularly if they follow large block trades, involve illiquid securities, or occur in volatile markets. This risk is heightened where trading may not be completed for several weeks, or at all, following the initial commencement of trading.

B. Securities in which Kopernik or a Related Person Has a Material Financial Interest. Principal Trading Policy From time-to-time Kopernik employees may invest in mutual funds or private funds or accounts managed by Kopernik. Those investments may represent all or a majority of the fund’s or account’s assets, causing the fund or account to be deemed a “principal” or proprietary account. Kopernik does not generally engage in principal trades between the Firm, or its principal accounts, on the one hand, and unaffiliated clients. In the limited circumstances when the Firm’s personnel deem it beneficial to engage in a principal transaction with a client, they will do so only in accordance with the specific notice and consent requirements set forth in Section 206(3) of the Advisers Act. Agency Cross Transactions In an agency cross trade, the investment adviser or an affiliate, as broker, crosses the transaction of an advisory client with the transaction of a brokerage client, and receives transactional compensation (i.e., in connection with a trade, the investment adviser acts as investment adviser to at least one party and acts as broker to both parties). Section 206(3) of the Advisers Act prohibits an investment adviser or any person controlling, controlled by or under common control with an investment adviser (i.e., an affiliate) to effect agency cross transactions without disclosure and client consent. However, unlike principal trades, the required disclosure and client consent may be obtained from a client in advance of a transaction and it may cover multiple transactions. The Firm does not intend to use an affiliate for brokerage or engage in agency cross transactions. The Firm would obtain prospective client consent to any agency cross transactions in conjunction with the client’s execution of an investment management agreement at the inception of the relationship, following full written disclosure concerning potential agency cross transactions. Cross Trades A “cross trade” is a pre-arranged transaction not involving a broker-dealer or brokerage commission between two or more client accounts that are managed by the same investment adviser. Kopernik would seek to ensure that the cross trade achieves best execution for any clients involved and that no client is disfavored by the cross trading. Kopernik does not generally act as intermediary in connection with cross trades, and currently expects that all trades between client accounts will be made by an unaffiliated broker-dealer. In the limited circumstances when the Firm’s personnel deem it beneficial to engage in a cross-trade between two or more client accounts, it will do so only in accordance with the Advisers Act. Underlying Portfolio Company Board Membership

A Kopernik related person serves as a director of an underlying portfolio company. In these circumstances, the related person will act as a representative of Kopernik and will seek to act in the best interests of Kopernik’s clients, consistent with his or her duties as a director of the underlying portfolio company. If irreconcilable conflicts of interest were to arise between the interests of Kopernik’s clients and the underlying portfolio company, then the related person would resign the position at the underlying company or take other appropriate action to address the conflict. However, the related persons will seek to anticipate and prevent such conflicts before they occur. Related persons acting as officers or directors of underlying portfolio companies may also come into possession of material non-public information concerning the company. Kopernik will handle such information in accordance with its Information Barrier Policy and the relevant provisions of its Code of Ethics. Any related person serving as a board member of a portfolio company will receive no compensation for services as a Board Member but may receive de minimis reimbursement for expenses related to attending board meetings.

The Firm does not recommend, request, or require that a client direct some of its brokerage. Kopernik does not anticipate accepting non-discretionary broker accounts which are those where the client directs Kopernik to direct all of their brokerage to a particular Broker at a pre-established commission rate. Kopernik seeks to obtain “best execution,” as described below, for all client transactions for which it has brokerage discretion. Kopernik’s ability to seek best execution will be somewhat limited for partially discretionary brokerage accounts. Where a client directs some brokerage, the arrangement can cost the client more money or otherwise have less favorable results than if Kopernik had discretion as to which broker to use, because Kopernik may be unable to aggregate orders to reduce brokerage commissions, and Kopernik may be unable to achieve the most favorable execution of the client’s transactions. Mutual funds and other Funds managed by Kopernik typically provide Kopernik with full discretion to seek best execution. Best Execution Generally Kopernik seeks to obtain best execution on all client trades for which it exercises brokerage discretion through the use of select brokers, dealers, or other trading venues (collectively, “Brokers”) and by negotiating brokerage commissions and other transaction costs. Kopernik considers best execution as the combination of best net price and execution under the circumstances. In considering best execution, Kopernik takes into account not only the available prices and commission rates, but also a variety of other factors, including but not limited to, the liquidity and activity expected in the market for a particular security, the size and timing of the transaction and the difficulty of its execution, the nature of the security, a Broker’s operational and execution capacities (including its commitment of capital and its trading infrastructure), its financial responsibility and responsiveness, its ability to reduce

market impact, access to underwritten offerings, secondary markets and over-the-counter investment opportunities, the availability of bonds or stocks to borrow for short sales, the value of research services provided by a Broker which is expected to enhance Kopernik’s portfolio management capabilities, and other factors, without having to demonstrate that such factors are of direct benefit to any particular client. For example, a Broker being asked to use its own capital to complete a trade would be expected to charge a higher commission rate. Kopernik does not use any affiliated broker-dealer to execute trades on behalf of its clients. As permitted by the Section 28(e) safe harbor, Kopernik in its discretion may cause a client to pay a commission for effecting a transaction in excess of the amount or rate another Broker would have charged for effecting that transaction when Kopernik concludes in good faith that the commission paid is reasonable in relation to the quality of execution considering, also, the value of any research services or products provided by the Broker, viewed in terms of the particular transaction or Kopernik’s overall responsibilities with respect to all accounts over which Kopernik exercises discretionary authority. Such research services or products can be used for clients other than the client that generated the “soft dollars” under the safe harbor. Certain clients, for regulatory or other reasons, do not allow soft dollars for the acquisition of research or third-party research services, but may ultimately benefit from research and third-party research services acquired through soft dollars generated through other clients’ transactions. This includes arrangements in which a non-U.S. investment manager has delegated investment discretion and trading authority to Kopernik and has contractually imposed additional regulatory requirements. When purchasing or selling fixed income securities or other Securities traded on the over-the-counter market, Kopernik may purchase directly from the issuer or from a Broker engaged in making a market for such Securities. There is generally no stated commission in the case of Securities traded in the overthe counter markets, but the price generally includes an undisclosed dealer mark-up. Securities also may be purchased from underwriters at prices that include underwriting fees. Kopernik may transmit orders to Electronic Communications Networks (“ECNs”) and Alternative Trading Systems (“ATSs”) to execute purchases and sales of securities where such networks and systems are believed to provide best execution for Kopernik clients. Transactions on exchanges, commodities markets and other agency transactions involve the payment of negotiated brokerage commissions. Such commissions vary among different Brokers. Transactions in foreign securities sometimes involve the payment of fixed brokerage commissions. Brokerage commissions in foreign developed and emerging or frontier markets may be materially higher than those in the U.S.

Brokerage and Use of Prime Broker Kopernik or its affiliates has selected one or more firms to serve as prime broker in order to hold the securities of, and/or execute transactions for, certain Kopernik Private Funds and other pooled investment vehicles for which Kopernik serves as investment manager. This selection is consistent with Kopernik’s obligation to obtain best execution of all securities transactions. In addition to custody and execution, a prime broker can provide other core functions (such as reporting, clearing, financing, and securities lending) as well as value added services (such as capital introductions, advanced research and analytics and technology services) to Kopernik and/or Kopernik Private Funds. Kopernik will choose which prime broker effects a particular transaction and/or the amount of commission paid by the Kopernik Private Funds for the trade. Kopernik may “trade away” from a prime broker for specific trades, executing trades through other brokers in an effort to gain access to greater inventory or better price or execution. “Trading away” from a prime broker can result in the Kopernik Private Funds incurring additional costs. Kopernik’s use of a prime broker for the Kopernik Private Funds, where the prime broker provides core functions and/or value-added services in addition to custody and execution, benefits Kopernik. The conflict of interest this presents is addressed by Kopernik’s policies and practices ensuring that best execution is achieved for all client account trades, as described above. Kopernik reserves the right in its sole discretion to change a Kopernik Private Fund’s prime brokerage arrangement, although notice of any such change will be provided in accordance with applicable law and regulations. Brokerage for Investment Company Sales Prohibited In accordance with Rule 12b-1(h) of the 1940 Act, Kopernik cannot consider in its best execution analysis the fact that a Broker has sold securities of an SEC-registered investment company managed by the Firm. Kopernik may not compensate a Broker for any promotion or sale of shares of an SECregistered investment company managed by the Firm by directing client transactions to the Broker or paying higher remuneration to that broker or dealer, including but not limited to any higher commission, mark-up, mark-down, or other fee (or portion thereof). In particular, commissions cannot be allocated to a Broker in return for sale of the registered investment companies managed by Kopernik, or sale of Kopernik Private Funds, for “shelf space” for the funds, for exposure of Funds to the Broker’s sales force or clients, or for any other arrangement that is designed to support or promote the Broker’s sales of Funds’ shares. Investment Research and Use of Soft Dollars Consistent with its policy of seeking best execution, Kopernik considers the research and brokerage services provided by various Brokers, including the reputation and quality of their analyses, investment ideas, and market and financial data and other information. These research and statistical services may

consist of research reports or oral advice from the Brokers regarding particular companies, industries or general economic conditions. Included also as part of these services may be informational meetings, interviews, and seminars arranged by a Broker between Kopernik analysts and brokerage analysts or executives of companies in which Kopernik clients have invested or may invest in the future. “Research services” used by Kopernik means advice, analyses, information and reports about securities that provide lawful and appropriate assistance to the investment manager in the performance of its investment decision-making responsibilities and that reflect the expression of reasoning or knowledge. “Brokerage services” means those services that relate to the execution of a trade from the point at which the investment manager communicates with the broker-dealer for the purpose of transmitting an order for execution through the point at which funds or securities are delivered or credited to the advised account. Kopernik receives and pays for research services in a variety of ways. Brokers, for example, may provide proprietary products or services directly. Kopernik may also arrange for a Broker to allocate a portion of commissions (or markups or markdowns) to a fund of commission credits maintained by the Broker (“Soft Dollars”) from which the Broker, at Kopernik’s request, pays itself for proprietary research and/or other research services from independent Brokers and other providers, including market data services (“Commission Sharing Agreements”). Commission Sharing Agreements help Kopernik select the most appropriate Broker for trade execution regardless of whether or not such Broker prepares or develops the research services used by Kopernik. In addition, Kopernik may pay directly for research services provided by firms that are not broker-dealers. Research services furnished by Brokers through whom Kopernik may effect securities transactions for a particular account can be used by Kopernik in servicing its other discretionary accounts. Kopernik does not attempt to allocate Soft Dollars to client accounts in proportion to the Soft Dollar credits generated by specific accounts. As a result, research services may not be used by or for the benefit of the client who paid the brokerage commission. Kopernik uses Soft Dollars to obtain a research or brokerage product or service which has “mixed use”, such as an Order Management System and related terminals. Where a product or service has a mixed use, and only part of the use falls within the scope of Section 28(e), Kopernik will make a reasonable allocation of the cost of the product or service according to its use. Only the percentage of the product or service that is within the scope of Section 28(e) will be paid for with Soft Dollars. Kopernik will keep all books and records concerning these mixed-use allocations. Conflicts of Interest Kopernik faces a number of potential conflicts of interest in its best execution obligations. Kopernik selects and uses Brokers that also have other business with Kopernik and its affiliates. When exercising

discretion to select Brokers and negotiating brokerage commissions or other transaction costs, and in evaluating and reviewing best execution, Kopernik does not take into account a Broker’s business, distribution or referral arrangements with Kopernik or its affiliates. In addition, when Kopernik uses client brokerage commissions (or markups or markdowns) to obtain research or brokerage services, it receives a benefit because it does not need to produce or pay for those services itself. Kopernik has an incentive to select a Broker based on its interest in receiving research or brokerage services, rather than on its clients’ interests in receiving the most favorable execution, and to trade frequently to generate commissions that can be used to pay for those services. The Firm’s Best Execution Committee, which oversees Kopernik’s trading, seeks to mitigate these potential conflicts. Kopernik accepts responsibility for trade errors that are its responsibility, but not the errors of clients, third-party Brokers, transition agents, or custodians. Ultimately it is Kopernik that decides whether an incident is an error that requires compensation by Kopernik to the client, which creates a conflict of interest. Kopernik has implemented a written trade error policy to manage conflicts concerning trade errors and ensure that errors are corrected in a fair and timely manner. B. Order Aggregation Aggregation, or “bunching” of trade orders, occurs when an investment adviser combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. The Firm generally aggregates trades, but is not required to, where aggregation is practicable and is believed to be in clients’ best interests. Should Kopernik choose to accept a client that requires Kopernik to use a specific Broker for a trade, aggregation may not be possible for that client. To seek the potential advantages of trade aggregation, Kopernik may in some cases “step-out” executed transactions to the custodial or directed brokerage firm’s designated trading desk. In a step-out transaction, Kopernik will, consistent with its objective of achieving best execution, direct securities to a specific Broker for execution and instruct the broker to execute the transactions and transmit (or “step out”) a portion of the transaction to another brokerdealer. Kopernik may request that the executing broker-dealer step out a portion of the transaction for many reasons, including but not limited to, provision of research services to Kopernik. Where Kopernik is unable to aggregate a client’s order with other orders, the cost of execution may be higher for all clients. Sometimes Kopernik determines that it does not need to aggregate all orders, that it will not be able to complete all orders for the same Security in one order or that it would not be practicable to aggregate all orders because of custodian or custodian affiliate requirements, reporting requirements in certain foreign jurisdictions, or contractual or legal obligations to certain clients or third parties. Further, in certain circumstances, Kopernik may exclude specific accounts, including certain proprietary private

funds, from aggregated trades where inclusion could result in disproportionate execution costs, operational inefficiencies, or where brokerage arrangements could impair Kopernik’s ability to achieve best execution. In such circumstances. Kopernik will enter a separate trade order for the same Security to be executed after approximately fifty percent (50%) of the aggregated order for the same Security is completed. The remaining fifty percent (50%) of the aggregated order for the same Security will then be completed. Because of this trading rotation, certain accounts may receive prices/executions that are more or less favorable which could affect an account’s performance returns. Given Kopernik’s trading approach of executing trades within a 3% band of arrival price, it is possible some trades will not be completed as originally directed and trades may be subject to potential adverse price movements, particularly if they follow large block trades, involve illiquid securities, or occur in volatile markets. This risk is heightened where trading may not be completed for several weeks, or at all, following the initial commencement of trading given Kopernik’s trading approach. Kopernik, through an unaffiliated Broker, may place combined orders for all clients simultaneously with any Broker and if any order is not filled at the same price, they may be allocated on an average price basis. In an “average price” account, purchase and sale orders placed during a trading day on behalf of the participating clients are combined, and Securities bought and sold pursuant to such orders are allocated among such clients on an average price basis. There may be instances, such as when orders are placed with more than one Broker, that make it impossible for Kopernik to average the prices paid. In these instances, Kopernik will allocate the filled orders in an equitable manner. Similarly, if an order on behalf of more than one account cannot be fully executed under prevailing market conditions, Kopernik acting through an unaffiliated Broker may allocate the Securities traded among the different accounts on any basis that it considers equitable, including pro rata based on the portfolio size of each participating client. In these circumstances, each client account would pay, in connection with the acquisition of Securities by more than one account, the average price per unit acquired, which may be higher than if it had acted alone, and it may otherwise not be able to execute an investment decision as effectively as it could have if it had acted alone. There may be corresponding potential disadvantages when more than one client simultaneously seeks to dispose of commonly held Securities.

Any potential compliance exceptions identified by the OMS Compliance module will trigger a review of the trade by the Compliance team. When all compliance checks are complete, the trade is then electronically routed to the Kopernik trading desk for execution. B. Factors Prompting Review of Client Accounts Other than a Periodic Review A review of a client account may be triggered by unusual activity in the account, contributions to or distributions from an account, changes in guidelines or account objectives agreed by Kopernik, or other special circumstances. Client accounts will be reviewed periodically to ensure compliance with the appropriate list of guidelines, restrictions, and investment parameters. For separately managed accounts, Kopernik may undertake reviews as a result of a client’s request. Such reviews can address investment performance, investment objectives, Securities positions and other investment opportunities. C. Content and Frequency of Account Reports to Clients Registered investment companies and other funds advised or sub-advised by Kopernik will receive reports at least quarterly, or as negotiated. Investors in the Kopernik Global All-Cap Fund, LP or Kopernik Global All-Cap Offshore Fund, Ltd. receive investment performance commentary by Kopernik on a monthly basis, while investors in Kopernik Global Unconstrained Fund, LP; Kopernik Global Unconstrained Offshore Fund, Ltd.; Kopernik Global Long-Term Opportunities Fund, Ltd.; and Kopernik Global Long-Term Opportunities Fund, LP receive investment performance commentary periodically. Kopernik Private Fund investors also receive individual statements indicating the current value and performance of their investment in each respective Private Fund on a monthly basis. Clients in separately managed accounts receive a quarterly investment statement and may receive written commentaries regarding investment performance. The Firm’s policy is to not disclose mutual fund portfolio holdings until at least 30 days have passed since the date the portfolio holdings were determined. With respect to Kopernik Private Fund or CIT portfolio holdings, the Firm’s policy is not to disclose portfolio holdings until 10 business days after month-end. Kopernik will disclose portfolio holdings to the client or to third-party vendors with a legitimate business need for

such information. Kopernik may provide certain clients or investors with additional information, such as transaction summaries, gain/loss reports or commission reports, if agreed to by Kopernik. Kopernik expects to provide annual audited financial statements to investors in Kopernik Private Funds within 120 days of the applicable fund’s fiscal year end.

Compensation to Non-Supervised Persons for Client Referrals Kopernik has engaged a third-party as an introducer of potential institutional clients or investors in certain Kopernik pooled investment vehicles and separately managed accounts. Kopernik may further engage unaffiliated third-party organizations including a placement agent, consultant, finder, or other solicitor, or similar person to solicit investors for certain Kopernik Private Funds. Kopernik may engage registered broker-dealers, solicitors exempt or excepted from registration who are not affiliated with Kopernik, and foreign brokers or placement agents that have clients or contacts that wish to invest in Kopernik products or strategies. Kopernik’s solicitation arrangements will comply with Rule 206(4)-1 of the Advisers Act. Generally, the referral fee will be based on a percentage of the investment advisory fees earned on assets invested with Kopernik at the start or over a few years of the new client’s or investor’s relationship. Clients do not pay higher fees to Kopernik as a result of any solicitation agreements. Some clients and prospective clients may use investment consultants to evaluate and recommend investment advisers. Kopernik also may pay fees to consultants for advice and services, industry information, or conference attendance. A conflict could arise if the consultant recommended Kopernik’s services based upon such payments or the amount of services purchased. Kopernik and its employees are permitted to send corporate gifts or pay for meals and entertainment for individuals of firms that do business with Kopernik, including firms that refer clients to Kopernik, subject to limitations in the Code.

independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and that each Private Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year. Account Statements Clients in separate accounts will receive account statements from Kopernik (or an independent service provider hired by Kopernik) at least quarterly. Kopernik utilizes SEI Global Services, Inc. to provide all middle- and back-office functions. Separate account clients with a Qualified Custodian may also receive account statements from the qualified custodian and should carefully review those statements. Kopernik statements are not intended to replace the statements from the client’s Qualified Custodian. Clients are urged to compare the information contained in Kopernik account statement with the information reflected on the statements sent by Qualified Custodians. Clients should notify their Qualified Custodian promptly if they do not receive an account statement on at least a quarterly basis.

Kopernik’s discretionary authority is limited by investment guidelines agreed with each client. A client may select an investment strategy with existing, standard investment guidelines and request reasonable restrictions on the management of its account. If Kopernik agrees to those restrictions, it will manage the account in accordance with the agreed upon, revised investment guidelines. Kopernik will not be able to accommodate proposed investment restrictions that are onerous or incompatible with Kopernik’s standard investment strategies and investment philosophy, and Kopernik may decline to accept or terminate client accounts with such restrictions. Kopernik generally also has full discretion concerning the timing of investing a client’s assets at the start of managing a client account and receipt of additional contributions to an account. Kopernik also serves as the investment manager for several private funds with broad discretionary authority. Kopernik’s investment decisions and advice with respect to each fund are subject to each fund’s investment objectives and guidelines, as set forth in its private placement offering memorandum. Kopernik entered into an investment management agreement, or similar agreement, with each fund, pursuant to which Kopernik or an affiliate of Kopernik was granted discretionary trading authority, subject to the limitations contained in that agreement and the offering memorandum. For the Collective Investment Trusts, Kopernik’s authority is subject to investment guidelines and the Trustee who maintains ultimate fiduciary authority over the management of, and the investment made, in the funds. For Advisory Only clients, Kopernik does not make actual decisions to purchase, hold or sell assets of the client account and is not authorized to place discretionary orders for the execution of securities or other transactions for or on behalf of such client account. Claims on Behalf of Clients. Kopernik’s acceptance of investment discretion does not normally extend to litigation and legal proceedings. Accordingly, the Firm will not initiate lawsuits on behalf of clients. For class actions, clients should arrange for their custodian to prepare and file proofs of claim.

Kopernik will provide reasonable assistance in the preparation of any proof of claim for client accounts but shall not provide any legal advice in connection with class actions. Similarly, Kopernik will not be expected or required to take any action with respect to bankruptcy actions involving securities presently or formerly held in client accounts.

Kopernik has adopted the guidelines of and will generally vote in accordance with the recommendations of Institutional Shareholder Services, Inc. (“ISS”) with certain exceptions, as noted in Kopernik’s Proxy Voting Policies and Procedures. In some cases, Kopernik may agree generally to vote proxies for a particular client account in accordance with the third-party recommendations or guidelines selected by the client. In general, unless otherwise restricted, Kopernik reserves the right to override the applicable third-party recommendations or guidelines in any situation where it believes that following such recommendations or guidelines is not in its clients’ best interests. If a material conflict of interest has been identified and the matter is covered by the applicable recommendation or guidelines, the Proxy Voting Committee will cause proxies to be voted in accordance with the applicable recommendation or guidelines. If a material conflict of interest has been identified and the matter is not covered by the applicable recommendation or guidelines, Kopernik may either vote in accordance with the recommendation of an alternative independent third-party (who may be a proxy advisor) or disclose the conflict to the client, obtain the client’s consent to vote, and make the proxy voting determination itself. Kopernik may decide not to vote proxies in respect of securities of any issuer if it determines it would be in its clients’ overall best interests not to vote. Such determination may apply in respect of all client holdings of securities or only certain specified clients, as Kopernik deems appropriate under the circumstances. Kopernik may also decline to vote proxies where the voting would in Kopernik’s judgment result in some other financial, legal, regulatory disability or burden to Kopernik or the client (such as imputing control with respect to the issuer). If Kopernik receives proxies for securities that are transferred into a client’s portfolio that were not recommended or selected by Kopernik and are sold or expected to be sold promptly in an orderly manner (“legacy securities”), Kopernik will generally refrain from voting such proxies. Since legacy securities are expected to be sold promptly, voting proxies on such securities would not further

Kopernik’s interest in maximizing the value of client investments. Kopernik may consider an institutional client’s special request to vote a legacy security proxy, and if agreed will vote such proxy in accordance with the guidelines herein. Kopernik does not offer a securities lending service. However, Kopernik clients may enter into securities lending arrangements with custodians or other third-party agent lenders. Kopernik will not be able to vote securities that are on loan under these types of arrangements. However, under rare circumstances, for voting issues that may have a significant impact on the investment, Kopernik may ask clients to recall securities that are on loan if it believes that the benefit of voting outweighs the costs and lost revenue to the client or fund and the administrative burden of retrieving the securities. A copy of Kopernik’s Proxy Voting Policies and Procedures, as amended from time to time, and information on how Kopernik voted a client’s securities is available to clients upon written request. Clients seeking this information should contact Kopernik Global Investors, LLC, Attn: Administration, 2502 N. Rocky Point Drive, Suite 300, Tampa, Florida 33607.

In order to provide you with individualized service, we collect certain non-public personal information about you from information you provide on applications or other forms and information about your account transactions with us. This privacy policy lists the non-public personal information Kopernik may collect and describes the policies we apply to storing and disclosing that non-public personal information. INFORMATION WE COLLECT We collect the following information from our clients (if applicable): name, address, telephone number, e-mail address, birth date, driver’s license number, social security number, tax identification number, signature, or bank account information. We also collect information such as e-mail address, phone number, address, job title, and company information from non-clients through inquiries by mail, e-mail, telephone, or through the Kopernik subscription form found on Kopernik’s website. INFORMATION WE DISCLOSE We do not disclose any non-public personal information about you to anyone, except as permitted by law. Specifically, so that we may continue to offer you products and services that best meet your investing needs, and to effect transactions that you request or authorize, we disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, or printers and mailers that assist us in the distribution of investor materials. With respect to individuals that subscribe to receive emails containing Kopernik commentary and materials, non-public personal information including the individual’s name, email address, physical address, telephone number, job title, and company will be shared with companies hired to assist with the distribution of the material you have requested to receive. These companies will use this information only for the services for which we hired them and are not permitted to use or share this information with anyone for any other purpose. Furthermore, Kopernik will disclose non-public personal information in circumstances where Kopernik believes in good faith that a disclosure is required under applicable law, to cooperate with regulators, or to cooperate with law enforcement authorities. If you would like to opt out of Kopernik’s disclosure of non-public personal information, you may send an email to legal@kopernikglobal.com. HOW WE SAFEGUARD YOUR INFORMATION If you decide at some point either to close your account(s) or to become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice. With regard to our internal security procedures, Kopernik has safeguards in place to prevent unauthorized access to our systems and procedures to protect personal information from unauthorized access and use. Kopernik takes reasonable steps to protect the non-public personal information provided to it by its clients. Furthermore, we have implemented processes and procedures to prevent unauthorized access, disclosure, or theft of any non-public information including restricting access to your personal and

account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your non-public personal information and to comply with all applicable laws. ADDITIONAL POLICIES APPLICABLE TO CALIFORNIA RESIDENTS Pursuant to the California Consumer Privacy Act (“CCPA”), personal information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, either directly or indirectly, with a California resident or household. “Personal data” for the purposes of this policy includes non-public personal information and personal information as defined under the CCPA with regard to California residents. Under the CCPA, California residents may have certain rights concerning their personal information, such as (i) the right to know what personal information Kopernik collects, (ii) the right to delete personal information collected (subject to exceptions), (iii) the right to opt-out of the sale of their personal information, and (iv) the right to not be discriminated against for exercising their rights under the CCPA. Kopernik may disclose your information for a business purpose to third-party service providers as described above. We do not sell California resident personal information. If you are a California resident and wish to exercise your rights under the CCPA, to the extent they are applicable, please call 1-813-314-6100 or send an email to info@kopernikglobal.com. Kopernik will only provide certain information or delete personal information in response to a request from a California resident (or their designee) upon verification, in Kopernik’s sole discretion, that the person is a California resident or the legally authorized designee of a California resident. Kopernik reserves the right to retain the personal information of a California resident after a request to delete their information to the extent permitted by the CCPA or any other law or regulation. Kopernik may update or revise this privacy policy at any time and without prior notice.