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The Windacre Partnership LLC: investment adviser

The Windacre Partnership LLC is an investment adviser registered with the SEC (file 801-78978, CRD 168761). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$11.4B
Discretionary
100%
Accounts
3
Employees
8
In advisory roles
4
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles3$11.4B100.0%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Snehal Rajnikant AminPersonCEOE 75% or moreApr 2013Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Part 2A Brochure, filed Mar 3, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

The WindAcre Partnership was founded by Snehal Amin in 2013 and began providing advisory services to non-fee paying, proprietary clients in October 2013 and to fee paying clients in February 2014. Mr. Amin is the principal beneficial owner of The WindAcre Partnership and the only beneficial owner (through direct and indirect ownership) holding more than 25%. The WindAcre Partnership seeks to achieve its investment objective for clients by identifying, buying and holding a highly concentrated portfolio of undervalued good businesses, and selling them as they approach fair value. The WindAcre Partnership invests almost exclusively in publicly traded equities (or their equivalents).

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However, The WindAcre Partnership has acquired privately held company interests through take-private transactions. The WindAcre Partnership pursues a long only investment strategy and has/will not engage in short sales or other forms of hedging. The WindAcre Partnership may use limited leverage from time to time. With respect to each private fund that it manages (each, a “Fund”), The WindAcre Partnership tailors its services to the strategies and conditions set forth in the Fund’s offering and governing documents. For these private fund clients, The WindAcre Partnership provides advisory services to the Fund, rather than to any individual investor in the private funds. Therefore, it should be noted that The WindAcre Partnership does not tailor its investment advice to take into account any specific investment conditions of any individual investor in a private fund. As of December 31, 2025, The WindAcre Partnership manages approximately $11,422,849,000 in discretionary client assets under management. All discussions of private funds in this brochure, including but not limited to their investments, the strategies used in managing private funds, the fees and other costs associated with an investment in the Fund, and conflicts of interest faced by The WindAcre Partnership and its affiliates in connection with the management of the Fund are qualified in their entirety by reference to each Fund’s respective confidential offering memorandum (if any) and governing documents (referred to collectively as the “Offering Documents”).

Item 5. Fees and compensation

The fees that The WindAcre Partnership charges for advisory services varies among clients. Private fund investors pay fees that are commensurate with the series or share class of the private fund in which they invest. The Fund is structured such that The WindAcre Partnership receives an annual management fee that is commensurate with the respective series or share class in which an investor is invested. Depending upon their respective series or share class, investors pay an annual management fee to The WindAcre Partnership ranging from zero to 1.5% of their respective capital account balance. The WindAcre Partnership’s management fees are charged monthly in advance and The WindAcre Partnership instructs the Fund's administrator to pay these fees by using cash available to such Fund.

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In addition, The WindAcre General Partner LP (the “General Partner”) receives an annual performancebased incentive allocation from the Fund that is unique to each specific series or share class in the Fund. This performance-based incentive allocation ranges from zero to 40% annually and is calculated based upon an individual investor’s return over a particular period of time compared to the return of varying hurdles or benchmarks over that same period of time. Incentive allocations are subject to a high-water mark and/or loss carry forwards.

Both the management fee and the incentive allocation, as well as other terms, are more fully described in the respective Offering Documents for each Fund. Potential investors should review such Offering Documents for full details as to how the management fees and incentive allocations are calculated and collected. The WindAcre Partnership and its affiliates render their services to the Fund at their own expense and are responsible for their overhead expenses as described more fully in the Offering Documents for each Fund. Certain other expenses are paid by the Fund and are described more fully in the Offering Documents for each Fund. At the time of filing, The WindAcre Partnership does not perform advisory services for any separately managed accounts. However, in the event that The WindAcre Partnership assumes any separately managed accounts as clients, The WindAcre Partnership expects to charge management fees and/or incentive allocations to those accounts that are similar to those stated above for the Fund. However, such allocations may be individually negotiated based upon any restrictions placed on The WindAcre Partnership, the business relationship between such client and The WindAcre Partnership, and any other factors that The WindAcre Partnership deems appropriate.

Item 6. Performance-based fees and side-by-side management

As discussed in Item 5 – Fees and Compensation, each of The WindAcre Partnership's clients are charged an incentive allocation where earned. Please refer to Item 5 for a description of performance-based incentive allocations earned by management.

Item 7. Types of clients

The underlying investors in the Fund, while not considered clients of The WindAcre Partnership under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), are persons that are both “accredited investors” within the meaning of the Securities Act of 1933, as amended, and “qualified purchasers” as defined in Section 2(a)(51)(a) of the Investment Company Act of 1940, as amended (the “IC Act”), as well as certain knowledgeable employees. The Fund has minimum investment amounts and various other eligibility requirements. The Fund's investors may include, but are not limited to, fund of funds, institutions, businesses, pensions, trusts, government entities and individuals meeting certain net worth requirements.

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The interests or shares in the Fund are offered privately pursuant to Regulation D and, as such, are not registered under the federal securities laws and regulations. Accordingly, interests or shares in the Fund are offered and sold only to those investors that meet the eligibility requirements for private placements and/or offshore transactions. Investors in the Fund are generally required to make minimum initial investments of at least $100,000,000; however, such amount could be reduced at the sole discretion of the General Partner, an affiliate of The WindAcre Partnership.

Item 8. Methods of analysis, investment strategies and risk of loss

All references to the Fund in this brochure, including but not limited to their investments, the strategies used in managing private funds are qualified in their entirety by reference to each Fund’s respective Offering Documents. The following is a general discussion of the methods of analysis, investment strategies and the risk of loss associated with The WindAcre Partnership’s overall investment strategy. These risk factors may change over time. THE INFORMATION BELOW IS INTENDED TO SERVE AS A SUMMARY OF POTENTIAL RISKS OF INVESTING WITH THE WINDACRE PARTNERSHIP. THE FOLLOWING IS NOT A SUBSTITUTE FOR THE OFFERING DOCUMENTS IN THE FUNDS. ANY REFERENCES TO ANY CLIENT IN THIS BROCHURE, INCLUDING, BUT NOT LIMITED TO, THEIR INVESTMENTS AND MANAGEMENT STRATEGIES, ARE QUALIFIED IN THEIR ENTIRETY BY REFERENCE TO EACH CLIENT’S RESPECTIVE OFFERING DOCUMENTS, GOVERNING DOCUMENTS,

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INVESTMENT OBJECTIVES, AND GUIDELINES. THESE RISKS MAY CHANGE OVER TIME. THE WINDACRE PARTNERSHIP MAY OFFER ADVISORY SERVICES, ENGAGE IN AN INVESTMENT STRATEGY, AND MAKE ANY INVESTMENT, INCLUDING ANY NOT DESCRIBED IN THIS BROCHURE, THAT THE WINDACRE PARTNERSHIP DEEMS APPROPRIATE, SUBJECT TO EACH CLIENT’S INVESTMENT OBJECTIVES AND GUIDELINES. POTENTIAL INVESTORS SHOULD REVIEW THE GOVERNING DOCUMENTS IN THEIR ENTIRETY AND CONSULT THEIR OWN LEGAL, TAX, AND/OR FINANCIAL ADVISERS BEFORE INVESTING WITH THE WINDACRE PARTNERSHIP. POTENTIAL INVESTORS IN THE FUNDS MUST REVIEW OFFERING DOCUMENTS IN THEIR ENTIRETY BEFORE INVESTING. Markets and Instruments The WindAcre Partnership pursues a long-only investment strategy, investing almost exclusively in publicly traded equities (or equivalents). Portfolio Concentration The WindAcre Partnership maintains highly concentrated portfolios on behalf of their clients, typically consisting of 10-20 investments in the Fund. At certain times, the portfolio could be even more concentrated, holding fewer than 10 investments. Risk Factors Investment Losses The WindAcre Partnership will make investments in equity securities of companies based on its assessment of the quality of each business and each business’ intrinsic value relative to current valuation. These are inherently subjective judgments, and require assumptions regarding the future. The assumptions could relate to, among many other things, future competitor behavior, customer behavior, input prices, merger/acquisition transactions closing, regulatory changes and appropriate discount rates. Some or all of these assumptions and judgments could turn out to be wrong, resulting in The WindAcre Partnership overestimating the quality of a business and its intrinsic value. These situations could result in a significant loss for clients. Equity Investments The market value of equity securities fluctuates, and is affected by a wide range of factors outside of individual company performance, such as economic outlook, financial market conditions and force majeure events. The WindAcre Partnership does not attempt to predict or hedge against such factors. However, such factors may have meaningful impact on the value of the Fund’s investments for clients at any given time. Market Direction It is anticipated that The WindAcre Partnership will manage client accounts to be largely or fully invested, and it will not engage in short selling or other similar portfolio hedging. Accordingly, while The WindAcre Partnership’s objective is to outperform the equity market and generate attractive absolute returns over a market cycle for clients, it does not believe it can escape the direction, positive or negative, of meaningful market moves, particularly over shorter time periods. Governmental Interventions Extreme volatility and illiquidity in markets has in the past led to, and may in the future lead to, extensive governmental interventions in equity, credit and currency markets. Generally, such interventions are intended to reduce volatility and precipitous drops in value. In certain cases, governments have intervened on an “emergency” basis, suddenly and substantially eliminating market participants’ ability to continue to

implement certain strategies or manage the risk of their outstanding positions. In addition, these interventions have typically been unclear in scope and application, resulting in uncertainty. It is impossible to predict when these restrictions will be imposed, what the interim or permanent restrictions will be and/or the effect of such restrictions on the The WindAcre Partnership’s strategy. Volatility The WindAcre Partnership will manage client accounts with long exposure only and will not engage in short selling or other similar portfolio hedging. Accordingly, client portfolios will likely be subject to more rapid and extreme change in value than would be the case if The WindAcre Partnership engaged in such hedging. Concentration The WindAcre Partnership’s client portfolios will be heavily concentrated (i.e., typically 10-20 investments). Accordingly, the amount of client capital which may be committed to any one investment will generally be relatively large. A loss in any one position could therefore have a material adverse impact on a client’s invested capital. Further, the client portfolios will likely be subject to more rapid and extreme change in value than would be the case if the client maintained a portfolio diversified among issuers, industries, companies and types of securities. Non-U.S. Investments The WindAcre Partnership may invest globally on behalf of clients. Investing in securities of non-U.S. companies, which are generally denominated in non-U.S. currencies, involves certain considerations comprising both risks and opportunities not typically associated with investing in U.S. companies. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of non-U.S. taxes, less liquid markets and less available information than is generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, greater risks associated with counterparties and settlement, difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. Currency Risks Client investments that are denominated in non-U.S. currencies are subject to the risk that the value of their particular currency will change in relation to the U.S. Dollar. Among the factors that may affect currency values are trade balances, the level of short-term interest rates, differences in relative values of similar assets in different currencies, long-term opportunities for investment and capital appreciation and political developments. The WindAcre Partnership will not hedge these risks, and therefore such changes in currency values will result in changes in the value of the portfolio. Small to Medium Cap Stocks The WindAcre Partnership takes an agnostic approach to market capitalizations (so long as minimum liquidity requirements are met) and so may invest in the stocks of companies with small to medium sized market capitalizations. Doing so involves higher risks in some respects than investing in stocks of larger companies. Among other issues, these stocks are generally less liquid, resulting in a longer time to enter and exit the investment, and more share price volatility. Activist Investments The WindAcre Partnership invests in securities of companies that The WindAcre Partnership believes are undervalued by the marketplace and are likely to appreciate over time. While it would be considered extremely rare, The Windacre Partnership may take an activist role if necessary in order to protect the

underlying intrinsic value of an existing portfolio company. Doing so involves the risk that opponents of the proposed actions by The Windacre Partnership may seek to oppose, investigate, or otherwise impact catalysts to intrinsic value. There is a risk that shareholder and other stakeholders, including those who may have diverging interests fail to cooperate. Moreover, securities which The WindAcre Partnership believes are incorrectly valued may not ultimately be valued in the capital markets at the price and/or within the time frame The WindAcre Partnership anticipates even if an active investing strategy is successfully implemented. Options Although it does not expect to do so under normal conditions, The WindAcre Partnership may at times purchase options on single stocks on behalf of clients. The purchase of an option involves the payment of a premium by the investor and the corresponding right to either purchase or sell the underlying stock for a specific price at a certain time (or during a certain period). If the underlying stock price does not change as expected, a client could lose the entire premium. Over-the-counter options also involve counterparty solvency risk. Custody There are risks involved in dealing with the custodians who settle the Fund’s trades. The Fund maintains custody accounts with their primary custodians (the “Custodians”). Although The WindAcre Partnership monitors the Custodians and believes that they are appropriate custodians, there is no guarantee that the Custodians, or any other custodians that the Fund may use from time to time, will not become bankrupt or insolvent. The Fund and/or the Custodians may also appoint sub-custodians in certain non-U.S. jurisdictions to hold the assets of the Fund. The Custodians may not be responsible for cash or assets which are held by subcustodians in certain non-U.S. jurisdictions, nor for any losses suffered by the Fund as a result of the bankruptcy or insolvency of any such sub-custodian. Additional information regarding the potential risks related to custody and the use of sub custodians is available in the respective Offering Documents of the Fund. Illiquidity Investors in the Fund may be subject to significant restrictions on withdrawal as more fully described in the Offering Documents for the Fund. Accordingly, an investment in the Fund is a relatively illiquid investment and involves a high degree of risk. Further, The WindAcre Partnership occasionally holds instruments that are subject to lock-up periods, limited liquidity provisions or similar limitations, such that when held limit the ability for The WindAcre Partnership to expeditiously liquidate such securities. Leverage The Fund may utilize limited leverage from time to time. This results in the Fund controlling substantially more assets than the Fund has equity. Leverage increases the Fund’s returns if the Fund earns a greater return on investments purchased with borrowed funds than the Fund's cost of borrowing such funds. However, the use of leverage exposes the Fund to additional levels of risk, including (i) greater losses from investments than would otherwise have been the case had the Fund not borrowed to make the investments, (ii) margin calls or interim margin requirements which may force premature liquidations of investment positions and (iii) losses on investments where the investment fails to earn a return that equals or exceeds the Fund's cost of borrowing such funds. In the event of a sudden, precipitous drop in value of the Fund’s assets, the Fund might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying its losses.

Incentive Allocation The allocation to the General Partner of a percentage of the Fund's net profits creates an incentive for the Investment Manager, an affiliate of the General Partner, to cause the Fund to make investments that are riskier or more speculative than would be the case if this allocation were not made. Since the incentive allocation is calculated on a basis which includes unrealized appreciation of assets, such allocation may be greater than if it were based solely on realized gains. Side Letters See the Offering Documents for the Fund for further information regarding The WindAcre Partnership’s restrictions on the execution of side letters on behalf of Fund clients. Reliance on Snehal Amin The WindAcre Partnership relies heavily on the services of the portfolio manager, Snehal Amin. Mr. Amin is responsible for all of the major decisions affecting the client accounts, and solely responsible for all investment decisions for clients. Plans for handling the Fund in the event of his death or incapacitation are contained within the Offering Documents for the Fund and should be reviewed carefully prior to investment. Accounting for Uncertainty in Income Taxes The Financial Accounting Standards Board has released Accounting Standards Codification Topic 740 (“ASC 740”) (formerly known as “FIN 48”) to provide consistent guidance on the recognition of uncertain tax positions. ASC 740 prescribes, among other things, the minimum recognition threshold that a tax position is required to meet before being recognized in an entity’s financial statements. Investors in the Fund should be aware that, among other things, ASC 740 could have a material adverse effect on the periodic calculations of the net asset value of the Fund including reducing the net asset value of the Fund to reflect reserves for income taxes that may be payable in respect of prior periods by the Fund. This could adversely affect certain limited partners, depending upon the timing of their purchase and withdrawal of limited partnership interests. Absence of Regulatory Oversight While the Fund may be considered similar to an investment company, The WindAcre Partnership does not intend to register it as such under the IC Act, in reliance upon an exemption available to privately offered investment companies, and, accordingly, the provisions of that Act (which, among other matters, require investment companies to have disinterested directors, require securities held in custody to at all times be individually segregated from the securities of any other person or marked to clearly identify such securities as the property of such investment company and regulate the relationship between the adviser and the investment company) will not be applicable. ERISA Risks The assets of the Fund may, at various times, be deemed to be “plan assets” subject to Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”). During these periods, the Investment Manager, in its capacity as Investment Manager to the Fund, will be a fiduciary with respect to plans or accounts subject to Title I of ERISA and/or Section 4975 of the Code investing in the Fund directly or indirectly through a “Benefit Plan Investor” (as defined below) and will be prohibited from causing the Fund to engage in certain transactions. While The WindAcre Partnership believes that it can affect the Fund investment strategies utilizing various statutory and class exemptions to ERISA’s prohibited transaction regime, there may be particular transactions which ERISA and/or the Code will prevent the Fund from entering into or investments which the Fund must sell before it might otherwise do so.

Conflicts of Interest The WindAcre Partnership serves as the Investment Manager of the Fund. In addition, The WindAcre Partnership and its affiliate, the General Partner (and their members, principals, affiliates and employees) may serve as investment adviser or Investment Manager to other separately managed accounts and conduct investment activities for their own accounts. Such other entities or accounts (the “Other Clients”) may have investment objectives or may implement similar investment strategies. Accordingly, the Fund and the Other Clients may co-invest in many of the same securities and issuers.

Item 9. Disciplinary information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of The WindAcre Partnership or the integrity of The WindAcre Partnership’s management. The WindAcre Partnership has no disciplinary information to disclose.

Item 10. Other financial industry activities and affiliations

The WindAcre Partnership and its employees do not have any other material financial industry activities or affiliations. The WindAcre Partnership and its employees are focused exclusively on providing The WindAcre Partnership’s investment advice.

Item 11. Code of ethics, participation in client transactions and personal trading

The WindAcre Partnership has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. The WindAcre Partnership’s Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth The WindAcre Partnership’s practice of supervising the personal securities transactions of supervised persons. Individuals associated with The WindAcre Partnership may not buy or sell individual debt or equity securities while employed by The WindAcre Partnership. New employees may be given a period of time in which to wind down any individual debt or equity positions they obtained prior to employment with The WindAcre Partnership.

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It is the expressed policy of The WindAcre Partnership that no person employed by The WindAcre Partnership shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with its Code of Ethics, The WindAcre Partnership requires that anyone associated with this advisory practice provide annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. The WindAcre Partnership requires such persons to also receive approval from the Chief Compliance Officer prior to investing in any IPOs or private placements (limited offerings). The WindAcre Partnership requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. The WindAcre Partnership’s Code of Ethics further includes the firm's policy prohibiting the trading of securities based on material non-public information. Any individual not in observance of the above may be subject to disciplinary measures. The WindAcre Partnership will provide a complete copy of its Code of Ethics to any client or prospective client upon request to the Chief Compliance Officer at The WindAcre Partnership’s principal address. Additionally, it is The WindAcre Partnership’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts.

Item 12. Brokerage practices

The WindAcre Partnership is authorized to determine the broker or dealer to be used for each securities transaction for the Fund. In selecting brokers or dealers to execute transactions, The WindAcre Partnership need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not The WindAcre Partnership’s practice to negotiate “execution only” commission rates, thus the Fund may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate.

Read the rest of Item 12 (297 more words)

Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. The WindAcre Partnership will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning of Section 28(e). Although The WindAcre Partnership will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. In selecting brokers and negotiating commission rates, The WindAcre Partnership will take into account the financial stability and reputation of brokerage firms, and the research, brokerage or other services provided by such brokers. The WindAcre Partnership may place transactions with a broker or dealer that (i) provides The WindAcre Partnership (or an affiliate) with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refers investors to the Fund or other products advised by The WindAcre Partnership (or an affiliate), if otherwise consistent with seeking best execution; provided The WindAcre Partnership is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of investors. When appropriate, The WindAcre Partnership may, but is not required to, aggregate client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will be allocated securities based on the average price achieved for such trades.

Item 13. Review of accounts

Mr. Amin and the investment team review the strategy and investments of the client accounts at least daily, performing reviews of the positions, allocations, and strategy. Mr. Amin and the investment team provide investors with audited annual financial statements, periodic unaudited performance reports, and, for U.S Funds, all tax information relating to their investments in the Fund necessary for U.S. federal income tax purposes.

Item 14. Client referrals and other compensation

The WindAcre Partnership does not receive any economic benefit from anyone other than its clients for providing investment advice or other advisory services to its clients.

Item 15. Custody

The WindAcre Partnership or its affiliates enter into agreements with qualified custodians to maintain custody of the Fund’s assets as and to the extent required by Rule 206(4)-2 under the Advisers Act. These qualified custodians generally include banks, registered broker dealers and potentially certain foreign financial institutions. While The WindAcre Partnership does not take physical custody of any client assets, affiliates of The WindAcre Partnership may be deemed to have custody pursuant to SEC. The Fund is responsible for all costs of such qualified custodians. In the case of separately managed account clients, the

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client will choose the custodian. The WindAcre Partnership will not have custody of any such assets. These clients will receive account statements directly from the custodian. As The WindAcre Partnership has arranged for delivery of audited financial statements to each Fund investor within 120 days of the end of each fiscal year, investors do not receive reports directly from the Fund’s qualified custodians. The WindAcre Partnership urges all clients and underlying investors to carefully review all statements received from the administrator and/or custodian.

Item 16. Investment discretion

The WindAcre Partnership’s investment advisory services for the Fund are provided on a discretionary basis. The WindAcre Partnership may exercise this discretion to determine what securities to trade on behalf of the Fund or each separately managed account, in what amount to trade such securities and the executing brokers for such transactions. This discretion is subject to any guidelines or restrictions on the investment activities set out in the agreements between The WindAcre Partnership and each such Fund or separately managed account.

Item 17. Voting client securities

The WindAcre Partnership intends that, absent definitive reasons why a proxy should not be voted, all proxies will be voted based on the Firm’s proxy voting policy. The WindAcre Partnership has developed a proxy voting policy which it believes is reasonably designed to ensure that proxies are voted in the best interest of its clients and in accordance with its fiduciary duties and Rule 206(4)-6 under the Advisers Act. Clients may not direct The WindAcre Partnership as to how to vote a particular proxy. The WindAcre Partnership’s policies and procedures contain procedures designed to address potential conflicts of interest that may arise between The WindAcre Partnership and its clients. Clients may obtain both information about how The WindAcre Partnership voted proxies and a copy of its Proxy Voting Policy by either calling or emailing Chris Smith at 713-623-7711 or chris@windacre.com.

Item 18. Financial information

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about The WindAcre Partnership’s financial condition. The WindAcre Partnership has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.