Rock Springs Capital: investment adviser

The Funds and the General Partner Rock Springs provides discretionary investment advice to private investment funds organized as domestic or foreign private pooled investment vehicles (the “Funds”). The Funds are organized as master-feeder structures whereby each domestic fund (“Domestic Fund”) and offshore fund (“Offshore Fund” and together with the applicable Domestic Fund, the “Feeder Funds”) invests substantially all of its assets in a master fund (“Master Fund”). All trading occurs at the Master Fund level. Rock Springs began providing investment advisory services in October 2013. The Funds have been established to pursue investment strategies that focus primarily on investing in companies in healthcare and healthcare-related industries, with an emphasis on companies and/or products that Rock Springs believes serve critical unmet needs. The Funds’ investment objective is to generate capital appreciation, primarily through investments in publicly traded and privately placed securities of companies in these industries. Rock Springs manages the Funds in accordance with the investment strategies, objectives, restrictions and guidelines set forth in their respective confidential offering documents, limited partnership agreements and/or investment management agreements (the “Governing Fund Documents”), as applicable, and does not provide investment advice individually to the limited partners of the Funds (each, an “Investor” and together, “Investors”). Rock Springs generally does not permit Investors to impose restrictions on investments made by the Funds. However, Investors elect whether to participate in special investments, which include investments by the Funds in private companies and privately-placed debt as well as certain illiquid securities and restricted securities, as described in more detail in Item 8 below. Client Assets Under Management As of the close of business on December 31, 2025, Rock Springs managed approximately $1.8679 billion of client assets on a discretionary basis. Rock Springs does not currently manage any assets on a non-discretionary basis.

Funds. The fees and expenses applicable to each Fund are set forth in detail in each of the Fund’s Governing Fund Documents. Rock Springs’ fee schedule is omitted because this brochure is only being delivered to qualified purchasers as defined in the Investment Company Act of 1940, as amended (the “Investment Company Act”). Rock Springs’ compensation is negotiable and Rock Springs may, in its sole discretion, elect to waive, reduce or calculate differently any compensation with respect to any person, including partners or employees of Rock Springs or its affiliates, such persons’ family members and trusts or other entities established for the benefit of such persons or their family members (collectively, and together with Rock Springs and its affiliates, “Related Persons”). Organizational, Operating and Other Expenses As a general matter, expenses borne by the Feeder Funds are set forth in the relevant Governing Fund Documents. The Feeder Funds bear all of their organizational, operating and other costs and expenses, as well as indirectly bear their pro rata share of the applicable Master Fund’s organizational, operating and other expenses, including investment-related expenses (e.g., costs and expenses associated with the investigation of investment opportunities (whether or not consummated) (which also includes expenses relating to attendance at medical and industry conferences), research, negotiating, financing, sourcing, acquiring, holding, hedging, settling and disposing of its investments) or other transaction costs, including travel expenses (including, for the avoidance of doubt, research and investigation-related travel (which includes first-class airfare in accordance with Rock Springs’ travel policy)), transaction fees, consulting (e.g., expert network fees), fees and reasonable out-of-pocket expenses incurred by an independent investor representative, advisory, investment banking, legal and other professional fees relating to investments or contemplated investments, the Master Fund’s brokerage commissions, information-related expenses (including costs and expenses associated with Bloomberg, FactSet, market data and market data feeds, vendors of portfolio analytics software (e.g., best execution analytical software) and tools and other similar costs and expenses), clearing and settlement charges, custodial fees, interest expenses, appraisal fees and expenses, expenses, interest charges and costs incurred in connection with any credit facilities, expenses incurred in collection of monies owed to the applicable Fund, legal, auditing and accounting expenses (including, but not limited to, expenses associated with the preparation of the applicable Fund’s financial statements, any tax returns and with respect to Schedules K-1), out-of-pocket costs incurred by Rock Springs (including its counsel) relating to the preparation of regulatory filings or the determination of whether such regulatory filings are necessary, and any other costs associated with such regulatory filings related to the Funds or Rock Springs with respect to the Funds (including, but not limited to Schedules D, F, G and/or 13H filings, Section 16 filings, Form PF filings, Form N-PX, Form SHO and Hart-Scott-Rodino), insurance expenses (including directors’ and officers’ insurance, errors and omissions insurance, cybersecurity insurance and other similar policies), fees and expenses of the Funds’ administrators, organizational expenses, expenses relating to the ongoing offer and sale of interests and withdrawals and transfers thereof, including, but not limited to legal expenses incurred by the Feeder Funds and Rock Springs in amending the Feeder Funds’ confidential offering documents, printing and mailing costs, management fees, any entity-level taxes, fees or other governmental charges levied against the Funds or any special purpose vehicle, all litigation-related and indemnification expenses, wind-up and liquidation expenses, extraordinary expenses and expenses comparable to any of the foregoing. The Feeder Funds also bear their pro rata share of the third-party expenses incurred by the applicable Master Fund in relation to its compliance obligations with respect to applicable anti-money laundering laws or the laws, regulations, and executive

orders administered by the Treasury Department’s Office of Foreign Assets Control or other laws or regulations by any person in any relevant jurisdiction, including expenses incurred with respect to the preparation of compliance manuals and ongoing training. The Feeder Funds share all items of profit, loss, income and expense of the applicable Master Fund on a pro rata basis in accordance with their respective capital account balances in the Master Fund, unless, in the judgment of Rock Springs, tax, regulatory, legal or other considerations make such pro rata arrangements inappropriate; provided that costs, fees and expenses incurred for the benefit of only a Domestic Fund or an Offshore Fund will be allocated solely to such Domestic Fund or Offshore Fund, respectively. Rock Springs Personnel Compensation All remuneration paid to Rock Springs, the General Partner and their respective principals, officers, partners or employees (collectively, “Rock Springs Personnel”) in connection with service by Rock Springs Personnel on the board of directors of a company in which a Fund invests (collectively, “Director’s Compensation”) shall reduce (but not below zero) the management fee that Rock Springs receives from the Funds by the amount of such Director’s Compensation following receipt or realization of such Director’s Compensation. Director’s Compensation received by Rock Springs in the form of warrants, options or securities shall be exercisable or disposable, as the case may be, in Rock Springs’ sole discretion, and shall reduce the management fee by the amount received. Any Director’s Compensation received by Rock Springs that is attributable to more than one Fund shall be prorated on a fair and equitable basis among all Funds as determined in good faith by Rock Springs. Allocation of Expenses Costs and expenses borne by more than one Fund will be allocated in accordance with Rock Springs’ expense allocation policy, which seeks to allocate expenses pro rata based on respective net asset values (which may be based on single investments or overall net asset value of the relevant Funds) and/or based on other equitable considerations that may be appropriate under the circumstances as determined by Rock Springs. Rock Springs will allocate all research- and investigation-related costs and expenses (including, but not limited to, attendance at or participation in broker-sponsored, industry- or sectorspecific or other conferences, expenses incurred in relation to meetings with industry or corporate spokespersons, physicians, government representatives and/or other key opinion leaders, expert network fees and expenses, and travel (which includes first-class airfare in accordance with the Rock Springs travel policy), lodging and other incidental costs, fees and expenses related to any of the foregoing) (collectively, “Research Expenses”) pro rata to the Funds based on their respective net asset values at the time such allocation is made; provided, however, that Research Expenses that relate directly to investment opportunities which are exclusive to a strategy implemented by one or more Funds will be allocated solely to such Fund(s), as applicable, based on its/their respective net asset value(s) at the time such allocation is made; and provided further that the allocation of Research Expenses to any special investment accounts of the Funds will be as provided in the expense allocation policy and the applicable Governing Fund Documents. The Funds will also share equally (i.e., 50/50) in certain expenses, including any out-of-pocket expenses related to any amendment to Governing Fund Documents except to the extent the amendment pertains to solely one Fund. The allocation of expenses involves subjective determinations by Rock Springs which may involve conflicts of interest. For example, although some expenses will be allocated pro rata among the Funds (e.g., based on respective net asset values or another methodology determined by Rock

Springs to be appropriate), other expenses may be allocated on a non-pro rata basis. In some instances, allocations may result in one or more Funds paying a disproportionate portion of an expense relative to the benefits actually received. Moreover, allocations of expenses will generally be based on information available at the time such allocations are made, on estimates (rather than exact figures) and on assumptions which Rock Springs believes are reasonable and appropriate but which may be imprecise. While Rock Springs believes that its expense allocation policy is reasonably designed, other reasonably designed allocation methodologies exist that will yield different results. To the extent that expenses of the Funds are paid by Rock Springs or its affiliates (in excess of its ratable share), the Funds will reimburse such party for such expenses. For more information regarding Rock Springs’ brokerage expenses, please see Item 12 herein entitled “Brokerage Practices.”

In addition, as the Funds are subject to different performance-based compensation structures, Rock Springs may have an incentive to favor certain Funds over others. Please see Item 8 and Item 12 for additional information about the Allocation Procedures (as defined below), which are reasonably designed to mitigate such conflicts of interest. Rock Springs has adopted a code of ethics to enforce a standard of conduct for its employees and to address potential conflicts of interest, including conflicts of interest between Rock Springs and its clients that may arise as a result of performance-based compensation arrangements. Please see Item 11 below for a discussion of Rock Springs’ code of ethics.

However, Rock Springs and/or its affiliates maintain discretion to accept less than the minimum investment threshold. Each Investor is required to meet certain suitability qualifications, such as being an “accredited investor” within the meaning set forth in Regulation D under the Securities Act of 1933, as amended, and a “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act.

In addition, the Funds may invest in securities which are illiquid, have limited liquidity or for which there is no ready market, including without limitation securities issued by private companies, restricted securities and privately-placed debt. Rock Springs will designate investments in private companies and privatelyplaced debt as well as certain illiquid securities and restricted securities as special investments. Each Investor must elect either to participate in or to not participate in special investments at the time that the Investor initially invests in a Fund (or makes any additional investment in a Fund). There can be no assurance that the Funds will achieve their investment objectives. The Funds seek to achieve the compounding of gains in long-term, secular winners in an industry prone to extreme outcomes and/or in companies that are innovative in discovering and developing therapeutic solutions to critical unmet healthcare needs. Rock Springs’ investment process leverages a long-term horizon, seeking to take advantage of the healthcare sector’s inherent volatility to increase position sizes over time. There can be no assurance that Rock Springs will achieve the objectives of the Funds. Investors may lose all or substantially all of their investment in the Funds. Summary of Principal Investment Risks Investing involves substantial risks, including the risk of total loss of capital, and may not be suitable for all Investors. No guarantee or representation is made that the Funds’ investment programs, including, without limitation, the Funds’ investment objectives, diversification strategies or risk monitoring goals, are or will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will be avoided. Past results of investments made by the investment professionals of Rock Springs are not necessarily indicative of the Funds’ or Rock Springs’ future performance. The following are certain of the principal risks associated with the investment activities of the Funds, the structure of the Funds, and investing in the Funds in general. Some of the below risks apply to some but not all of the Funds. Investors should refer to the applicable Governing Fund Documents for a more comprehensive description of the various risks applicable to each Fund. General Investment Risk. Investments, including that of the Funds, are subject to the general risks associated with the underlying businesses, including general economic and market conditions, changes in regulatory requirements and laws (including laws relating to taxation of the Funds’ investments), reliance on management at the company level, interest rate and currency fluctuations, high inflation rates, general economic downturns, economic uncertainty, domestic and foreign political situations, and other factors. All of the Funds’ investments risk the loss of capital. The Funds could incur material losses even if Rock Springs reacts quickly to difficult market conditions, and there can be no assurance that the Funds will not suffer material losses and other adverse effects from broad and rapid changes in market

conditions in the future. Thus, there can be no assurance that the Funds’ program will be successful or that an Investor will not lose some or all of its investment in the Funds. Cybersecurity Risk. The Funds are subject to risks associated with a breach in their cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from “hacking” by other computer users, other unauthorized access and the resulting damage and disruption of hardware and software systems, loss or corruption of data as well as misappropriation of confidential information. In recent years, cybersecurity attacks on companies, including companies in the financial services industry, have become increasingly prevalent. If a cybersecurity breach occurs, the Funds may incur substantial costs, including those associated with: forensic analysis of the origin and scope of the breach; increased and upgraded cybersecurity; investment losses from sabotaged trading systems; the impeding of trading; identity theft; unauthorized use of proprietary information; litigation; adverse investor reaction; the dissemination of confidential and proprietary information; and reputational damage. A cybersecurity breach could adversely affect the Funds and their investors by, among other things, interfering with the processing of shareholder transactions; impeding the ability to calculate net asset value; causing the release or misuse of confidential Funds information or private investor information (which may violate privacy and other laws, including those related to identity theft). Cybersecurity breaches may involve unauthorized access to a Fund’s digital information systems (e.g., through “hacking” or malicious software coding), and may come from multiple sources, including outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users) or cyber extortion, including exfiltration of data held for ransom and/or “ransomware” attacks that render systems inoperable until ransom is paid, or insider actions (e.g., intentionally or unintentionally harmful acts of Rock Springs personnel). In addition, cybersecurity breaches involving a Fund’s third-party service providers (e.g., the administrator and prime brokers), trading counterparties or issuers in which the Funds invest can also subject a Fund to many of the same risks associated with direct cybersecurity breaches or extortion of data. Although Rock Springs has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because the Funds do not directly control the cybersecurity systems of issuers in which a Fund may invest, trading counterparties or third-party service providers to the Funds. Such entities have experienced cyber attacks and other attempts to gain unauthorized access to systems from time to time, and there is no guarantee that efforts to prevent or mitigate the effects of such attacks or other attempts to gain unauthorized access will be successful. There is also a risk that cybersecurity breaches are not detected. There can be no assurance that the Funds will not suffer losses relating to cyber attacks on the Funds, their service providers, trading counterparties or the issuers in which the Funds invest. Any cybersecurity breach could expose Rock Springs and/or the Funds to civil liability as well as regulatory inquiry and/or action. Financial Institution Risk/Distress Events. An investment in the Funds is subject to the risk that one of the Funds’ banks, brokers, hedging counterparties, lenders or other custodians of some or all of the Funds’ assets (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty, similar to events that occurred in the United States banking sector in March 2023 (each, a “Distress Event”). Distress Events can be caused by factors including eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. In the event a Financial Institution experiences a Distress Event, the Funds and/or their portfolio companies may not be able to access deposits, borrowing facilities or other services

for an extended period of time or ever. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (“FDIC”), in the case of banks, or the Securities Investor Protection Corporation (“SIPC”), in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. Although in recent years governmental intervention has resulted in additional protections for depositors, there can be no assurance that governmental intervention will be successful or avoid the risk of loss, substantial delays or negative impact on banking or brokerage conditions or markets. Any Distress Event has a potentially adverse effect on the ability of Rock Springs to manage the Funds and their investments, and on the ability of Rock Springs, the Funds and/or portfolio companies to maintain operations, which in each case could result in significant losses and unconsummated investment acquisitions and dispositions. Such losses have the potential to include the Funds to pay fees and expenses in the event the Funds are not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of investors to make capital contributions or otherwise), as well the inability of the Funds to acquire or dispose of investments at prices that the relevant General Partner believes reflect the fair value of such investments and/or the inability of portfolio companies to make payroll, fulfill obligations and maintain operations. Although Rock Springs expects to exercise contractual remedies under the agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. Many Financial Institutions require, as a condition to using their services or otherwise, that Rock Springs and/or the Funds maintain all or a set amount or percentage of their respective accounts or assets with the custodian, which heightens the risks associated with a Distress Event with respect to such custodians. Although Rock Springs seeks to do business with custodians that it believes are creditworthy and capable of fulfilling their respective obligations to the Funds, Rock Springs is under no obligation to use a minimum number of custodians with respect to any Fund, or to maintain account balances at or below the relevant insured amounts. Leverage and Borrowing Risks. The Funds have the power to borrow funds and will do so when deemed appropriate, including enhancing the Funds’ returns and satisfying withdrawal requests that would otherwise result in the premature liquidation of investments. The Funds may borrow funds from broker-dealers, banks and other lenders to finance trading operations, which borrowings may be secured by assets of the Funds. The use of such leverage can, in certain circumstances, increase the losses to which the Funds’ investment portfolios may be subject. Any event that adversely affects the value of an investment would be magnified to the extent that an asset or the Funds are leveraged. The cumulative effect of the use of leverage by the Funds in a market that moves adversely to the Funds’ investments could result in a substantial loss to the Funds, which would be greater than if the Funds were not leveraged. Leverage may be achieved through, among other methods, direct borrowing, purchases of securities on margin and the use of options, futures, forward contracts, repurchase and reverse repurchase agreements, swaps and other derivative instruments. The access to capital could be impaired by many factors, including market forces or regulatory changes. Illiquid Investments. The Funds invest in securities that are illiquid, that are not publicly traded and/or for which no market is currently available, and the Funds may not be able to sell or otherwise dispose of such securities on a short-term basis. Such non-publicly traded securities and financial instruments may not be readily disposable and, in some cases, may be subject to contractual, statutory or regulatory

prohibitions on disposition for a specified period of time. The market value of a Fund’s investments will fluctuate with, among other things, changes in prevailing interest rates, general economic conditions, the condition of financial markets, developments or trends in any particular industry and the financial condition of the issuers of the securities in which the Funds invest. During periods of limited liquidity and higher price volatility, a Fund’s ability to acquire or dispose of investments at a price and time that is advantageous may be impaired. As a result, in periods of rising market prices, the Funds may be unable to participate in price increases fully to the extent that the Funds are unable to acquire desired positions quickly. Conversely, the Funds’ inability to dispose fully and promptly of positions in declining markets will cause net asset value to decline as the value of unsold positions is marked to lower prices. Special Investments. The Funds may commit capital to special investments in which only Investors who have elected to participate in special investments at the time of designation will participate. Notwithstanding the foregoing, in the case of an investment that initially was not a special investment that subsequently is designated as a special investment, all investors that are Investors at the time that such special investment is designated as such will participate in such special investment. These special investments may be highly illiquid, and the assets, liabilities, profits and losses attributable to such special investments will be reflected only in Investors’ special investment accounts, and Investors will not receive any proceeds from special investments until they are undesignated. Investors may, however, be subject to tax on their participation in special investments prior to their undesignation. Any capital allocated to a special investment will not be available for withdrawal until such special investment is undesignated, if at all. Thus, each Investor is likely to encounter a substantial delay after its requested withdrawal date in receiving withdrawal proceeds relating to special investments, and the risk of loss associated with such special investments will remain with the Investor. Although only a subset of the Investors may participate economically in a particular special investment—e.g., only those Investors who had elected to participate in special investments at the time of designation—for state law purposes, all the assets of the Fund will be subject to any losses or liabilities, such as those resulting from litigation, relating to any such special investment. Once a Fund has committed capital to a special investment, it may have little, if any, ability to reduce the Fund’s exposure to such special investment for a substantial period of time, even if the Fund’s overall portfolio has become over-concentrated in the applicable market sector. Investments in Unlisted Securities. The Funds invest in unlisted securities. Because of the absence of any trading market for these investments, it may take longer to liquidate, or it may not be possible to liquidate, these positions that would be the case for publicly traded securities. Although these securities may be resold in privately negotiated transactions, the prices realized on these sales could be less than those originally paid by the Funds. Further, companies whose securities are not publicly traded will generally not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. Small to Medium Capitalization Companies. The Funds invest in the stocks of companies with smallto medium-sized market capitalizations. While Rock Springs believes these investments often provide significant potential for appreciation, these stocks, particularly smaller capitalization stocks, involve higher risks in some respects than do investments in larger capitalization stocks. For example, prices of these stocks are often more volatile than prices of larger capitalization stocks. In addition, due to thin trading in some of these stocks, an investment in these stocks may be more illiquid than investments in larger capitalization stocks.

Trading and Allocation Risks. The Allocation Procedures (defined below) involve complex and sometimes subjective judgments; although Rock Springs seeks to make such judgments in good faith and consistent with its obligations to the Funds, no assurance can be provided that Rock Springs’ judgments will prove correct or that trading and allocation decisions will result in the Funds achieving their investment objectives. Furthermore, while Rock Springs seeks to invest according to each Fund’s target portfolio parameters in specified sub-sectors (i.e., the desired investment in a particular security, in relation to total assets, that Rock Springs determines to be appropriate), the ultimate allocation to each security is subject to adjustment pursuant to the Allocation Procedures. Accordingly, on any particular day, an investment in a security could be allocated to a Fund such that, after the allocation on that day, such Fund’s holdings of the security would fall above or below such Fund’s target portfolio parameter for that security. When making trading and allocation decisions, Rock Springs relies on its available resources, which in some cases could be limited, particularly in challenging or uncertain markets. While Rock Springs performs trading and allocation functions consistently with the Allocation Procedures and its agreements with the Funds, there can be no assurance that Rock Springs’ available resources or its personnel responsible for allocation and trading decisions will ultimately result in the most favorable trades, allocations or returns to the Funds or Investors therein. Investments in Undervalued Assets. The Funds may seek to invest in undervalued securities. The identification of investment opportunities in undervalued assets is a difficult task, and there is no assurance that such opportunities will be successfully recognized or acquired. Returns generated from the Funds’ investments may not adequately compensate Investors for the business and financial risks assumed. An Investor should be aware that it may lose all or part of its investment in the applicable Feeder Fund. The Funds may be forced to sell, at a substantial loss, assets believed to be undervalued, if they are not in fact undervalued. In addition, the Funds may be required to hold such assets for a substantial period of time before realizing their anticipated value. During this period, a portion of the Funds’ funds would be committed to the assets purchased, thus preventing the Funds from investing in other opportunities. In addition, the Funds may finance such purchases with borrowed funds and thus will have to pay interest on such funds during such waiting period. Short Selling. The Funds’ investment portfolios generally include short positions. Short selling involves selling securities which are usually not owned and borrowing the same securities for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling allows the investor to profit from a decline in the price of a particular security to the extent that such decline exceeds the transaction costs and the costs of borrowing the securities. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying security could theoretically increase without limit, thus increasing the cost to the Funds of buying those securities to cover the short position. There can be no assurance that the securities necessary to cover a short position will be available for purchase. Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. Call Options. There are risks associated with the sale and purchase of call options. The seller (writer) of a call option which is covered (e.g., the writer holds the underlying security) assumes the risk of a decline in the market price of the underlying security below the purchase price of the underlying security less the premium received, and gives up the opportunity for gain on the underlying security above the exercise price of the option. The seller of an uncovered call option assumes the risk of a theoretically unlimited increase in the market price of the underlying security above the exercise price of the option. The securities necessary to satisfy the exercise of an uncovered call option may be unavailable for

purchase, except at much higher prices, thereby reducing or eliminating the value of the premium. Purchasing securities to cover the exercise of an uncovered call option can cause the price of the securities to increase, thereby exacerbating the loss. The buyer of a call option assumes the risk of losing its entire premium investment in the call option. Put Options. There are risks associated with the sale and purchase of put options. The seller (writer) of a put option which is covered (e.g., the writer has a short position in the underlying security) assumes the risk of an increase in the market price of the underlying security above the sales price (in establishing the short position) of the underlying security plus the premium received, and gives up the opportunity for gain on the underlying security if the market price falls below the exercise price of the option. The seller of an uncovered put option assumes the risk of a decline in the market price of the underlying security below the exercise price of the option. The buyer of a put option assumes the risk of losing its entire investment in the put option. Derivatives. The Funds may use derivative financial instruments, including, without limitation, warrants, options, swaps, convertible securities, notional principal contracts, contracts for differences, forward contracts, futures contracts and options thereon, and may use derivative techniques for hedging and for other trading purposes. The use of derivative instruments involves a variety of material risks, including the extremely high degree of leverage often embedded in such instruments and the possibility of counterparty or clearinghouse non-performance as well as of material and prolonged deviations between the actual and the theoretical value of a derivative, due to, for example, nonconformance to anticipated or historical correlation patterns. In addition, the markets for certain derivatives are frequently characterized by limited liquidity, which can make it difficult and costly to the Funds to close out positions in order either to realize gains or to limit losses. Equity Securities. The Funds invest in equity securities. Numerous inter-related and difficult-toquantify economic factors, as well as market sentiment, subjective and extraneous political, climaterelated and terrorist factors, influence the performance of equities. There can be no assurance that Rock Springs will be able to anticipate future performance correctly. The Funds’ equity positions may be leveraged, and even comparatively minor adverse market movements can result in substantial losses. The value of a stock in which the Funds invest may decline due to general weakness in the stock market or because of factors that affect a company or a particular industry. The Small Capitalization Biotechnology Sector. The speculative nature of small capitalization biotechnology companies creates a high degree of risk. The Funds invest in small biotechnology issuers which are subject to significant scientific, financial, regulatory and marketing risks, among others. In addition, the prices of small capitalization biotechnology securities are subject to significant fluctuation and are often more volatile than the prices of the securities of larger capitalization companies. Although Rock Springs may succeed in identifying undervalued securities, there can be no assurance that stock prices will reflect the actual value identified by Rock Springs over the time frame during which the Funds hold investments. Binary Events. The Funds invest in therapeutics, biotechnology and other companies that may be subject to anticipated “binary events” in the form of anticipated clinical trial results or regulatory agency news or decisions. The market value of the securities of certain of these companies may be particularly sensitive to such binary events. Often, the success or failure of a therapeutics, biotechnology or other company in which the Funds invest will be dependent on the outcome of a binary event such as the approval of the company’s single major drug.

Investments May Be Volatile. The prices of the Funds’ investments can be highly volatile. Price movements of the instruments in which the Funds’ assets are invested may be influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. In addition, governments from time to time intervene, directly and by regulation, in certain markets, particularly those in currencies, financial instruments, futures and options. Such intervention often is intended directly to influence prices and may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. The Funds also will be subject to the risk of the failure of any exchanges on which their respective positions trade or of the clearinghouses of such exchanges. Industry Risk. A fund that focuses its investments in specific industries or sectors is more susceptible to developments affecting those industries and sectors than a more broadly diversified fund. Because the Funds invest significantly in healthcare companies, the Funds may perform poorly during a downturn in that industry. Healthcare companies can be adversely affected by, among other things, legislative or regulatory changes, competitive challenges, government approval of products and services, and product obsolescence. The securities of companies in the healthcare sector, especially those of smaller, researchoriented companies, tend to be more volatile than the overall market. The success of investments in the healthcare sector is often based upon expectations about future products, research progress, and/or new product filings and approval with regulatory authorities. In addition, a number of these companies may have limited operating histories. As a result, these companies may face undeveloped or limited markets, have limited products, have no revenue or profit-making history, operate at a loss, have limited access to capital and/or be in the developmental stages of their business. Diseases, Pandemics and Epidemics. The impact of diseases, epidemics and pandemics could have a negative impact on the Master Fund, its investments and their performance and financial position. Coronavirus (or new variants thereof), renewed outbreaks of other epidemics or pandemics or the outbreak of new epidemics or pandemics could result in health or other government authorities requiring the closure of offices or other businesses and could also result in a general economic decline. For example, such events could adversely impact economic activity through disruption in supply and delivery chains. Moreover, Rock Springs’ operations and those of the Funds and its investments could be negatively affected if personnel are quarantined as the result of, or in order to avoid, exposure to a contagious illness. Similarly, travel restrictions or operational issues resulting from the rapid spread of contagious illnesses could have a material adverse effect on business and results of operations. A resulting negative impact on economic fundamentals and consumer confidence could negatively impact market value, increase market volatility, cause credit spreads to widen, and reduce liquidity, all of which could have an adverse effect on the business of the Investment Manager, the Master Fund and its investments. The duration of the business disruption and related financial impact caused by a widespread health crisis cannot be reasonably estimated. The effects of a public health emergency, including, without limitation, the COVID-19 pandemic, could materially and adversely impact (a) the value and performance of the Funds and (b) the ability of the Funds to continue to meet loan covenants, post margin or repay loans on a timely basis or at all, or (c) the Funds ability to source, manage and divest investments and the Funds ability to achieve its investment objective, all of which could result in significant losses to a Fund. The foregoing market conditions could cause a Fund to write down assets materially as the fair market value of its investments could be reduced in light of a potential or actual economic decline or recession, decline in or lack of consumer confidence or uncertain and volatile market conditions that are difficult to assess or predict. In addition, the operations of Rock Springs and the Funds and each of their

respective affiliates have the potential to be significantly impacted, or even temporarily or permanently halted, as a result of government quarantine measures, voluntary and precautionary restrictions on travel or meetings and other factors related to a public health emergency, including its potential adverse impact on the health of any such entity’s personnel. Political Uncertainty. Some of the results of recent elections and referenda around the world have been unexpected and resulted in material market changes and increases in market uncertainty. The future of current regulations, or the adoption of new regulations, is also uncertain. These uncertainties may have adverse impacts on or alternatively create investment opportunities for the Funds. Trade and Tariff Developments. The U.S. government has recently imposed, and may in the future increase, tariffs on specific countries and commodities. In response, certain foreign trading partners imposed retaliatory tariffs on certain U.S. goods, and others may do the same in the future. These developments have created significant uncertainty about the future relationship between the United States and certain other countries with respect to trade policies, treaties and new and increased tariffs. These developments, or the continued uncertainty relating U.S. trade policies, may have a material adverse effect on global economic conditions and the stability of global financial markets, and may reduce global trade and, in particular, trade between the impacted nations and the United States. Market Abuse. Any fraud, price manipulation, market abuse or improper influence in markets in which the Funds directly or indirectly invest may have a material adverse effect on the Funds. There can be no assurance that any form of regulation or any market constraints would prevent fraud, price manipulation, market abuse, or improper influence in the future. Moreover, there can be no assurance that any redress would be available to, or would be practical for, the Funds to pursue with respect to any particular fraud, price manipulation, market abuse, or improper influence. Climate Change. Ongoing changes to the climatic conditions in which the Funds operate and invest may have an adverse impact on the Fund and their investments. While the precise future effects of climate change are unknown, it is possible that changes in weather patterns or extreme weather (such as floods, hurricanes and other storms) could, among other adverse impacts, damage Fund investments. Significant increases in precipitation levels or wind could cause damage to Fund investments and can create periods in which Fund investments are inoperable. Further, rising sea levels could, in the future, adversely affect the value and operations of any low-lying coastal portfolio companies, resulting in the imposition of new taxes or increase applicable insurance rates. Climate change may also give rise to changes in regulations and consumer sentiment that could have a negative impact on the operations of the Fund and their investments by increasing their operating costs or restricting or decreasing demand for their activities, among other effects. The adverse effects of climate change and related regulation at state, federal and international levels could have a material adverse effect on the business, financial position, results of operations or cash flows of Funds and their investments. Any of the foregoing could adversely affect the value of Fund investments and their performance. Governmental Intervention; Market Disruptions; Dodd-Frank Wall Street Reform and Consumer Protection Act. The global financial markets have in prior years gone through pervasive and fundamental disruptions that have led to extensive and unprecedented governmental intervention. Such intervention was in certain cases implemented on an “emergency” basis, suddenly and substantially eliminating market participants’ ability to continue to implement certain strategies or manage the right of their outstanding positions. In addition, as one would expect given the complexities of the financial markets and the limited time frame within which governments have felt compelled to take action, these interventions have often been unclear in scope and application, resulting in confusion and uncertainty which in itself can be materially

detrimental to the efficient functioning of the markets as well as previously successful investment strategies. In the case of any future market disruptions, it is impossible to predict what additional interim or permanent governmental restrictions (or easing of restrictions) may be imposed on the markets or the effect of such restrictions on Fund strategies. Geopolitical Risks and Force Majeure. An unstable geopolitical climate and continued threats of terrorism could have a material adverse effect on general economic conditions, market conditions and market liquidity. For example, a shifting political landscape may increase volatility in the market or alter the regulation of the investment industry as a whole. In addition, increased focus and scrutiny of globally operating organizations may adversely affect the Funds and their investment activities. Additionally, a serious pandemic or a natural disaster could severely disrupt the global, national and/or regional economies. Geopolitical tensions, including the conflict between Russia and Ukraine, the ongoing conflict between the U.S. and Iran, tensions between the U.S. and China, tensions between Taiwan and China, the ongoing conflicts between Israel and Hamas (including attacks on merchant ships in the Red Sea) and the further escalation of tensions between Israel and various countries in the Middle East and North Africa, could lead to uncertainty, severe disruption to supply chains across sectors and industries worldwide and volatility in global markets and industries that could negatively impact the Funds and portfolio companies. Further, political uncertainty caused by, among other things, populist political parties and economic nationalist sentiments could have repercussions across regional and global financial markets, which could adversely affect the valuations of the Funds’ investments. Moreover, certain current events and resulting movements (including protests) have caused social unrest in the United States and in other parts of the world. At times, such movements have been accompanied by violence and looting which has seen certain businesses suffer physical damage and economic loss. In addition, such movements have seen certain businesses become subject to adverse publicity and heightened scrutiny as a result of historical action or inaction. To the extent that one or more Funds invest in portfolio companies that are impacted by such social unrest, physical damage and economic loss or the threat thereof (e.g., in the health services sector), there could be a material adverse impact on the Fund and their investments. Additionally, the Funds or their portfolio companies may be affected by force majeure events such as events beyond the control of the party claiming that the event has occurred including, without limitation, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern (see further “Diseases, Pandemics and Epidemics”), war, cyber-attacks, terrorism and labor strikes. Some force majeure events may adversely affect the ability of a party, including the Funds, a portfolio company or a counterparty to the Funds to perform its obligations until it is able to remedy the force majeure event. In certain circumstances, the Funds or a portfolio company of the Funds may be parties to a contract that does not provide a remedy in favor of the Funds or such portfolio companies if a force majeure event occurs. In this event, the Funds or such portfolio companies may be required to continue to comply with their obligations (including, but not limited to, payment or performance of their obligations) under the contract even though they may not receive some or all of the benefits to which they are entitled under such contracts. Such a circumstance may cause the Funds or such portfolio companies to suffer economic loss, and such loss may be exaggerated if a force majeure event subsists for an extended period of time. United Kingdom (“U.K.”) Membership in the E.U. The U.K. ceased to be a member of the E.U. on January 31, 2020 (“Brexit”). Uncertainties remain relating to certain aspects of the U.K.’s future

economic, trading and legal relationships with the E.U. and with other countries. Ongoing regulatory divergence in financial services, clearing, data and disclosure, as well as new border controls and rules of origin, may affect market access, costs and valuations. The framework is subject to review and political change, and uncertainties remain relating to certain aspects of the U.K.’s future economic, trading and legal relationships with the E.U. and with other countries. Risks Specific to the Healthcare Industry A fund that focuses its investments in specific industries or sectors is more susceptible to developments affecting those industries and sectors than a more broadly diversified fund. Because the Funds invest in the securities of companies in the healthcare, life sciences and related industries (including biotechnology companies), the Funds may perform poorly during a downturn in such industries. Such industries can be adversely affected by, among other things, uncertainty with respect to legal and regulatory requirements, legislative or regulatory changes, government enforcement activity (including lawsuits initiated by whistleblowers), competitive challenges, requirements for government approval and ongoing marketing of products and services, coverage of and/or reimbursement for products and services by third-party payors (including, for example, government healthcare programs), consumer demand for products and services, and product obsolescence. The securities of companies in the healthcare, life sciences and related industries and sectors, especially those of smaller, research-oriented companies, tend to be more volatile than the overall market. The success of investments in the healthcare and life sciences sectors is often based upon expectations about future products and services, research progress, and/or new product filings, product approval by regulatory authorities, and adequate coverage and reimbursement by third-party payors (including, for example, government healthcare programs). In addition, a number of these companies have limited operating histories. As a result, these companies face undeveloped or limited markets, have limited products or services, have no revenue or profit-making history, operate at a loss, have limited access to capital and/or be in the developmental stages of their businesses, with high risks of not being able to launch their products or services and of not becoming profitable. Affordable Care Act Risks; Inflation Reduction Act Risks; Health Care Reform. In March 2010, the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act (collectively known as the “ACA”) became federal law in the United States. This law substantially changed the way healthcare is financed by both governmental and private third-party payors, and significantly affected the healthcare industry. The ACA included provisions that, among other things, changed numerous aspects of the federal healthcare programs, reduced and/or limited Medicare reimbursement to healthcare providers, required all individuals to have health insurance (with limited exceptions) and imposed new and/or increased taxes. There is substantial uncertainty regarding the ACA’s future in light of recent and potential future judicial challenges and legislative amendments. Other legislative changes have been proposed and adopted in the United States since the ACA was enacted. Future federal healthcare reform measures have been proposed and will likely be adopted, in some form, in the future. There is significant uncertainty regarding the future of the ACA and healthcare reform measures under the current presidential administration. The healthcare industry faces risks related to the Inflation Reduction Act (IRA), including potential financial challenges for providers, increased competition, and the need to adapt to new regulations and cost-sharing requirements. The IRA aims to lower prescription drug costs for Medicare beneficiaries by

allowing the government to negotiate prices for certain drugs and imposing rebates on price hikes exceeding inflation. This could lead to reduced revenue for portfolio companies and potentially impact the financial stability of other portfolio investments that rely on those drugs. The IRA’s provisions to lower prescription drug costs could lead to increased competition among drug manufacturers and providers, as they strive to maintain market share and profitability, which could negatively impact the performance of a Fund. The IRA prohibits health plans from imposing cost-sharing on items or services essential to preventive care services. This could lead to a shift in healthcare spending towards preventive care and potentially affect the revenue streams of providers who specialize in other areas of care. It is difficult to predict the impact of the ACA, IRA, and any future healthcare reform measures, including regulatory changes to the Medicare Advantage business, or proposals on the Funds and the healthcare and healthcare-related industries in which they invest. Certain of these proposals, if enacted, could have far-reaching implications for the healthcare and healthcare-related industries and the companies in which the Funds invest, including without limitation placing downward pressure on prices and potentially reducing revenues. Moreover, even if broader healthcare reform legislation is not enacted in the near term, continued advocacy for an expanded government role in healthcare and continued introduction of legislation promoting such changes by members of Congress could result in increasing uncertainty regarding the future direction of the healthcare, healthcare-related, and life sciences industries, which uncertainty could itself have material adverse effects on companies in which the Funds invest and, thereby, the Funds. Various healthcare reform proposals have also emerged at the state level. Rock Springs cannot predict the impact that these federal and state healthcare reforms will have on the Funds or the companies in which the Funds invest. The ACA, IRA, and other reforms may lower reimbursements for the products approved for sale in the United States, reduce medical procedure volumes relating to such approved products, impact demand for such products or the prices at which such products may be sold, which could have a material adverse effect on a company’s business, financial condition and results of operations, which may, in turn, negatively impact the Funds’ returns. Technological Obsolescence. Certain healthcare and medical technology-related businesses are characterized by single-product focus and rapidly changing technologies. Success in a business with a single-product focus is particularly sensitive to technological changes and the development of alternative competing products. These changes and developments may render existing products and technologies obsolete. Volatility in Market Value. The market value of healthcare and healthcare-related companies in general has been highly volatile, with significant price fluctuations that are often unrelated to the operating performance of particular companies. Unanticipated Delays and Uncertainty of Product Development. Unanticipated problems may arise in connection with the development of new products or technologies, and many of such efforts could ultimately be unsuccessful. For example, in the United States, the Food and Drug Administration (“FDA”) is responsible for the approval of new drugs, the licensure of biological products, and the clearance or approval of medical devices (including some health-related software), under the Federal Food, Drug, and Cosmetic Act, the Public Health Service Act, and implementing FDA regulations. The FDA also regulates, and in some cases must grant prior approval for, clinical use in human subjects of investigational products. The FDA’s clearance, licensure, and approval processes are inherently unpredictable and in many cases the success or failure of the companies in which the Funds invest will depend on the outcome of these processes. The approval process for obtaining marketing authorization typically takes many years, and is extremely expensive and uncertain. In addition, as part of the process

for obtaining marketing authorization, companies may need to conduct in vitro and in vivo preclinical studies involving animals, and may need to obtain FDA approval for, and conduct, clinical trials involving humans. Clinical trials may require submission, and FDA approval, of an investigational new drug application or an investigational device exemption prior to commencement of any clinical trials. In addition, clinical trials are subject to continuing oversight, including by the FDA, institutional review boards, and data safety monitoring boards. At any time, the FDA may place a clinical trial on partial or full clinical hold if, among other things, it believes that a clinical trial either is not being conducted in accordance with FDA requirements or presents an unacceptable and significant risk to clinical trial patients, including as a result of a serious adverse event, concerns with a class of product candidates or after an inspection of the clinical trial operations, trial sites or manufacturing facilities. Even if results from preclinical studies are favorable, the results in clinical trials on humans may differ, and results from initial clinical trials may not reflect those obtained in later stage trials. Preclinical studies and clinical trials are costly and lengthy and the results of these studies and trials are highly uncertain. Notifications or applications to market a drug, biological product, or medical device may require different types of scientific data, which may include performance testing, in vitro and in vivo preclinical studies, and clinical studies. Even if a sponsor conducts all required scientific investigations to support a notification or application to market a drug, biological product, or device, the sponsor may nonetheless be unable to obtain marketing authorization for a candidate drug, biological product, or medical device for a number of reasons. If a company in which a Fund invests is unable to obtain these approvals in a timely fashion, or if after approval for marketing, a product is later determined to be ineffective or to have unacceptable side effects not discovered during testing, the company may experience significant adverse effects, which in turn, could negatively affect the performance of the Fund. Delays in commercializing products may therefore result in the need to seek additional capital, potentially diluting the interests of investors. These various factors may result in abrupt advances and declines in the securities prices and/or valuation of particular companies in the healthcare industry and, in some cases, may have a broad effect on the prices of securities of companies in particular segments of the healthcare industry generally. Investing in Pharmaceutical and Medical Device Manufacturers; Costs and Risks Associated with Regulatory Approval Over Products. The development, testing, manufacturing and marketing of products by pharmaceutical, biotechnology and medical device manufacturers are subject to extensive regulation by numerous governmental authorities in the United States and other countries. The process obtaining marketing authorization for products from the FDA is typically costly and time consuming for pharmaceutical and medical device companies, and the success of certain of the Funds’ investments may be dependent upon obtaining such government approvals, licenses, or clearances. Even if the regulatory approval, licensure or clearance of a product is granted, the approval may be subject to limitations on the uses for which the product may be marketed, or the conditions of approval may require costly post-marketing testing and surveillance to monitor the safety, purity, potency or efficacy of the product. Any adverse effects observed after the approval and marketing of the product could cause the withdrawal of the product from the marketplace. If a company in which the Funds invest is unable to obtain necessary regulatory approvals in a timely fashion, or if after approval for marketing, a product is later determined to be ineffective or to have unacceptable side effects not discovered during testing, such company may experience significant adverse effects, which in turn, could negatively affect the performance of the Funds. Dependence on Single Products. Certain companies in which the Funds invest may only have one product under development. There can be no assurance that any such product will be approved, cleared, or licensed for marketing by the FDA or any other U.S. or non-U.S. regulatory agency. Further, competition to such product may develop from other new and existing products. In either case, if a

company is dependent on one product, the consequences of such failure could be devastating to the prospects of such company, which in turn could negatively affect the performance of the Funds. Third-Party Coverage and Reimbursement. The ability of certain companies in the healthcare, healthcare-related, and life sciences industries to commercialize certain of their products and product candidates and/or provide services depends, in part, upon the availability of reimbursement from thirdparty payors, such as federal and state government healthcare programs, private health insurers, managed care organizations, and other payors. Government and other third-party payors increasingly attempt to contain costs by limiting both coverage and level of reimbursement for certain products and services. If government and third-party payors do not provide adequate coverage and reimbursement levels for certain products and services, the market acceptance of those products and services may be drastically limited, with such limitation resulting in harm to the companies’ businesses. Investment in Companies Dependent Upon Scientific Developments and Technologies. The Funds invest in biopharmaceutical companies. Biopharmaceutical companies are subject to a unique set of risks, including: (i) rapidly changing science and technologies; (ii) new competing products and improvements in existing products which may quickly render existing products or technologies obsolete; (iii) exposure, in certain circumstances, to a high degree of government regulation, making these companies susceptible to changes in government policy and failures to secure, or unanticipated delays in securing, regulatory approvals, licensures, or clearances; (iv) exposure related to the outcome of clinical trials; (v) scarcity of management, technical, scientific, research and marketing personnel with appropriate training; (vi) actual or perceived safety and efficacy issues of their products; (vii) the possibility of lawsuits related to intellectual property rights; and (viii) rapidly changing investor sentiments and preferences with regard to healthcare sector investments (which are generally perceived as risky). Potential Conflicts of Interest Valuation of Assets. Securities and other assets in which the Funds invest are valued by Rock Springs in accordance with Rock Springs’ valuation policy, which may be amended from time to time in the discretion of Rock Springs. In making valuation determinations, Rock Springs is conflicted because the valuation of such securities and other assets affects its compensation. There is no guarantee that the value determined by Rock Springs will represent the value that will be realized by the Funds on the eventual disposition of the investment or that would, in fact, be realized upon an immediate disposition of the investment. Additionally, the Funds’ portfolio of investments will, at any given time, include securities or other financial instruments or obligations that are very thinly traded or for which no market exists or that are restricted as to their transferability under applicable securities laws. These investments may be extremely difficult to value accurately. The value of any investment on any valuation date is intended to represent the fair value of such investment on such date based upon the amount at which the investment could be exchanged between willing parties, other than in a forced liquidation sale, and is an estimate of such value using the methodology described in Rock Springs’ valuation policy. Any valuation of an investment may not reflect the actual amount received by the Funds upon the liquidation of such investment. In addition, the timing of liquidations of investments may also affect the prices obtained upon such liquidations. General Economic Conflicts. Certain of the Funds’ terms possess inherent conflicts of interests for Rock Springs, including, without limitation incentive allocations (which may incentivize Rock Springs to take greater risks in investing the Funds’ capital due to the General Partner’s potential to share in the

increased profits that might result) and the withdrawal provisions (which may incentivize the General Partner to delay withdrawals to maximize the net asset value of the Fund in order to increase the amount of management fees or potential for incentive allocations to it). Allocation of Investment Opportunities. Rock Springs has financial and other incentives to favor a Fund that charges higher fees (including potentially more lucrative incentive fees allocation) or a Fund or account that is proprietary or has a higher percentage of proprietary capital, or to otherwise employ more leverage over such Funds. As the allocation of investment opportunities among the Funds creates conflicts of interest, Rock Springs has established and maintains policies and procedures, which it will amend from time to time, that it believes are reasonably designed to assure that investment opportunities which are determined by Rock Springs to be appropriate for more than one account are allocated among accounts fairly and equitably under the circumstances and in a manner that is consistent with applicable law and contractual obligations (the “Allocation Procedures”). The Allocation Procedures do not guarantee that a Fund will invest in each opportunity that would be permissible or that it will invest any particular amount of its assets in an investment opportunity. Rather, Rock Springs evaluates the appropriateness of each investment opportunity that is potentially suitable for multiple Funds (a “common opportunity”) (including the relative amount to be purchased or sold) based on the particular circumstances of the opportunity and each account in light of the characteristics of, and Rock Springs’ expectations as to, the opportunity, the investment objectives and restrictions for the particular account, applicable law and other relevant considerations as set forth in the Allocation Procedures. In some cases, Rock Springs will determine, based on the Allocation Procedures, including the factors described below, that a common opportunity to purchase or sell an investment, while permissible for multiple Funds, is appropriate for, or in the best interest of, one Fund but not another Fund, in which case the Fund for which such opportunity is most appropriate would generally purchase or sell the full amount of the common opportunity that Rock Springs deemed appropriate. Such determinations could adversely impact the returns of one Fund on an absolute basis or relative to those of another Fund based on the subsequent performance of the security in question. Rock Springs expects that, in many cases, it will determine, based on the Allocation Procedures and the considerations described above, that a particular common opportunity to purchase or sell a security is appropriate for multiple Funds. When Rock Springs determines that a common opportunity which relates to a new investment and/or trading decision is appropriate for multiple Funds, Rock Springs will determine, based on the Investment Factors (as described below), whether to allocate it among the Funds pro rata according to the formula set out in the Allocation Procedures, or whether a non-pro rata allocation is in the best interests of the Funds including, but not limited to, in circumstances where one Fund requires additional exposure to an investment in order to achieve Rock Springs’ desired target portfolio parameters with respect to such investment, while another Fund has already achieved the target portfolio parameters relevant to the investment, which would result in relatively less (or none) of the common opportunity being allocated to such other Fund, so long as such other Fund receives fair and equitable investment allocations over time, as determined in good faith by Rock Springs. As a general matter, common opportunities in private investments will be allocated on an adjusted pro rata basis, with adjustments made to reflect target portfolio parameters of the Funds, the Investment Factors and these additional factors: (i) the investment limitations and targets for private securities of the Funds; (ii) anticipated time between private investment and initial public offering; (iii) weight of existing private portfolio in each of the Funds, and anticipated near term changes to that weighting due to expected initial public offerings or acquisitions; and (iv) the level of risk presented by the investment relative to the current portfolio and risk tolerance of the Funds.

In order to mitigate conflicts of interest associated with allocation of common opportunities, the Allocation Procedures are intended to result in investment opportunities that Rock Springs reasonably concludes are appropriate for each Fund being allocated fairly and equitably in a manner that is in the accounts’ overall best interests. Under the Allocation Procedures, when determining whether a common opportunity is appropriate for the Funds and allocations among the Funds, Rock Springs considers the Funds’ respective objectives, policies and restrictions, and other factors (“Investment Factors”) such as: (i) the investment objectives, policies and restrictions of the Fund, as set forth in the Governing Fund Documents; (ii) portfolio risk, diversification or investment concentration parameters for the Fund; (iii) market and/or issuer criteria and considerations relevant to the Fund, including but not limited to determining whether, at the time a common opportunity is considered, the Fund is already sufficiently exposed to the relevant issuer; (iv) the characteristics of the common opportunity (including expected return, type of security, seniority in the capital structure, and call and put features), as relevant to the Fund; (v) the size of the available common opportunity; (vi) tax efficiencies, potential adverse tax consequences, and other tax considerations applicable to the Fund; (vii) targeted asset size of the Fund; (viii) the avoidance of de minimis investments or allocation amounts; (ix) whether the Fund has significant excess liquidity or a significant need for liquidity (i.e., whether the Fund has excess cash to invest as a result of a capital call or an influx of new cash from new investors or where the Fund has a need for significant liquidity to fund withdrawal requests that requires the sale of a portion of the public securities in the Fund’s portfolio); (x) the timing of anticipated inflows and outflows of capital of the Fund; (xi) targeted leverage level of the Fund; (xii) the amount of capital/cash the Fund has available for investment; (xiii) available liquidity of the Fund (including through borrowings, capital calls, or sales of liquid assets) and liquidity requirements for the Fund; (xiv) the capital structure characteristics of the Fund (i.e., whether the Fund is a drawdown fund or is fully-funded); (xv) legal and regulatory restrictions or considerations relevant to the Fund; (xvi) whether a portion of the Fund’s liquid assets should be preserved for other common opportunities; and (xvii) such other factors as may be relevant to the Fund in relation to the particular common opportunity. Special Investments. Rock Springs will have a conflict of interest in designating special investments, as doing so prevents any withdrawals from associated special investment accounts, which will continue to be included in the calculation of, and subject to, management fees and, upon undesignation, the incentive allocation. Rock Springs has a potential conflict of interest in undesignating a special investment where an Investor has withdrawn all of the capital account from which the special investment account amount was initially deducted. In this instance, Rock Springs has a potential incentive to undesignate a special investment prematurely. In such circumstances, Rock Springs also has a potential conflict of interest in not wanting to undesignate a special investment as such investments are included in the management fee base or undesignating would lead to an increase in the proportion of illiquid assets remaining in a Fund in which Rock Springs personnel invest. Transactions between the Funds and Rock Springs. Rock Springs or its affiliates may enter into “principal transactions” with the Funds within the meaning of Section 206(3) of the Advisers Act in which Rock Springs or such affiliate acts as principal for its own account with respect to the sale of a security to or purchase of a security from the Funds. Principal transactions will be completed in compliance with applicable law. In analyzing such principal transactions, Rock Springs will have a conflict between acting in the best interests of the Funds and assisting itself or its affiliates by selling or purchasing a particular security. Any such principal transactions will require approval, prior to settlement, by the Investors or their representatives as provided in the applicable Governing Fund Documents. Rock Springs may cause a Fund to purchase securities or other assets from, sell securities or other assets

to or engage in other transactions with another account managed by Rock Springs when Rock Springs believes such transactions are appropriate and in the best interests of such Funds. In the event Rock Springs wishes to reduce the investment of one or more of such clients in a security or other asset and increase the investment of other clients in such security or other asset, it may effect such transactions by directing the transfer of the securities or other assets between clients directly or by transferring the economic return of the securities or other assets between clients through swaps or other derivatives. When derivatives are used in such transactions, additional conflicts of interest can be introduced such as exposing a client to credit and execution risks. The transactions described above will be carried out in compliance with Rock Springs’ applicable fiduciary requirements, the applicable Governing Fund Documents and any legal or other requirements established by Rock Springs for the benefit of each Fund that participates in such transactions. Allocations of Expenses and Liabilities. Rock Springs may engage with U.S. and non-U.S. governmental entities regarding investments or matters related to the Funds. This could give rise to certain conflicts of interest, as Rock Springs may be forced to address multiple clients’ liabilities (including, but not limited to, tax liabilities) in a single negotiation with such a governmental entity, which could result in Rock Springs negotiating in a manner to provide the best outcome on an aggregate basis, whereas the interests between the Funds may not be aligned. To the extent Rock Springs has investments in any one or more such Funds, Rock Springs will have a conflict of interest in acting in a manner which benefits the Funds in which Rock Springs is invested. Non-Public or Confidential Information. Rock Springs and its affiliates or related persons may acquire material non-public and/or confidential information that may restrict by law, internal policies or otherwise Rock Springs from purchasing securities or other assets, or selling securities or other assets for themselves or their clients (including the Funds) or otherwise using or receiving such information for the benefit of Rock Springs and its affiliates or related persons or their clients. This could cause Rock Springs to be restricted (due to the receipt of “material non-public information” or other reasons) from participating in certain corporate event investments. Service Providers. Certain advisors, vendors or other service providers to the Funds and/or one or more companies in which the Funds hold an interest (collectively, the “Fund Entities”) also provide goods or services to—or have business, personal, financial or other relationships with—Rock Springs. Such advisors, vendors and service providers may include accountants, administrators, lenders, bankers, broker-dealers, attorneys, consultants, and investment or commercial banking firms (“Service Providers”). Such Service Providers may be investors in the Funds, sources of investment opportunities to the Funds or commercial counterparties of the Funds. Additionally, certain Rock Springs Personnel may have family members, friends or relatives that are employees of, investors in, consultants to, or otherwise have business relationships with, a Service Provider or an affiliate thereof, including relationships where such family members or relatives receive financial benefits from the Service Provider or an affiliate thereof. These relationships may influence Rock Springs or its affiliates in deciding whether to select or recommend such a Service Provider to perform services for a Fund. Notwithstanding the foregoing, Rock Springs will only select a Service Provider to perform services for a Fund to the extent Rock Springs or an affiliate thereof has determined that doing so is appropriate for the Fund given all surrounding facts and circumstances and is consistent with the Investment Manager’s responsibilities under applicable law, provided, however, Rock Springs may not necessarily seek out the lowest-cost option when engaging such Service Providers as other factors or considerations may prevail over cost.

Participation or Interest in Client Transactions Related Persons have investments in the Funds and/or other accounts managed by Rock Springs. In addition, Rock Springs directs the Feeder Funds’ investments into the applicable Master Fund, for which the General Partner serves as general partner. As a result, Related Persons have interests in investments that may also be recommended to clients. See “Conflicts of Interest” in Item 8 above for a summary of some of the circumstances in which such conflicts of interest arise. If such a conflict arises, Related Persons (including employees) are generally required to subordinate the interests of any other parties (or their own interest) to the Funds, and in any event would be required to disclose the conflicts. Personal Trading To mitigate the conflicts discussed above, except for investment in the Funds or accounts (including any proprietary accounts) managed by Rock Springs, employees must pre-clear certain personal securities transactions, including listed equity transactions and securities obtained through a private placement, before completing the transactions. Rock Springs may deny any proposed transaction, particularly if the transaction poses a conflict of interest or if Rock Springs is planning on transacting in the same security

at or about the same time on behalf of the Funds or any other account managed by Rock Springs. Transactions with respect to healthcare-related securities, public or private, (as determined by Rock Springs) as well as non-healthcare securities held by the Funds in their personal accounts (other than accounts managed by Rock Springs) will be subject to heightened scrutiny and pre-clearance requests may be denied at the CCO’s discretion. Such a situation could provide an incentive for a portfolio manager to trade in a way that would be advantageous to him or her personally but that would not be expected to have a positive effect on (and could even be adverse to) a Fund. Consideration of such matters is a factor in our decision as to whether permission will be granted for any particular transaction. See “Conflicts of Interest” under Item 8 above for additional information. Employees are also required to provide annual reports of holdings and quarterly reports of securities transactions in “Reportable Securities” as defined in the Advisers Act. Employees must disclose all personal trading accounts initially upon commencement of employment and annually thereafter Rock Springs will provide a copy of the Code to any client, Investor or qualified prospective client or Investor upon request. To review a copy of the Code, please contact Rock Springs by telephone at (410) 220-0130.

transactions are effected and the speed of error resolution, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the brokerdealer; the quality, comprehensiveness and frequency of research and other related services considered to be of value; the state of the broker-dealer’s facilities and computer trading systems; the quality of a broker-dealer’s confidentiality program; and the competitiveness of commission rates in comparison with other broker-dealers satisfying Rock Springs’ selection criteria. Accordingly, if Rock Springs determines in good faith that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the brokerage and products or services provided by such broker-dealer, the Funds may pay commissions to such broker-dealer in an amount greater than the amount another broker-dealer might charge for effecting the same transaction. Rock Springs has a Best Execution Committee which meets to evaluate the Funds’ brokerage arrangements. It should be noted that when Rock Springs uses client brokerage commissions to obtain research and related services, Rock Springs receives a benefit because it does not need to produce or pay for the research or other products or services. In addition, Rock Springs has an incentive to select or recommend a broker or dealer based on its interest in receiving the research or other products and services, rather than on the Funds’ interests in receiving best execution. Soft Dollar Benefits Section 28(e) of the Exchange Act provides a safe harbor that allows an investment adviser to pay more

than the lowest available commission in order to obtain brokerage and research services (commonly referred to as a “soft dollar” arrangement). This practice involves a conflict of interest, but Section 28(e) of the Exchange Act provides that it will not constitute a breach of Rock Springs’ fiduciary duty to the Funds if the services and products consist of eligible “research” and “brokerage” services and products and certain other conditions are met. Rock Springs will only use soft dollars to obtain products and services that fall within the safe harbor provided by Section 28(e) of the Exchange Act (provided, that from time to time, broker-dealers provide without being requested to do so, research or other products or services to most or all of their customers and Rock Springs accepts such products or services rather than producing or paying for the same from another provider). Where a product or service provided has both “eligible” uses under Section 28(e) (i.e., uses related to Rock Springs’ investment decision-making process) and other uses, Rock Springs will allocate the cost of any such product or service between the eligible and non-eligible uses in good faith. Only the percentage of the product/service that is used for brokerage/research may be paid with soft dollars. Research and brokerage services obtained by the use of commissions arising from the Funds’ portfolio transactions may be used by Rock Springs in its other investment activities. The Funds may not necessarily, in any particular instance, be the direct or indirect beneficiaries of such research or brokerage services. Because the Feeder Funds invest in Master Funds and all trading occurs at the Master Fund level, any soft dollar benefits that arise from client brokerage commissions paid by a Master Fund will benefit the Master Fund as the trading entity. To the extent that Rock Springs advises more than one entity that generates soft dollar benefits, Rock Springs will not necessarily allocate such benefits to the entities in proportion to the soft dollar benefits each entity generates. Rock Springs seeks to allocate soft dollar benefits in a fair and equitable manner. The types of products and services that Rock Springs received with client brokerage commissions in the past year included: research reports on companies, industries and securities; economic, market and financial data; access to broker-dealer analysts and corporate executives; and attendance at industry seminars and broker-dealer organized conferences. Investor Introductions Rock Springs may receive introductions to Investors through broker-dealers that execute trades on behalf of Rock Springs. Rock Springs does not believe that it pays any additional fees or higher commissions as a result of these introductions. Rock Springs seeks best execution on all transactions. However, Rock Springs has an incentive to select or use a broker-dealer based on receiving Investor referrals from that counterparty, rather than the Funds’ interest in receiving best execution. Rock Springs will only utilize a broker-dealer if the Best Execution Committee has determined that the arrangement would be in the Funds’ best interest, including considering the factors set forth above in this Item 12. Allocation of Investment Opportunities Rock Springs has established and maintains Allocation Procedures, which it will amend from time to time, that it believes are reasonably designed to assure that investment opportunities which are suitable and determined by Rock Springs to be appropriate for more than one Fund are allocated among such Funds fairly and equitably over time and in a manner that is consistent with applicable law and contractual obligations. The Allocation Procedures do not guarantee that any Fund will invest in each opportunity that would be permissible or that it will invest any particular amount of its assets in an investment opportunity. Rather, Rock Springs evaluates the appropriateness of each investment opportunity that is potentially suitable for more than one Fund (including the relative amount to be allocated among participating Funds) based on Funds’ objectives, policies and restrictions, as well as a

number of other factors specified in the Allocation Procedures and Governing Fund Documents. Allocation decisions sometimes involve subjective determinations by Rock Springs. See “Allocation of Investment Opportunities” in Item 8 above for additional information. Trade Aggregation If Rock Springs determines to buy or sell the same security using the same trading parameters (i.e., market vs. limit order, price, etc.) on behalf of more than one Fund at the same time, Rock Springs will generally, but is not obligated to, place an aggregated order for such accounts consistent with the duty to seek best execution. Where Rock Springs determines to implement a new investment or trading decision for a Fund on a contemporaneous basis, it expects to place such orders on an aggregated basis. Aggregated orders that result in partial fills will be allocated between participating Funds according to the Allocation Procedures. Trade Errors Trade errors may occur as a result of mistakes made on the part of broker-dealers, or mistakes on the part of Rock Springs’ personnel including portfolio managers and traders. Trade errors are an intrinsic factor in any complex investment process, and will occur notwithstanding the exercise of due care and special procedures designed to prevent trade errors. Trade errors are, therefore, distinguishable from errors in judgment, due diligence or other factors leading to a specific trading instruction being generated, as well as from unauthorized trading or other improper conduct by personnel. Trade errors might include, for example, keystroke errors that occur when entering trades into an electronic trading system, failures of oral communication between the portfolio managers and traders or typographical or drafting errors related to derivatives contracts or similar agreements. Rock Springs maintains trade error policies and procedures. In accordance with such policies and procedures, to the extent any trade errors occur, they will be (i) corrected by Rock Springs as soon as practicable after their discovery and (ii) corrected in a manner such that any profit and loss as a result of such trade errors are minimized. Rock Springs will strive to correct all trade errors prior to settlement. Trade errors are considered to be one of the costs of the Funds doing business. Thus, any profit or loss that results from a trade error is left in the account of the applicable Fund. Broker-dealers that cause trade errors as a result of their own mistakes may be responsible for any losses that result from such errors. The applicable Fund shall not be responsible for any losses resulting from trade errors and similar human errors (to the extent not borne by the relevant broker-dealer), absent Rock Springs’ bad faith, gross negligence, willful misconduct or fraud.

Subject to a Fund’s Governing Fund Documents, Investors generally receive (i) monthly performance summaries; (ii) annual audited financial reports; and (iii) annual tax information necessary to complete any applicable U.S. tax returns. Investors in certain Funds may be provided commentary on such Funds’ quarterly performance in quarterly investor letters.

Accordingly, ISS will generally vote proxies on behalf of the Funds in favor of management proposals, in accordance with ISS’ Proxy Voting Guidelines, available at https://www.issgovernance.com/. In cases where ISS recommends a vote against a management proposal, ISS will notify Rock Springs of the upcoming vote and of the proposal(s) for which ISS is recommending a vote against management. Rock Springs will then request ISS’ research report detailing the reasons for such recommendation(s). Rock Springs evaluates the report to determine whether to accept ISS’ recommendation(s). In the event that Rock Springs decides to vote a proxy (or particular proposals within a proxy) in a manner different from ISS’ recommendation, Rock Springs will document the reasons supporting the decision.

Rock Springs retains ultimate authority with regard to voting client securities and may override ISS’ recommendation or choose to abstain from voting if it determines, in its discretion, that the vote is not in the best interests of the Funds. Rock Springs retains all required documentation associated with proxy voting. Rock Springs has the authority to vote a proxy (or particular proposals within a proxy) contrary to ISS’ recommendation, including in the event of a material conflict of interest. In the event of a material conflict of interest where Rock Springs does not intend to accept ISS’ recommendation with regard to a proxy vote (or one or more proposals within a proxy), Rock Springs’ Proxy Committee (as defined in Rock Springs’ proxy voting policy) will review the particular proxy to determine whether a particular intended vote is in the Funds’ best interests. In addition, Rock Springs requires ISS to notify it if ISS experiences a material conflict of interest in the voting of the Funds’ proxies. If such material conflict of interest occurs, ISS procures independent research relating to such proxy vote and Rock Springs determines the appropriate vote. Rock Springs may abstain from voting client securities if exercising voting authority would impose costs on the Funds, including opportunity costs resulting from restricting the use of securities for lending in order to preserve the right to vote. In general, Rocks Springs believes it is in the Funds’ best interests to abstain from voting client securities that have been lent to third parties, rather than to incur the cost of recalling those securities in order to vote the accompanying proxy. A copy of Rock Springs’ proxy voting policies and procedures and information about how Rock Springs voted proxies may be obtained by contacting Rock Springs at (410) 220-0130.