Alluvial Capital Management, LLC: investment adviser

Personal investment policy Asset selection Regular portfolio monitoring

Separately managed accounts offered by Alluvial Capital Management are completely customizable per the client’s investing goals and needs but will generally conform to the Global Focused Value strategy. Global Focused Value – The Focused Value strategy invests in 10-15 of Alluvial’s highest-conviction securities selections, with the goal of exceeding the returns of world stock markets by a significant margin. This strategy may feature industry or geographic concentrations and is intended for investors with a long investing time horizon and the ability to endure significant near-term losses in the pursuit of attractive long-term profits. Alluvial evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Alluvial will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Alluvial seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Alluvial’s economic, investment or other financial interests. To meet its fiduciary obligations, Alluvial attempts to avoid, among other things, investment or trading practices that systematically

advantage or disadvantage certain client portfolios, and, accordingly, Alluvial’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Alluvial’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent that might have a limited supply, among its clients on a fair and equitable basis over time.

Services Limited to Specific Types of Investments Alluvial generally limits its investment advice to equities, fixed income securities, ETFs, real estate funds (including REITs), equity options and warrants, and non-U.S. securities, although Alluvial primarily recommends domestic equities. Alluvial may use other securities as well to help diversify a portfolio when applicable. Alluvial Capital Management LLC also conducts monitoring and ongoing management of client legacy positions and may exclude certain types of securities (based on economic sector, market capitalization, domicile, etc.) based on the expressed wishes of clients.

C. Client Tailored Services and Client Imposed Restrictions Alluvial will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Alluvial on behalf of the client. Alluvial may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Alluvial from properly servicing the client account, or if the restrictions would require Alluvial to deviate from its standard suite of services, Alluvial reserves the right to end the relationship.

D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Alluvial does not participate in any wrap fee programs.

E. Assets Under Management Alluvial has the following assets under management: Discretionary Amounts:

Non-discretionary Amounts:

Date Calculated:

$172,572,990

$0

12/31/2025

Daily fees paid are reported to clients on a quarterly basis on statements received from Interactive Brokers, LLC and/or Alluvial Capital Management, LLC. Daily fees are calculated as follows. (Account Value) x (Fee Rate)/(Number of Trading Days in Calendar Year.) For example, a $50,000 account paying fees at 2.00% annually would have a daily calculated fee rate of $50,000 x 2.00%/252, or $3.97.

Performance-based Fees – Separately Managed Accounts Qualified clients (as defined in Item 6 below) are charged a performance-based fee of 10% of net profits above a high water mark, rather than the standard asset-based portfolio management fee rates. These fees are negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients must pay the prorated performance-based fees for the billing period in which they terminate the Investment Advisory Contract up to and including the day of termination.

Management and Performance-based Fees – Pooled Vehicles The pooled vehicles managed by Alluvial are subject to management and/or performancebased fees as disclosed in the private placement memoranda provided to limited partners in connection with their subscriptions.

B. Payment of Fees Payment of Portfolio Management Fees Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization. Fees are paid daily.

Payment of Performance-based Fees Performance-based fees are calculated by Interactive Brokers, LLC and are withdrawn directly from the client’s accounts. Fees are paid quarterly in arrears.

C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Alluvial. Please see Item 12 of this brochure regarding broker/custodian.

D. Prepayment of Fees Alluvial collects its fees in arrears. It does not collect fees in advance.

E. Outside Compensation For the Sale of Securities to Clients Neither Alluvial nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

on his behalf) reasonably believes, immediately prior to entering into the contract, either: (a) Has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,100,000 (excluding the value of the client’s primary residence) at the time the contract is entered into; or (b) Is a

qualified purchases as defined in section 2(a)(51)(AA) of the Investment Company Act of 1940 (15U.S.C. 80a-2(51)(A)) at the time the contract is entered into; or (iii) A natural person who immediately prior to entering into the contract is: (a) An executive officer, director, trustee, general partner or person serving in similar capacity, of the investment adviser; or (b) An employee of the investment adviser (other than an employee performing solely clerical, secretarially or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar functions or duties for or on behalf of another company for at least 12 months. Clients should be aware that Alluvial manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) as well as accounts that are NOT billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because Alluvial or its supervised persons have an incentive to favor accounts for which Alluvial and its supervised persons receive a performance-based fee. Alluvial addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. Alluvial seeks best execution and upholds its fiduciary duty for all clients. Clients that are paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes.

B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.

Investment Strategies Alluvial’s use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

C. Risks of Specific Securities Utilized Alluvial’s use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary and include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss\for an uncovered call option is limitless. Spread option positions entail buying and selling

multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Risks Specific to Strategies of Alluvial’s Pooled Investment Vehicles: The purchase of the Interests involves a number of significant risks. In addition to the other risks and conflicts of interest hereunder, prospective investors also should consider the risks described in each pooled investment vehicle's private placement memorandum. The pooled investment vehicles may utilize the services of Portfolio Managers. Portfolio Managers generally use proprietary investment strategies that employ a variety of considerations, algorithms, and other factors in making investment decisions. These proprietary strategies generally are not fully disclosed to the General Partner or the Limited Partners. These strategies may involve risks under some market conditions that are not fully anticipated by the Portfolio Managers. Additionally, each pooled investment vehicle may invest in foreign markets and/or emerging markets, may purchase/sell call or put options, or engage, directly or indirectly, in the trading of derivative instruments. These, and other activities may increase the risk of volatility or loss of value. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in a pooled investment vehicle. Prospective investors should refer to the private placement memorandum of each pooled investment vehicle for a discussion of the principal risks specific to that pooled investment vehicle’s investment strategies. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Alluvial’s investing strategies are focused on micro-caps and less liquid securities. These types of investments are uniquely exposed to certain risks that must be understood by potential investors. Micro-cap firms often have small revenue bases, have high customer or supplier concentration, may lack significant managerial talent, may be at greater risk of financial distress and control a smaller portion of market share for their products or services than large firms. Frequently, the share prices of micro-cap and less liquid firms exhibit greater volatility than those of large firms. In times of economic stress or stock market declines, investors in Alluvial’s strategies may see the value of their holdings decline more than large firm indexes. Returns of micro-cap and less liquid firms’ stocks may diverge significantly from the broader market’s returns. Micro-caps and less liquid securities are often controlled or heavily influenced by a single owner or ownership group, which may result in disadvantaged treatment of minority shareholders. Micro-cap firms and less liquid stocks typically exhibit low trading volume, which may increase trading costs and slippage on purchases and sales. During times of market stress, the liquidity of micro-caps and less liquid stocks may decrease, making it more difficult to buy or sell. For these reasons, Alluvial’s strategies are suitable for only that part of an investor’s capital that can be exposed to these unique risks. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Alluvial Capital serves as both Limited Partner and portfolio manager for Alluvial Fund, LP and Tactile Fund LP. Periodically, management personnel of Alluvial Capital may also invest alongside clients in these pooled investment vehicles. As these investment vehicles constitute private funds, they represent limited participation opportunities. This introduces a potential conflict of interest, as Alluvial and its management personnel may have incentives beyond client suitability when recommending fund investments. To address this conflict, Alluvial Capital discloses it openly and commits to making investment recommendations that align strictly with client suitability.

D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Alluvial does not utilize nor select third-party investment advisers. All assets are managed by Alluvial management.

C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Alluvial may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Alluvial to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Alluvial will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold.

D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Alluvial may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Alluvial to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, Alluvial will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold.

While Alluvial has no formal soft dollars program in which soft dollars are used to pay for third party services, Alluvial may receive research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. Alluvial benefits by not having to produce or pay for the research, products or services, and Alluvial will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that Alluvial’s acceptance of soft dollar benefits may result in higher commissions charged to the client.

2. Brokerage for Client Referrals Alluvial receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.

3. Clients Directing Which Broker/Dealer/Custodian to Use Alluvial will require clients to use a specific broker-dealer to execute transactions.

B. Aggregating (Block) Trading for Multiple Client Accounts If Alluvial buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple Clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, Alluvial would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. Alluvial would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with the Adviser’s duty to seek best execution, except for those accounts with specific brokerage direction (if any).

The pooled investment vehicles (“Alluvial Fund, LP” and “Tactile Fund LP) are subject to audit at least annually and distribute audited financial statements which have been prepared by an independent certified public accountant in accordance with generally accepted accounting principles to all limited partners, members, or beneficial owners within 120 days of the end of its fiscal year. The investment adviser; (I) Hires an independent party to review all fees, expenses, and capital withdrawals from the accounts included in the pooled investment vehicle before forwarding them to the qualified custodian with the independent party’s approval for payment. (II) Sends written invoices or receipts to the independent party describing: (-a-) the amount of the fees, including any formulae used to calculate the fees, the time period covered by the fees and the amount of assets under management on which the fees were bases. (-b-) The expenses or capital withdrawals for the independent party to verify that payment of the fees, expenses, or capital withdrawals is in accordance with the documents governing the operation of the pooled investment vehicle and any statutory requirements applicable thereto.