Atlas Merchant Capital LLC: investment adviser

regional depository company-focused strategy (the “Regional Depository Fund”). Other Funds are co-investment vehicles structured to facilitate investments by third party co-investors alongside the PE Funds (“Co-Investment Vehicles”) and a fund-of-one that invests in special purpose acquisition vehicles (“SPACs”) and their sponsors (the “SPAC Fund”). The SPAC Fund is in the process of winding-down and is no longer accepting subscriptions. The Firm may in the future advise individual investors through funds-of-one or separately managed accounts (collectively with the Funds and the Co-Investment Vehicles, the “Clients” and each a “Client”). The Funds are exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”), pursuant to Section 3(c)(7) of the Investment Company Act. Interests in the Funds are privately offered to qualified investors. In the future, Atlas may provide discretionary and/or non-discretionary investment advice to other pooled investment vehicles, funds-of-one and/or separately managed accounts. Atlas provides discretionary investment management services to each Client pursuant to separate investment advisory agreements. Investment management services provided to each Client are tailored to such Client’s specific investment strategy, objectives, limitations and restrictions, as set forth in each investment advisory agreement, private placement memorandum, limited partnership agreement and/or other Client constituent document, as applicable (collectively, the “Governing Fund Documents”). Atlas’s investment objective is to generate long-term capital appreciation as further described in the Governing Fund Documents. As of December 31, 2025, Atlas had assets under discretionary management of $593,033,821.

The Management Fee charged to the Regional Depository Fund is generally based on the committed capital of the investor and is billed quarterly in advance. As of the date of this Brochure, the maximum Management Fee payable by the Regional Depository Fund is 2% per year of such total committed capital. The Management Fee charged to a Co-Investment Vehicle is generally based on the invested capital of the investor and is typically billed annually in advance. The Management Fee charged to the SPAC Fund is generally based on the net asset value of the capital account of the investor and is billed quarterly in advance. As of the date of this Brochure, the maximum Management Fee rate payable by the SPAC Fund is 0.25% per year of such net asset value. Atlas may elect to reduce, waive or calculate differently the Management Fee with respect to any investor. In the unlikely event Atlas does not provide services for the full period, a portion of the Management Fee is typically required to be returned to investors. In general, the amount of fees returned is calculated based on the number of days remaining in the applicable period. The Management Fee will typically be reduced (but not below zero) by an amount equal to 100% of the investor limited partners’ proportionate share of any other fees allocated to the Fund including but not limited to, transaction fees, break-up fees, director fees, monitoring fees, advisory fees, consulting fees and similar fees or compensation (net of related expenses) (“Transaction Fees”) paid to Atlas related to a Fund investment or potential Fund investment in a portfolio company (to the extent allocated to the Fund’s investment or potential investment in such portfolio company). Transaction Fees do not include: any management, advisory or other fees received by a General Partner (as defined below), Atlas, the Principals or any of their respective affiliates for investments that are not related to portfolio investments of a Fund; and any fees received by a General Partner, Atlas, the Principals or any of their respective affiliates in connection with services, activities or lines of business unrelated to the Funds. The types of fees that do or do not constitute Transaction Fees may vary among the Funds. In accordance with the Fund’s Governing Fund Documents, Transaction Fees paid by or attributable to any Fund’s portfolio company will generally be allocated based on the applicable Fund’s percentage ownership of such portfolio company, in proportion to the capital invested by all investors in the company. If more than one Fund is invested in any portfolio company, then the fees allocated to the Funds will generally be based on the respective Fund’s percentage ownership of such portfolio company. Fees allocated to a Fund will generally be further allocated among all investors in such Fund pro rata, based on each investor’s capital contributions. The general partners of the Funds, which are affiliates of Atlas (the “General Partners”), are generally eligible to receive a performance-based incentive allocation or carried interest, with respect to realized or unrealized investments, which is determined as a percentage of profits derived from the Funds’ investments (after taking into account expenses of the Fund, including Management Fees and, in the case of PE Funds and the Regional Depository Fund, following a preferred return to the Fund’s investors). If the performance-based carried interest of a PE Fund or the Regional Depository Fund results in an over-distribution of the agreed upon amount of carried

interest to the General Partner, the General Partner is subject to an after-tax “claw back” arrangement. As of the date of this Brochure, the maximum carried interest allocable to the General Partner of a PE Fund and of the Regional Depository Fund, respectively, is 20% of the profits derived from the disposition of investments (after taking into account expenses of the Fund, including Management Fees) and the maximum incentive allocation allocable to the General Partner of the SPAC Fund is 10% of the aggregate net capital appreciation attributable to a capital account for a fiscal year. In addition to the Management Fees and performance-based fees described above, each Fund is responsible for its own start-up costs, as set forth in the Governing Fund Documents, including but not limited to, legal, accounting, filing and other out-of-pocket expenses of organizing and raising capital (“Organizational Expenses”) and all placement fees. The fees, costs and expenses that constitute Organizational Expenses will vary from Fund to Fund. Pursuant to the PE Fund Governing Fund Documents and the Regional Depository Fund Governing Fund Documents, excess Organizational Expenses of a PE Fund and the Regional Depository Fund over a threshold amount will typically reduce the Management Fees otherwise payable by such PE Fund or the Regional Depository Fund, as applicable, by an identical amount. All placement fees will reduce the Management Fees otherwise payable by a PE Fund or the Regional Depository Fund, as applicable, by an identical amount. Strategic investors are from time to time entitled to a portion of the carried interest distributions received by the General Partners from certain of the Funds and/or a portion of the profit of the Firm. Each General Partner and each Atlas management entity pays its ordinary administrative and overhead expenses in managing Fund investments, including but not limited to salaries, benefits and rent. Each Fund also bears its own ongoing expenses (“Operating Expenses”) which generally includes, without limitation: expenses incurred in connection with the discovery, evaluation, investigation, development, making, valuation, acquisition, holding, purchase, ownership, supervision, structuring, carrying, monitoring, realization, liquidation, transfer, sale or other disposition of potential or actual investments, including loan fees, expenses relating to short sales, custodial fees, trustee fees, hedging expenses, bank service fees, private placement fees, sales commissions, appraisal fees, taxes, brokerage fees, brokerage commissions (including “soft dollar” arrangements), research fees, due diligence, interest expense, and commitment fees, transfer taxes and premiums, and duties payable in any jurisdiction in connection with any investment, underwriting commissions, clearing and settlement charges and discounts, and related legal, accounting, investment banking, advisory, consulting, information services and professional fees and expenses, and finance, communications (including interest access fees) and other expenses, and any third-party research and market data expenses (including quotation and market data services (e.g., Bloomberg, Reuters, S&P); travel-related expenses (including transportation, meal, entertainment and lodging expenses) related to or arising from the discovery, evaluation, acquisition, holding, monitoring or disposition of investments, including potential investments (which may include travel by way of non-commercial planes at rates not in excess of customary charter rates, where the General Partner determines such travel is necessary due to business

exigencies); expenses incurred in connection with the carrying or management of investments, including, without limitation, custodial, trustee, accounting, recordkeeping and other administration fees (including the fees and expenses of any third-party administrator), as well as portfolio accounting system licenses and fees; expenses incurred in connection with the preparation and distribution of the Fund’s financial statements, tax returns, Schedule K-1s and other communications with partners and the limited partner advisory committee of the Fund, if applicable, including, without limitation, expenses incurred in connection with purchasing, licensing or leasing computer software and hardware for such uses and expenses incurred in connection with providing the Fund’s investors on-line or electronic access to information and reporting relating to the Fund; attorneys’ and accountants’ fees and disbursements; taxes and other governmental charges levied against, or otherwise incurred or payable by, the Fund; insurance premiums or expenses (including directors’ and officers’ insurance and errors and omissions insurance and related brokers’ fees and commissions); any and all expenses to comply with laws and regulations related to the activities of the Fund (including regulatory and compliance-related expenses of the General Partner and Atlas incurred in connection with the operation of the Fund (including, without limitation, expenses related to the preparation and filing of Form PF with the SEC and complying with the Foreign Accounting Tax Compliance Act and the Alternative Investment Fund Managers Directive)); any and all expenses incurred in connection with any litigation or government inquiry, investigation or proceeding involving the Fund or any of its investors, including the amount of any judgment, settlements or fines; fees, costs and expenses associated with maintaining the Fund and any of its subsidiary entities, including fees, costs and expenses incurred in the organization, operation and restructuring of such subsidiary entities; interest on, and fees, costs and expenses arising out of the Fund’s borrowings and indebtedness (including the fees, costs and expenses incurred in obtaining lines of credit, loan commitments and letters of credit for the account of the Fund); expenses incurred in connection with the winding up and dissolution of the Fund or liquidation of the Fund’s assets; expenses relating to defaults by the Fund’s investors in the payment of any capital contributions; out-of-pocket expenses for transactions that are not consummated; expenses incurred in connection with any restructuring or amendments to the constituent documents of the Fund and related entities, including the General Partner of such Fund and Atlas; any and all expenses incurred in connection with distributions to the Fund’s investors; any and all expenses in connection with any meetings with Fund’s investors or any limited partner advisory committee of the Fund; expenses related to the Fund’s indemnification obligations; expenses incurred in connection with the formation of alternative investment vehicles and any intermediate, blocker and other special purpose vehicles formed to facilitate the investment by certain limited partners in a portfolio company, to the extent permitted under the Governing Fund Documents (to be borne solely by investors therein or for whose benefit such vehicle has been established); reasonable out-of-pocket expenses incurred by the members of any limited partner advisory committee of the Fund in connection with the fulfillment of their duties pursuant to the Governing Fund Documents (including meals, entertainment, lodging and other similar expenses and which may include reasonable travel expenses incurred by a committee member travelling to and from such meetings; expenses relating to the offer and sale of interests in the Funds; expenses related to the maintenance of the Fund’s registered office, if applicable; brokerage costs, if applicable; extraordinary expenses; compensation and other similar expenses of consultants (including industry executives, advisors, consultants, operating executives, subject matter experts or other persons acting in a similar capacity) who provide services to the Fund or its portfolio companies (including with respect to potential portfolio investments). The fees, costs

and expenses that constitute Operating Expenses will vary from Fund to Fund. Prospective investors in a Fund are advised to review the applicable Governing Fund Documents for a more detailed description of the fees and expenses associated with an investment in such Fund. To the extent any Operating Expenses are incurred for the benefit of more than one Client, such Operating Expenses will generally be borne by each benefiting Client on a pro rata basis or such other manner as the applicable General Partner determines to be reasonable. Investment vehicles owned by Atlas investment professionals, employees and related persons may invest in certain Funds. Such persons, as well as certain co-investors and unrelated persons, typically will not pay Management Fees and/or be subject to performance-based fees in connection with their investment in the Funds. If any limited partner is participating in a co-investment alongside a PE Fund or the Regional Depository Fund, respectively, (a “Co-Investor”), such Co-Investor will typically bear its pro rata share of fees, costs and expenses related to the sourcing, monitoring, investigation, development, acquisition or consummation, ownership, maintenance, hedging and disposition of the underlying co-investments. In the event that a Co-Investor participates in a co-investment through a CoInvestment Vehicle Client, the Co-Investor will generally bear its pro rata share of the aggregate organizational costs and expenses of such Co-Investment Vehicle Client as described above, unless such organizational costs and expenses (and related transaction costs of the relevant investment) are borne by the portfolio company in which the applicable Fund and such Co-Investment Vehicle Client invest. To the extent agreed upon by co-investors, Atlas and/or its affiliates may earn carried interest, receive a management fee and/or retain Transaction Fees or portfolio monitoring fees allocated to co-investors or Co-Investment Vehicle Clients that, in each case, will not reduce the compensation paid to Atlas or any of their respective affiliates by any Fund. The general partner of a PE Fund or of the Regional Depository Fund, respectively, in their respective discretion, may call capital for Management Fees and other expenses or pay such fees and expenses out of a Fund’s current income and proceeds from investments. To the extent practicable, any third-party expenses relating to consummated investments of a PE Fund or of the Regional Depository Fund, as applicable, will be charged to the relevant portfolio company. If such expenses are not charged to the relevant portfolio company, then they will be paid by the PE Fund to which they relate or to the Regional Depository Fund, as applicable, and included in the cost of the investment. Any break-up fees and third-party expenses relating to unconsummated investments will be borne by the Client to which they relate. Expenses incurred from or relating to prospective investments of a Fund that are ultimately not consummated or abandoned will be allocated 100% to the relevant Fund unless any potential coinvestor has agreed to bear its share of expenses relating to an unconsummated transaction. The allocation of such broken deal expenses will then be allocated using the methodology agreed upon by the investors. Broken deal expenses include but are not limited to legal, accounting, consulting and other professional fees, travel related expenses (including, without limitation, transportation, meals, entertainment and lodging), and other out of pocket expenses incurred in connection with unconsummated investment transactions. These expenses are borne by the relevant Fund, to the extent the costs are not reimbursed by the potential portfolio companies.

Certain types of costs that constitute Operating Expenses, Organizational Expenses, or other types of fees, expenses or costs that are borne directly or indirectly by a Client can overlap with or include costs associated with regulatory compliance obligations of Atlas. For example, the Organizational Documents of a Fund typically require the preparation and distribution of audited annual financial statements, the cost of which is borne by the Fund as an Operating Expense, even though this contractual requirement also serves as a means for Atlas to comply with requirements that are applicable to Atlas under SEC rules relating to the custody of client assets. Similarly, a Fund can be expected to bear Organizational Expenses that include costs incurred by Atlas to comply with regulatory standards relating to, among other things, “advertisements” and other communications with prospective investors under SEC rules. These and other direct or indirect Operating Expenses, Organizational Expenses, and other types of fees, expenses and costs generally will be allocated to such Fund or other Client to the extent permitted by the relevant Governing Fund Documents, even though the underlying requirement or activity associated with such fees, expenses or costs may relate, in whole or in part, to requirements that, from a legal or regulatory perspective, are applicable to Atlas, rather than to the Client or a portfolio investment. In addition to the full-time investment professionals of the Firm, the PE Funds, the Regional Depository Fund and their respective portfolio companies may engage the services of certain advisors to work actively with Atlas on sourcing and evaluating new transactions, as well as providing strategic advice related to portfolio company matters. These advisors are not partners or employees of Atlas or any of its affiliates, but rather consultants engaged by certain PE Funds or the Regional Depository Fund, as applicable. The compensation of such individuals is generally treated as an expense of the relevant Fund(s) or the relevant portfolio company. Atlas has engaged an advisory board comprised of a distinguished group of Senior Advisors (the “Senior Advisors”). The Senior Advisors serve as part-time consultants to Atlas to contribute their industry insight and experience to the Firm. Atlas is responsible for an annual retainer paid to certain Senior Advisors. The Senior Advisors are not employees of Atlas. In the event a Senior Advisor is engaged, retained or hired by a portfolio company directly, he or she may be paid a separate fee or salary by such portfolio company. Any such fees or income will not reduce the Management Fee payable by any Fund. In addition, Atlas works with Operating Partners who serve as part-time consultants to Atlas on certain operational matters related to the Funds’ portfolio companies (the “Operating Partners”). The Operating Partners are not employees of Atlas. In the event an Operating Partner is engaged by a portfolio company of any Fund directly, such Operating Partner may be paid a consultant fee by such portfolio company for his or her services, which fee will not reduce the Management Fee payable by any Fund. These services may also include but are not limited to representation on the Board of Directors of certain portfolio companies. Any payments made to retain Operating Partners and the Senior Advisors are paid by the Firm, and the Funds do not incur such retention expenses.

The General Partner of a Co-Investment Vehicle is typically entitled to receive a performancebased carried interest distribution, which is usually based on realized gains from its investment above a performance threshold, as specified in each Co-Investment Vehicle Governing Fund Documents. Such carried interest is calculated based on a percentage of profits generated from the Co-Investment Vehicle and is subject to the satisfaction of the return of capital (up to 100%), recoupment of losses, fees, expenses and other criteria set forth in the Governing Fund Documents. The General Partner of the SPAC Fund is also entitled to receive a performance-based carried interest distribution, which is based on realized gains from investments above a performance threshold, as specified in the SPAC Fund’s Governing Fund Documents. Such incentive allocations are calculated based on realized or unrealized net capital appreciation or net capital depreciation attributable to the SPAC Fund’s investments and are allocated among capital accounts in proportion to their respective opening balances for any accounting period. Such carried interest is calculated based on a percentage of profits generated from the Fund and is subject to the satisfaction of a preferred rate of return of up to 4%, the return of capital (up to 100%), recoupment of losses, fees, expenses and other criteria set forth in the Governing Fund Documents. Performance-based fees may create an incentive for Atlas to cause the Funds to make investments that may be riskier or more speculative than those which would be made under a different fee arrangement. However, this incentive is mitigated in part by the financial commitment Atlas’s personnel make to the Funds in an effort to align Atlas’s and the Funds’ interests. Atlas also seeks to address these conflicts through careful vetting of investment opportunities by its investment professionals and disclosure of investments to limited partners by way of capital calls distributed to the limited partners in advance of each investment and quarterly reports to the limited partners. Additionally, Atlas has implemented internal controls to address the potential conflicts associated with performance based fees, as more fully described in each Fund’s Governing Fund Documents. Furthermore, the constituent documents of the PE Funds and the Regional Depository Fund have after-tax “claw back” arrangements as described in the “Fees and Compensation” section above. Although Atlas accepts performance-based carried interest from its PE Funds and the Regional Depository Fund but may not receive such fees from its Co-Investment Vehicle Clients, Atlas does not believe that it faces conflicts of interest in this regard because such Co-Investment Vehicle Clients do not make investments other than investments alongside PE Funds or the Regional Depository Fund that are subject to performance-based carried interest. Allocations of Investments The possibility exists that Atlas will, from time to time, be presented with investment opportunities that fall within the investment objectives of more than one Client. Atlas has established policies

and procedures for allocating investment opportunities among its Clients. When Atlas determines that it would be appropriate for more than one Client to participate in an investment opportunity, Atlas will seek to allocate investments on an equitable basis for all of the participating Clients. There is typically no obligation for a Client to dispose of any investment at the same time as any other Client. In determining initial allocations of investments among the Clients, Atlas and its affiliates will take into account such factors as they deem appropriate, which may include, without limitation: investment objectives; relative amounts of capital available for investments, the timing of capital inflows and outflows and anticipated capital commitments and subscriptions; liquidity needs; applicable concentration limits and other investment restrictions; mandatory minimum investment rights and other contractual obligations applicable to participating Clients and/or to their investors; portfolio diversification; relative exposure to market trends; tax efficiencies and potential adverse tax consequences; regulatory restrictions applicable to participating Clients and their investors that could limit the Client’s ability to participate in a proposed investment; policies and restrictions applicable to participating Clients; the avoidance of odd-lots or a de minimis allocation to one or more participating Clients; the potential dilutive effect of a new position; the overall risk profile of a portfolio; the potential return available from a debt investment as compared to an equity investment; and any other considerations deemed relevant by Atlas and its affiliates. There can be no assurance that any Client’s return from a transaction will be equal to and not less than another Client participating in the same transaction or that it will be as favorable as it would have been had such conflict not existed. When Atlas determines that it would be appropriate for multiple Clients to participate in an investment opportunity, Atlas will seek to aggregate orders for all of the participating Clients, on an equitable basis. The Clients that participate in an aggregated order will generally participate at the average price for all of the transactions in that security with respect to each buy/sell program on a given business day, with transaction costs generally shared pro rata based on the Clients’ participation in the transaction. The effect of such aggregation may operate on some occasions to a Client’s disadvantage. Specifically, if Atlas has determined to invest at the same time for more than one of the Clients, Atlas may place combined orders for all such Clients simultaneously and if any order is not filled at the same price, it may average the prices paid. Similarly, if an order on behalf of more than one Client cannot be fully executed under prevailing market conditions, Atlas may allocate the securities traded among the different Clients on the basis that it considers equitable. In these circumstances, each Client would pay, in connection with the acquisition of securities by more than one Client, the average price per unit acquired, which may be higher than if it had acted alone, and it may otherwise not be able to execute an investment decision as effectively as it could have if it had acted alone. There may be corresponding potential disadvantages when more than one Client simultaneously seeks to dispose of commonly held securities and other investment positions. Though not expected to occur frequently, one or more Clients may invest in portfolio investments or other issuers in which one or more other Clients is invested in a different part of the capital structure. These investments include investments in corporate loans and debt securities, preferred equity securities and common equity securities. The interests of such Clients may not be aligned in all circumstances to the extent they hold more junior or senior debt or equity interests, as the

case may be, which could create actual or potential conflicts of interest or the appearance of such conflicts. In that regard, actions may be taken by a Client that are adverse to another Client. The interests of Clients that are invested in different parts of the capital structure of a portfolio company are particularly likely to conflict in the case of financial distress of the portfolio company (or increased financial stress after the Client invests in the portfolio company). For example, if additional financing is necessary as a result of financial or other difficulties, it may not be in the best interests of the Client holding senior secured debt issued by such portfolio company to provide such additional financing. If a Client holding more junior debt or equity positions were to lose their respective investments as a result of such difficulties, the ability of Atlas to recommend actions that are in the best interests of such Client might be impaired. In addition, it is possible that, in a bankruptcy proceeding, a Client’s interests may be subordinated or otherwise adversely affected by virtue of such other Client’s involvement and actions relating to their investment. There can be no assurance that the term of or the return on a Client’s investment will be equivalent to or better than the term of or the returns obtained by the other Client participating in the transaction. This may result in a loss or substantial dilution of a Client’s investment, while another Client recovers all or part of amounts due to it. Similarly, the General Partner’s ability to implement a Client’s strategies effectively may be limited to the extent that contractual obligations entered into in respect of the activities of the other Clients impose restrictions on a Client engaging in transactions that the General Partner may be interested in otherwise pursuing. Except as required by the Governing Fund Documents of a particular Fund, Atlas is under no obligation to present any particular investment opportunity to any particular Fund. Atlas cannot assure that a Fund will participate in all investment opportunities that may meet its investment objectives. Atlas has established procedures for allocating co-investment opportunities among limited partners in its Funds, which may consider any factors Atlas deems relevant, including, without limitation, the size, sophistication, tenure as an investor, commitment to making co-investment funds available, ability to consummate co-investments within a specified time frame, commitment to invest in future products, interest in pursuing co-investment opportunities or strategic expertise of the prospective co-investor. The structure and terms of any co-investment opportunity to be offered by Atlas to any limited partner of a Fund shall be determined by Atlas, subject to the restrictions, if any, set forth in the Governing Fund Documents of the relevant Fund. When and to the extent that employees and related persons of Atlas and its affiliates make capital investments in or alongside certain Funds, Atlas and its affiliates are subject to conflicting interests in connection with these investments.

including private funds of funds) and high net worth individuals. Investment advice is provided directly to the Funds and not individually to the limited partners of a Fund. Prospective investors should refer to the Governing Fund Documents of each respective Fund for information on minimum investment requirements. Typically, Atlas requires a minimum investment of $10,000,000 for its PE funds and for the Regional Depository Fund, although each General Partner, in its sole discretion, may accept lesser amounts and has accepted lower amounts.

This flexible investment approach provides Atlas with the ability to adapt with the evolving financial services industry and to capitalize on attractive investment opportunities. The development of themes is driven by three core factors: the investment professionals have a deep understanding of the businesses; valuations in the industry are attractive; and Atlas has the relevant expertise to add value and materially improve operations. Atlas focuses on acquiring businesses that are: capitalizing on growth opportunities resulting from evolving market dynamics; undervalued due to a number of factors, including regulatory or market factors, under management, and operational distress; and/or familiar to the Principals and Atlas’s experienced group of senior professionals (collectively, the “Senior Team Members”) due to their deep networks in the global financial services industry. The Senior Team Members’ active and substantial participation in the financial services industry provides Atlas with advantaged deal flow. Given the complexities of the industry, Atlas believes that successful investing requires not only specialized knowledge, but also a deep and extensive relationship network, which the Firm believes to be one of its key competitive advantages. The Senior Team Members bring significant operating and investing expertise across the global financial services industry to the PE Funds. Atlas employs a team-based approach to investing, implementing a collaborative process through the onset of due diligence, investment decision making and disposition. Prior to commencing the due diligence process, Atlas assembles the transaction team based on the relevant expertise of each investment professional and the particular circumstances of each investment opportunity. Every

transaction is overseen by one of the Principals. While all investment professionals are expected to contribute to investment discussions, final investment decisions are made by the Investment Committee, which is comprised of the Principals and Managing Directors (the “Investment Committee”). An investment in a PE Fund involves significant risk and potential conflicts of interest. There can be no assurance that a PE Fund’s investment objectives will be achieved, and actual investment results may vary substantially from the investment objective. Investors should be prepared to bear these risks. The descriptions contained below are a brief overview of different risks related to the PE Funds’ investment strategy; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operations of the PE Funds. Investors should carefully consider all risk factors set forth in a Fund’s Governing Fund Documents. Each prospective investor should carefully review the applicable Governing Fund Documents before deciding to make an investment in a PE Fund. Each prospective investor should consult with his or her own counsel and advisors as to all legal, tax, financial and related matters concerning an investment in the PE Funds. Capital Invested: An investor acquiring interests in the PE Funds must rely upon the ability of the General Partners and Atlas to identify, structure, and implement investments consistent with the PE Funds’ investment objectives and policies. The PE Funds, however, may be unable to find a sufficient number of attractive opportunities to meet their investment objectives. The success of the PE Funds will depend on the ability of the General Partners and Atlas to identify suitable investments, to negotiate and arrange the closing of appropriate transactions and to arrange the timely disposition of such investments. Furthermore, the PE Funds may not be able to invest a significant portion of their capital commitments during their respective investment periods. U.S. Dollar Denomination of Interests: Interests in the PE Funds will be denominated in U.S. dollars. Investors that will subscribe for interests in any country in which U.S. dollars are not the local currency should note that changes in the value of exchange between U.S. dollars and such currency may have an adverse effect on the value, price or income of the investment to such investor. There may be foreign exchange regulations applicable to investments in foreign currencies in certain jurisdictions. General Nature of the PE Funds’ Investments: A substantial portion of the PE Funds’ investments will be in equity or equity-related investments that by their nature involve business, financial, market and legal risks. While such investments offer the opportunity for significant capital gains, they also involve a high degree of risk that may result in substantial losses. There can be no assurance that the PE Funds will correctly evaluate the nature and magnitude of the various factors that could affect the value of such investments. Prices of the investments may be volatile and a variety of other factors that are inherently difficult to predict, such as domestic or international economic and political developments, may significantly affect the results of the PE Funds’ activities. As a result, the PE Funds’ performance over a particular period may not necessarily be indicative of the results that may be expected in future periods.

Although the PE Funds intend to make primarily control-oriented investments, the PE Funds may make minority equity investments in companies where it may have limited or no influence. Such a company may have economic or business interests or goals that are inconsistent with those of the PE Funds, and the PE Funds may not be in a position to limit or otherwise protect the value of its investment in the company. The PE Funds’ control over the policies of these companies may also be limited. The PE Funds may co-invest in a company with financial, strategic or other third-party investors. Such investments will involve additional risks not present in investments where a third party is not involved, including the possibility that the co-investor may have interests or objectives that are inconsistent with those of the PE Funds or may be in a position to take (or block) action in a manner contrary to the PE Funds’ investment objectives. In addition, the PE Funds may, in certain circumstances, be liable for actions of their third-party co-ventures or partners. The PE Funds’ investments may involve the incorporation of new companies. Significant risks are associated with the incorporations of such companies which may require substantial additional capital to support expansion or to achieve or maintain a competitive position. Such companies may face intense competition, including competition from companies with greater financial resources, more extensive development, marketing and service capabilities and a larger number of qualified managerial and technical personnel. The PE Funds’ investments may involve investments in public companies (including strategic public investments) or taking private portfolio companies public. Investments in public companies may subject the PE Funds to risks that differ in type or degree from those involved with investments in privately held companies. Such risks include, without limitation, greater volatility in the valuation of such companies, increased obligations to disclose information regarding such companies, limitations on the ability of the PE Funds to dispose of such securities at certain times (including due to the possession by the PE Funds of material non-public information), increased likelihood of shareholder litigation against such companies’ board members, which may include the Principals, regulatory action by the SEC and increased costs associated with each of the aforementioned risks. The PE Funds’ investments may involve turnaround or underperforming companies or companies identified by Atlas as being in need of additional capital. The financial condition of such companies may be weak or their balance sheets highly leveraged and any investment in them may involve a high degree of risk. The PE Funds generally invest in companies that operate in regulated business lines. Examples include, without limitation, financial services, banks, insurance, payments and broker-dealers. The operations of such companies are subject to compliance with applicable regulations, and such companies may be subject to increased regulations resulting from both new requirements and reregulation of previously de-regulated markets. Prices may be artificially controlled, and regulatory burdens may increase costs of operations. New or increased regulations could adversely affect the performance of the companies in which the PE Funds invest. Financial Services Risk Factors: The PE Funds generally invest primarily in the equity and debt of financial services companies. Financial services companies have asset and liability structures that are essentially monetary in nature and are directly affected by many factors, including

domestic and international economic and political conditions, broad trends in business and finance, legislation and regulation affecting the national and international business and financial communities, monetary and fiscal policies, interest rates, inflation, currency values, market conditions, the availability and cost of short- or long-term funding and capital, the credit capacity or perceived creditworthiness of customers and counterparties, and the level and volatility of trading markets. The profitability of the financial services industry may be adversely affected by a worsening of general economic conditions in domestic and international markets and by monetary, fiscal or other policies that are adopted by various governmental authorities and international bodies. Monetary policies have had, and will continue to have, significant effects on the operations and results of financial services companies. There can be no assurance that a particular financial services company will not experience a material adverse effect on its net interest income in a changing interest rate environment. Factors such as the liquidity of the global financial markets, the level and volatility of prices of financial instruments, investor sentiment, and the availability and cost of credit may significantly affect the activity levels of customers with respect to size, number and timing of transactions. A change in all or any of these factors could lead to a decline in the volume of transactions that financial services companies execute for their customers and thus lead to a decline in revenues from fees, commissions and spreads. The financial services industry is extremely competitive, and it is expected that competitive conditions in the industry will continue to intensify. Merger activity in the financial services industry has resulted in, and may continue to result in, larger institutions with greater financial and other resources that are capable of offering a wider array of financial products and services. The financial services industry has become considerably more concentrated as numerous financial institutions have been acquired by or merged into other institutions. Technological advances and the growth of e-commerce have made it possible for non­financial institutions to offer products and services that have been traditionally offered by financial services institutions. It is expected that cross-industry competition will continue to intensify. The financial services industry is highly dependent on communications and information systems and is exposed to many types of operational risk, including the risk of fraud by employees or other parties, record keeping error, errors resulting from faulty computer or telecommunication systems, computer failures, computer hacking, data breaches and damage to computer and telecommunication systems caused by internal or external events. Financial services companies operate in a highly regulated environment and are subject to extensive legal and regulatory restrictions and limitations and to supervision, examination and enforcement by regulatory authorities. Failure to comply with any of these laws, rules or regulations, some of which are subject to interpretation and may be subject to change, could result in a variety of adverse consequences, including civil penalties, fines, suspension or expulsion, and termination of deposit insurance, which may have material adverse effects. In order to comply with banking laws, rules and regulations, the PE Funds may be required to invest in a manner that may not be as advantageous as the manner of making investments that are not subject to such laws, rules and regulations. Additionally, banks and bank holding companies are subject to various legal and regulatory limitations under federal and state law on the extent to which they can pay dividends or make

redemptions, depending on their financial condition. If such limitations applied to any portfolio companies of a PE Fund, such PE Fund’s return on investment could be adversely affected. If a PE Fund becomes a bank holding company, such PE Fund and any entities, including the PE Fund’s limited partners, deemed to control the PE Fund may be subject to regulation under the Bank Holding Company Act of 1956 and other Federal and state banking laws. Investments Outside of Atlas’s Focus Areas and Primary Strategy: Investments outside of a PE Fund’s primary strategy will be subject to numerous and substantial risks. These risks include, without limitation: (i) the accumulation of minority positions in the outstanding voting stock, or securities convertible into the voting stock, of potential portfolio companies that may provide a PE Fund a limited ability to protect its position in such portfolio companies; (ii) investments in public companies that may be subject to greater volatility in their valuation, increased disclosure obligations, liquidity limitations at certain times, and increased likelihood of shareholder litigation; and (iii) turnaround or underperforming companies that may have weak financial conditions or highly leveraged balance sheets. Reliance on Portfolio Company Management: The day-to-day operations of a portfolio company are the responsibility of such company’s management team. Such responsibility includes, but is not limited to, managing regulatory, compliance and legal risks at the portfolio companies, including, without limitation, tax, the U.S. Employee Retirement Income Security Act of 1974 (as amended), pension, environmental, U.S. Foreign Corrupt Practices Act of 1977 (as amended) and jury verdict risks. Such risks and liabilities could result in substantial costs to a portfolio company or even cause bankruptcy. Although Atlas is responsible for monitoring the performance of portfolio companies and generally seeks to invest in companies operated by capable management and to assist existing management where possible, there can be no assurance that an existing management team, or any successor, even with the assistance of Atlas, will be able to successfully operate a portfolio company in accordance with Atlas’s strategy for such company. Investments Outside the United States, Canada, Western Europe and Japan: Although the PE Funds intend to invest primarily in companies headquartered in the United States, Canada, Western Europe and Japan, the PE Funds may from time to time invest in securities of companies headquartered elsewhere. Investing outside the United States, Canada, Western Europe and Japan may involve greater risks than investing in the United States. In particular, the value of the PE Funds’ investments in foreign securities and the income and other proceeds received with respect to such investments, may be denominated in local currencies other than the U.S. dollar and therefore may be significantly affected by changes in currency exchange rates, which may be volatile. Although the General Partners may attempt to hedge against foreign currency exchange rate risks by utilizing spot and forward foreign exchange contracts, foreign currency options or other instruments, there can be no assurance that the General Partners will be able to do so successfully or cost-effectively and the General Partners may decide not to hedge against such risks or to do so only incompletely. Additional risks may include: (i) risks of economic dislocations in the host country; (ii) less publicly available information; (iii) less well developed regulatory institutions; and (iv) greater difficulty of enforcing legal rights in a foreign jurisdiction. Moreover, companies outside the

United States, Canada, Western Europe and Japan may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those that apply to companies in the United States, Canada, Western Europe and Japan. Additionally, in some countries outside the United States, Canada, Western Europe and Japan, there is the possibility of expropriation of value, including through confiscatory taxation, limitations on the repatriation or sale of securities, property or other assets of the PE Funds, political or social instability or diplomatic developments, each of which could have an adverse effect on the PE Funds’ investments in such foreign countries. While the General Partners will take these factors into consideration in making investment decisions for the PE Funds, no assurance can be given that the General Partners will be able to evaluate these risks accurately. Follow-On Investments: The PE Funds may be called upon to provide follow-on funding for their portfolio companies or have the opportunity to increase their investments in some portfolio companies. There can be no assurance that the PE Funds will wish to make such follow-on investments or that the PE Funds will have sufficient funds to do so. Any decision not to make follow-on investments or the inability to make them may have a substantial negative impact on a portfolio company in need of such an investment or may diminish the PE Funds’ ability to influence the portfolio company’s future development. An investment in a PE Fund requires a long-term commitment with no certainty of return. It is unlikely there will be near-term cash flow available to the investors. Many of the PE Funds’ investments will be highly illiquid and there can be no assurance that the PE Funds will be able to realize such investments at attractive prices or otherwise be able to affect a successful realization or exit strategy. Consequently, partial or complete sales, transfers or other dispositions of such investments resulting in a return of capital or the realization of gains, if any, may require a lengthy time period or may result in distributions in kind to the investors. Additionally, the PE Funds may acquire securities that cannot be sold except pursuant to a registration statement filed under the Securities Act, or in accordance with Rule 144 promulgated under the Securities Act. There can be no assurance that private purchasers can be found for the PE Funds’ investments. The sale of restricted securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. As such, restricted securities may sell at a price lower than similar securities that are not subject to restrictions on resale. Such illiquidity may continue even if a PE Fund’s portfolio company obtains a listing on a securities exchange and/or after the term of a PE Fund has ended or a PE Fund has commenced dissolution. In addition, there can be no assurance that the disposition of a portfolio company will occur in one transaction. If a PE Fund effects a disposition of a portfolio company by means of a multi-step disposition, there can be no assurance that the remainder can be successfully sold. A multi-step disposition may result in a PE Fund holding a non-controlling interest in a portfolio company, which would result in the PE Fund having a limited ability to protect its position in such portfolio company. Dispositions of investments may be subject to legal, contractual and other limitations on transfer, the absence of an established market for the investments, or other restrictions that would interfere with sales of such investments or adversely affect the terms that could be obtained upon any disposition thereof. Such restrictions may apply even after the term of the PE Funds has ended or

the PE Funds have otherwise been dissolved. The PE Funds may have to sell, distribute or otherwise dispose of investments at a disadvantageous time as a result of its dissolution. This risk may be especially present with respect to investments made in the final years or months of the PE Funds’ commitment period and follow-on investments made thereafter. Investments in publicly traded companies (including, without limitation, portfolio companies that have made initial public offerings) may also be subject to legal or contractual restrictions on resale, including, without limitation, the possibility that Atlas or its affiliates will be in possession of material non-public information about the company. Public offering, merger and acquisition and recapitalization and reorganization opportunities may be limited or non-existent for extended periods of time, whether due to economic, regulatory or other factors. Such illiquidity may continue even if the underlying entities obtain listings on securities exchanges. Moreover, it is difficult to predict with any certainty whether there will be a ready and willing market of buyers for any particular portfolio company at the time the PE Funds seek a realization. In view of these limitations on liquidity, which are illustrative only and not exhaustive, the PE Funds will generally not be able to realize an investment in a privately held entity for a substantial number of years. There can be no assurance that the PE Funds will be able to dispose of its investments at the price and at the time it wishes to do so. There can be no assurances that the returns generated by the PE Funds’ investments will compensate the limited partners adequately for the business and financial risks assumed. There can be no assurances that the PE Funds will be able to dispose of investments at prices equal to or greater than the price at which the PE Funds purchased such investments. Operating and Financial Risks of Portfolio Companies: The performance of any portfolio company could deteriorate as a result of, among other factors, an adverse development in its business, a change in its competitive environment or an economic downturn. As a result, businesses that may have been expected to be stable may operate at a loss or have significant variations in operating results, may require substantial additional capital to support their operations or to maintain their competitive positions or may otherwise have a weak financial condition or be experiencing financial distress. In some cases, the success of a PE Fund’s investment strategy and approach will depend, in part, on the ability of Atlas and such portfolio company’s management teams to effect improvements in the operations of such portfolio company. The activity of identifying and implementing operating improvements and capturing synergies entails a high degree of uncertainty. There can be no assurance that Atlas or such portfolio company’s management team will be able to successfully identify and implement such operating improvements and capture synergies. In addition, a PE Fund may cause portfolio companies to bear certain fees, costs and expenses that such portfolio company would not otherwise bear, including the fees, costs and expenses incurred in developing, investigating, negotiating, structuring or consummating such PE Fund’s investments in such portfolio company. The payment of such fees, costs and expenses by such portfolio company will generally reduce the amount of cash that such portfolio company has on hand.

Leverage: The capital structures of certain financial services companies may include leverage and in some cases substantial leverage. If Atlas seeks to use leverage for a portfolio company, it will do so in a manner it believes is appropriate under the circumstances for such portfolio company. A leveraged capital structure of a portfolio company will increase the exposure of the portfolio company to adverse economic factors such as rising interest rates, downturns in the economy or deteriorations in the condition of the portfolio company or its industry which may impair such portfolio company’s ability to finance their future operations and capital needs and result in restrictive financial and operating covenants. As a result, such portfolio company’s flexibility to respond to changing business and economic conditions may be limited. If, for any of these reasons, a portfolio company is unable to generate sufficient cash flow to meet principal and/or interest payments on its indebtedness or similar payments or obligations, the value of the PE Fund’s investment in such portfolio company could be significantly reduced or even eliminated. The ability of a portfolio company to refinance debt securities may depend on their ability to sell new securities in the public high yield debt market or otherwise, or to raise capital in the leveraged finance debt markets, which historically have been cyclical with regard to the availability of financing. There can be no guarantee that debt facilities will be available at commercially attractive rates throughout the term of a given PE Fund or when due for refinancing such that such PE Fund or the applicable portfolio company will be exposed to less favorable terms or rates upon a refinancing, or that any facilities negotiated will be fully utilized. If a portfolio company is unable to refinance its debt or maintain the desired amount of financial leverage, such PE Fund may realize lower than expected returns from the portfolio company and may hold a larger than expected equity investment in such portfolio company. In addition, portfolio investments may be consummated through the use of leverage at the PE Fund level. Utilization of leverage will result in fees, expenses and interest costs to the PE Fund making the investment. Although the use of leverage may enhance returns and increase the number of investments that can be made, it may also substantially increase the risk of loss. Control Position Risk: The PE Funds intend to primarily make investments that allow the PE Funds to acquire control or exercise influence over management and the strategic direction of a portfolio investment as described in the Governing Fund Documents. This may be through such PE Fund’s representation on the portfolio company’s Board of Directors or otherwise. The exercise of control over a company imposes additional risks of liability for environmental damage, product defects, pension liabilities, failure to supervise management, violation of governmental regulations and other types of liability in which the limited liability characteristic of business operations may be ignored. The exercise of control over a portfolio investment could expose the assets of the PE Funds to claims by the portfolio companies underlying such investments, its security holders and its creditors. While Atlas intends to manage the PE Funds to minimize exposure to these risks, the possibility of successful claims cannot be precluded. Regional Depository Fund With respect to the Regional Depository Fund, the Firm targets privately negotiated and open market minority investments in the equity and debt of primarily U.S. regional banks. The Regional Depository Fund otherwise follows the same general risk factors as the PE Funds. An investment in the Regional Depository Fund involves significant risk and potential conflicts of interest. There

can be no assurance that the Regional Depository Fund’s investment objectives will be achieved, and actual investment results may vary substantially from the investment objective. Investors should be prepared to bear these risks. The descriptions contained below are a brief overview different risks related to the Regional Depository Fund; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operations of the Regional Depository Fund. Investors should carefully consider all risk factors set forth in the Regional Depository Fund’s Governing Fund Documents. Each prospective investor should carefully review the Governing Fund Documents before deciding to make an investment in the Regional Depository Fund. Each prospective investor should consult with his or her own counsel and advisors as to all legal, tax, financial and related matters concerning an investment in the Regional Depository Fund. Banking Industry Risk Factors: The Regional Depository Fund expects to invest primarily in the equity of U.S. regional banks and bank holding companies (“BHCs”). Banks have asset and liability structures that are based on maturity transformation and are directly affected by many factors, including domestic and international economic and political conditions, broad trends in business and finance, legislation and regulation affecting the national and international business and financial communities, monetary and fiscal policies, interest rates, inflation, currency values, market conditions, the availability and cost of short- or long-term funding and liquidity, capital management, the credit capacity or perceived creditworthiness of customers and counterparties and the level and volatility of trading markets as described above. Such factors can impact bank customers and counterparties and may impact the value of a bank’s assets, liabilities, and financial results. Fluctuations in interest rates, which affect the value of assets and the cost of funding liabilities, are not predictable or controllable, may vary from country to country, and may impact economic activity in various regions. A bank’s business and earnings will be significantly affected by the fiscal and monetary policies of the federal government and its agencies. Banks are particularly affected by the policies of the Board of Governors of the Federal Reserve System(the “Federal Reserve Board”), which regulates the supply of money and credit in the United States. The Federal Reserve Board’s monetary policy decisions directly affect the availability of bank loans and deposits, as well as the interest rates charged on loans and paid on deposits. Changes to Federal Reserve Board policies may have a material effect on a bank’s business, results of operations, and financial condition. The banking industry is extremely competitive, and it is expected that competitive conditions in the industry will continue to intensify. New competitors in the banking industry continue to emerge. For example, technological advances and the growth of e-commerce have made it possible for non-depository institutions to offer products and services that traditionally only offered by banks. These advances have also allowed financial institutions and other companies to provide electronic and internet-based financial solutions, including electronic securities and cryptocurrency trading, lending and other extensions of credit to consumers, payments processing, and online automated, algorithmic-based investment advice. Furthermore, both banks and their non-bank competitors face the risk that payments processing and other products and services, including deposits and other traditional banking products, could be significantly disrupted by the use of new technologies, such as cryptocurrencies and other applications using secure distributed ledgers, that may not require intermediation. New technologies have required and could require

banks to spend more to modify or adapt its products to attract and retain clients and customers or to match products and services offered by its competitors, including technology companies. In addition, new technologies may be used by customers, or breached or infiltrated by third parties, in unexpected ways, which can increase banks’ costs for complying with laws, rules, and regulations that apply to the offering of products and services through those technologies and reduce the income that banks earn from providing products and services through those technologies. Ongoing or increased competition may put pressure on the pricing for banks’ products and services or may cause banks to lose market share with respect to traditional banking products. This competition may be based on quality and variety of products and services offered, transaction execution, innovation, reputation, and price. The failure of any of a bank’s businesses to meet the expectations of clients and customers, whether due to general market conditions, underperformance, a decision not to offer a particular product or service, changes in client and customer expectations or other factors, could affect a bank’s ability to attract or retain clients and customers. Any such impact could, in turn, reduce a bank’s revenues. Increased competition also may require a bank to make additional capital investments in its businesses, or to extend more of its capital on behalf of its clients to remain competitive. In addition, frequent changes and inconsistencies in financial services regulation and supervision can negatively impact a bank’s businesses, operations, and financial results. For example, financial technology companies and other non-traditional competitors are generally not subject to the same regulations as a bank, or may be supervised by a federal or state regulatory agency that does not have the same resources or regulatory priorities as the federal bank regulatory agencies. Banks may also be harmed by competition in the provision of consumer credit by bank or nonbank competitors. Heightened competition for certain types of consumer loans could prompt industry-wide reactions such as significant reductions in the pricing or margins of those loans or the making of loans to less-creditworthy borrowers. If large numbers of consumers subsequently default on their loans, whether due to weak credit profiles, an economic downturn, or other factors, this could impair their ability to repay obligations owed to a given bank and result in higher chargeoffs and other credit-related losses. More broadly, widespread defaults on consumer debt could lead to recessionary conditions in the U.S. economy, and a bank’s consumer businesses may earn lower revenues in such an environment. A bank’s compensation practices are subject to review and oversight by the Federal Reserve Board, the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), and other federal regulators. The federal banking agencies have issued joint guidance on executive compensation designed to help ensure that a banking organization’s incentive compensation policies do not encourage imprudent risk taking and are consistent with the safety and soundness of the organization. In addition, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) required those agencies, along with the SEC, to adopt rules to require reporting of incentive compensation and to prohibit certain compensation arrangements. If as a result of complying with such guidance or rules a bank is unable to attract and retain qualified employees, or do so at rates necessary to maintain its competitive position, or if the compensation costs required to attract and retain employees become more significant, a bank’s performance, including its competitive position, could be materially adversely affected. A bank’s ability to complete acquisitions is in many instances subject to regulatory approval, and a bank or BHC cannot be certain when or if, or on what terms and conditions, any required

regulatory approvals would be granted. In recent years, federal authorities, including the federal banking agencies and Department of Justice, have increased their scrutiny of bank mergers and acquisitions, and there is continued uncertainty with regard to how they will evaluate bank mergers and acquisitions, including from an antitrust perspective. Any requisite approval could be delayed or not obtained at all, including due to, among other factors, an adverse development in either party’s regulatory standing or in any other factors considered by regulators when granting such approval, including factors not known at the time of entering into the definitive agreement for the acquisition or submission of the related application for regulatory approval, and factors that may arise subsequently; governmental, political or community group inquiries, investigations or opposition; or changes in legislation or the political environment more generally. Anticipated challenges in obtaining any requisite regulatory approval, or uncertainty as to the prospects for obtaining approvals, could also prevent a bank or BHC from pursuing a potential acquisition it may otherwise view as attractive. Further, changes in banking or tax laws or regulations that could impair or eliminate the expected benefits of merger and acquisition activities. Recent events impacting the banking industry, including the failures of Silicon Valley Bank, Signature Bank, and First Republic Bank, have resulted in increased scrutiny on banks (particularly regional banks) among consumer and commercial depositors, other counterparties and investors, as well as significant disruption, volatility and reduced valuations of equity and other securities of banks in the capital markets. These events occurred during a period of rapidly rising interest rates which, among other things, had resulted in unrealized losses in longer duration securities and loans held by banks, and more competition for bank deposits. These events may increase the risk of a potential recession. These recent events have, and could continue to, adversely impact the market price and volatility of a bank’s common stock. These recent events also may result in potentially adverse changes to laws or regulations governing banks and BHCs or result in the impositions of restrictions through supervisory or enforcement activities, including higher capital requirements, which could have a material impact on a bank’s profitability. For example, in November 2023, the FDIC implemented a special assessment to recover losses to the Deposit Insurance Fund following the spring of 2023 bank failures. Inability to access short-term funding, reduction of client deposits or changes in a bank’s credit ratings could increase the cost of funding, limit access to capital markets, or negatively impact a bank’s overall liquidity or capitalization. A bank may be impacted by concerns regarding the soundness or creditworthiness of other financial institutions, which can cause substantial and cascading disruption within the financial markets and increased expenses. Banks are subject to various regulatory capital requirements, including leverage- and risk-based capital requirements. The Basel III capital standards substantially revised the risk-based capital requirements applicable to BHCs and their depository institution subsidiaries, including the definitions and the components of Tier 1 capital and total capital, the method of evaluating riskweighted assets, institution of a capital conservation buffer, and other matters affecting regulatory capital ratios. Strict eligibility criteria for instruments to be considered regulatory capital were also implemented under the rules. The federal banking agencies have released a proposal to amend the Basel III risk-based capital framework which could significantly revise the risk-based capital requirements for banks with assets of $100 billion or more. In addition, enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act in May 2018 significantly tailored several provisions of the Dodd-Frank Act, including how stress tests are run. Bank holding companies with total assets of less than $100 billion are no longer subject to company-run

stress testing requirements under section 165(i)(2) of the Dodd-Frank Act, including publishing a summary of results. There may be increased regulatory scrutiny in the course of routine examinations, and new regulations designed to respond to recent negative developments in the banking industry, all of which may increase a bank’s costs of doing business and reduce its profitability. Among other things, there may be increased focus by both regulators and investors on deposit composition, the level of uninsured deposits, brokered deposits, unrealized losses in securities portfolios, liquidity, commercial real estate composition and concentration, capital, and general oversight and control of the foregoing. Banks could face increased scrutiny or be viewed as higher risk by regulators and/or the investor community, which could negatively affect their results of operations and financial condition. In addition, laws, regulations, and the expectations of federal and state banking regulators, investors, and other stakeholders regarding appropriate climate-related financial risk management, practices and disclosures are continuously evolving and may require banks to adhere to new or heightened requirements and expectations regarding the disclosure and management of their climate-related financial risks and related lending, investment, operations and advisory activities. For example, the Federal Reserve Board, FDIC, and OCC jointly issued interagency guidance for large financial institutions on principles for climate-related financial risk management in October 2023. The New York State Department of Financial Services issued final guidance for New York State-regulated banking and mortgage institutions relating to the management of material financial and operational risks due to climate change in December 2023, and the SEC finalized climate-related disclosure rules in March 2024. In addition, a number of states have proposed or enacted statutes and regulations addressing climate change and sustainability issues. Any such new or heightened requirements may result in higher regulatory, compliance, and other expenses, and may subject a bank to different and potentially conflicting requirements in the various jurisdictions in which it operates. SPAC Fund The SPAC Fund was formed to invest in SPACs and their sponsors. The SPAC Fund is in the process of winding-down and is no longer accepting subscriptions. An investment in the SPAC Fund involves significant risk and potential conflicts of interest. There can be no assurance that a SPAC Fund’s investment objectives will be achieved, and actual investment results may vary substantially from the investment objective. Investors should be prepared to bear these risks. The descriptions contained below are a brief overview of different risks related to the SPAC Fund’s investment strategy; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operations of the SPAC Fund. Investors should carefully consider all risk factors set forth in the SPAC Fund’s Governing Fund Documents. Each prospective investor should carefully review the applicable Governing Fund Documents before deciding to make an investment in the SPAC Fund. Each prospective investor should consult with his or her own counsel and advisors as to all legal, tax, financial and related matters concerning an investment in the SPAC Fund.

No Assurance of Returns; Relation to Other Investment Results: There is no assurance that the SPAC Fund will be able to generate returns for its investors or that the returns will be commensurate with the risks of investing in SPACs and their sponsors. There can be no assurance that the SPAC Fund’s investment objectives will be achieved or that there will be any return of capital. Therefore, an investor should only invest in the SPAC Fund if the investor can withstand a total loss of its investment. The past investment performance of the entities with which officers and employees of Atlas have been associated cannot be taken to guarantee future results of any investment in the SPAC Fund. Nothing contained herein should be deemed to be a prediction or projection of the future performance of the SPAC Fund. Risks Related to Investments in SPACs: A SPAC is a single-use vehicle incorporated for the purpose of raising capital through an initial public offering to fund the acquisition, through a merger, capital stock exchange, asset acquisition or other similar business combination, of one or more operating businesses. After the acquisition of a target company, a SPAC typically would exercise control over the management of such target company to increase the target company’s value. Capital raised through the initial public offering of securities of a SPAC is typically placed into a trust until the target company is acquired or a predetermined period of time elapses. Investors in a SPAC typically would receive a return on their investment in the event that a target company is acquired and such target company’s value increased. If a SPAC is unable to locate and acquire a target company (or target companies) by the deadline, the SPAC would be forced to liquidate its assets, which could result in losses due to the SPAC’s expenses and liabilities. There are a number of risks associated with investing through SPACs, including: (i) because a SPAC is typically created without a specifically-identified acquisition target, it never, or only after an extended period of time, find and execute a suitable transaction, during which period the capital committed to or invested in the SPAC will not be available for other uses; (ii) SPACs invest in single assets and not diversified portfolios, and investments therein are therefore subject to significant concentration risk; (iii) SPACs are exempt from the rules promulgated by the SEC to protect investors in “blank check” companies, such as Rule 419 promulgated under the Securities Act, so investors in SPACs are not afforded the benefits or protections of those rules; (iv) SPACs could generate substantial fees, costs and expenses (including fees that accrue to the benefit of Atlas without any offset against fees payable by the SPAC Fund), which are typically borne by the investors therein (in some cases, regardless of whether, or when, the SPAC consummates a transaction); (v) the value of any target company could decrease following its acquisition by a SPAC; (vi) the value of the SPAC Fund invested and held in the trust could decrease as the SPAC is locating a target by the deadline; (vii) if a SPAC is unable to consummate a business combination, the SPAC Fund is forced to wait until the deadline before liquidating distributions are made; (viii) redemption rights make SPACs unattractive to targets or preclude SPACs from completing a business combination; and (ix) the use of SPACs as an investment tool has only recently become more widespread, and there remains substantial uncertainty regarding the viability of SPAC investing on a large scale, the supply of desirable target companies and whether or to what degree regulatory, tax or other authorities will implement additional or adverse policies relating to SPACs and SPAC investing.

Risks Applicable to all Funds LP Advisory Committees: Certain Funds have advisory boards that consist of representatives of certain investors in such Funds. Any approval or consent given by such advisory boards tends to be binding on such Funds and all of their investors. Members of such advisory boards are also authorized to give approvals or consents required under the Advisers Act (as defined herein), including in respect of conflicted transactions (including principal transactions under Section 206(3) of the Advisers Act) and consents to the “assignment” of a client’s advisory agreement under the Advisers Act. Members of such advisory boards owe no fiduciary duty to the Fund, are under no obligation to act in the best interests of the Fund as a whole, and could choose to act only in the best interests of the investor with which such member is affiliated. Although Atlas has adopted policies and procedures designed to manage conflicts among Clients, members of the advisory boards could themselves have conflicts of interest that do not disqualify such members from voting or consenting to matters submitted to their advisory boards for consideration or review. Among other things, the possibility exists that the respective advisory boards of two or more Funds will have overlapping membership, and such overlapping membership may result in a member having a conflict of interest. For example, in a cross trade situation where Atlas arranges for a Fund to purchase an investment from or sell an investment to another Fund, if an advisory board member has an interest in both Funds involved in the cross trade, such member could favor one Fund over the other if such member’s interests are more aligned with the Fund it favors. As a result, if the member has an interest unrelated to Atlas, it could choose not to act in the best interests of the Fund that it represents. In such instances, Atlas expects that such advisory board member will act in the best interests of the Fund that it represents; however, there is no assurance that such conflicts of interest will be eliminated. Furthermore, there could arise certain instances where, notwithstanding that a Fund’s Governing Fund Documents could suggest that a particular transaction or conflict of interest ought to be submitted to the advisory board for its review or consent, Atlas could instead defer to the judgment of a portfolio investment’s board of directors (or equivalent body) with respect to such transaction or conflict of interest, including, for example if such portfolio investment is publicly traded, if Atlas does not control such portfolio investment or if the portfolio investment has its own conflicts committee. Additionally, it is expected that investors in Funds who designate representatives to participate on the advisory boards may, by virtue of such participation, have more information about the Fund and investments in certain circumstances than other investors generally and may be provided information in advance of communication to other investors generally. Systems Risk and Cybersecurity: The Funds depend on Atlas and its affiliates to develop and implement appropriate systems for its activities. Atlas and its affiliates rely heavily on computer programs and systems (and may rely on new systems and technology in the future) and service providers for various purposes in connection with its activities on behalf of its investors, including, without limitation, to trade, clear and settle transactions, to evaluate certain financial instruments, to monitor its portfolio and net capital and to generate risk management and other reports that are critical to oversight of such investors’ activities. Certain of Atlas’s and the Funds’ activities will

be dependent upon systems operated by third parties, including, without limitation, prime brokers, market counterparties, administrators, and Atlas may not be in a position to verify the risks or reliability of such third-party systems. The Funds’ service providers may also depend on information technology systems and, notwithstanding the diligence that Atlas may perform on its service providers, Atlas may not be in a position to verify the risks or reliability of such information technology systems. The failure, corruption or breach of one or more systems (including as a result of the occurrence of a disaster such as a cyberattack, a natural catastrophe, an industrial accident, a terrorist attack or war, events unanticipated in Atlas’s disaster recovery systems, or a support failure from external providers) operated by a service provider, or the inability of such systems to satisfy the Funds’ needs, including, without limitation, the execution of orders, could have a material adverse effect on Atlas’s ability to conduct business and thus, the Funds and their performance, particularly if those events affect Atlas’s computer-based data processing, transmission, storage and retrieval systems or destroy Atlas’s data. If a significant number of Atlas’s personnel were to be unavailable in the event of a disaster, Atlas’s ability to effectively conduct the Funds’ business could be severely compromised. Atlas, the Funds, their portfolio companies and their respective service providers depend heavily upon computer systems to perform necessary business functions. Atlas’s and the Funds’ computer systems could be subject to cyber attacks and unauthorized access, such as physical and electronic break-ins, unauthorized tampering or unauthorized access to sensitive information, including, without limitation, information regarding the limited partners and the Funds’ investment activities, or to render data or systems unusable, which could result in significant losses. Like other companies, Atlas and the Funds may experience threats to its data and systems, including through malware and computer virus attacks, unauthorized access, system failures and disruptions. If one or more of these events occurs, it could potentially jeopardize the confidential, proprietary and other information processed and stored in, and transmitted through, Atlas’s and the Funds’ computer systems and networks, which could lead to or cause (i) losses of sensitive information or capabilities essential to Atlas’s, the Funds’ and/or the portfolio company’s operations, (ii) the disclosure of limited partners’ personal information, and/or (iii) interruptions or malfunctions in their operations, which could all result in damage to their reputation, financial losses, potential liability, litigation, remedial actions, loss of business, increased costs, regulatory penalties and/or customer dissatisfaction or loss and could have a material effect on the Funds. Cybersecurity attacks are evolving and include, but are not limited to, malicious software, attempts to gain unauthorized access to data, and other electronic security breaches that could lead to disruptions in critical systems, unauthorized release of confidential or otherwise protected information and corruption of data. Atlas’s or a portfolio company’s controls and procedures, business continuity systems and data security systems could prove to be inadequate. These problems may arise in both Atlas’s or a portfolio company’s internally developed systems and the systems of third–party service providers. The use of personal information by the Funds and their portfolio companies is regulated by foreign, federal and state laws, as well as by certain third-party agreements. As privacy and information security laws and regulations change or as new laws are enacted, the Funds and their portfolio companies may incur additional costs to ensure that they remain in compliance with those laws and regulations.

The occurrence of an extreme event may result in (and, in the case of COVID-19, has already resulted in) the closure of offices, the implementation of global or regional work-from-home policies, and/or travel disruptions or restrictions. Any such actions may increase Atlas’s, the General Partners’, their portfolio companies’ and their respective affiliates’ and service providers’ dependency on technology systems such as those described above; result in the rapid deployment of new and potentially less familiar technology or operations systems; or lead to the utilization of existing systems in a significantly increased scope or unanticipated manner. If a significant number of Atlas’s personnel were to be unavailable in the event of a disaster or other event, Atlas’s ability to effectively conduct the Funds’ business could be severely compromised. All of the above could increase the risk of cybersecurity or business continuity related losses, all of which could have a material effect on the Funds. Artificial Intelligence and Machine Learning Developments. The use and rapid proliferation of artificial intelligence models, tools, algorithms, networks and functionality (including machine learning technology and large language models) (collectively, “AI Technology”), pose risks to Atlas, the Funds and the Funds’ portfolio companies. Atlas could be further exposed to the risks of AI Technology if third-party service providers or any contractual counterparties, whether or not known to Atlas, use AI Technology in their business activities in ways that give rise to business or regulatory risk (including prohibited or high-risk use cases under legislation such as the European Union’s AI Act). Atlas will not be in the position to control the way third-party products using AI Technology are developed or maintained, or the in which third-party services are provided. The use of AI Technology may result in claims by third parties, regulatory actions and other liabilities for Atlas, including claims, actions and liabilities that were not foreseen or foreseeable. Among other things, Atlas’s use of AI Technology may depend on access to third-party products that could be modified, restricted or discontinued, potentially disrupting operations and creating legal or reputational risk. Further, use of AI Technology by any of the parties described in the previous paragraph could include the input of confidential information (including material, nonpublic information), sensitive financial information, personally identifiable information or thirdparty proprietary materials (including intellectual property rights), whether authorized to do so, or by third parties in contravention of agreements, or by Atlas personnel and affiliates and other persons, in each case, in contravention of the AI Policy, into AI Technology applications. It is possible that such actions could result in confidential information becoming part of a dataset accessible by other third-party AI Technology applications and users. Use of this information and materials in this manner could result in damage to Atlas’s business (including reputational damage), regulatory investigations or fines and/or claims by third parties under contract or law. There are also risks associated with authorized use of AI Technology. Such AI Technology is highly reliant on the collection and analysis of large amounts of data, and it may not be possible or practicable to incorporate all relevant data into the model that AI Technology utilizes to operate. Moreover, certain data in such models may contain a degree of inaccuracy and error, potentially materially so, and could otherwise be inadequate or flawed, which would likely degrade the accuracy and effectiveness, and increase the risk of use, of AI Technology. AI Technologies may also be susceptible to manipulation by third parties, including through prompt injection and other adversarial interference, that could degrade accuracy and performance. In addition, even with accurate and complete data, AI Technology is known to sometimes produce output that contains

unknown errors. AI Technologies may also be capable of taking actions on behalf of Atlas, which may be executed incorrectly or have unintended effects, including on third parties. To the extent that Atlas, the Funds, and the Funds’ portfolio companies are exposed to the risks of AI Technology use, any such inaccuracies, errors or unintended effects could have adverse impacts on Atlas, the Funds and the Funds’ portfolio companies, including as a result of third-party (including employee) claims arising from such inaccuracies or errors. Additionally, AI Technology may generate outputs that violate applicable law or the rights, including intellectual property rights, of third parties. Atlas may face legal risks to the extent it uses, relies upon or disseminates such outputs. The legal framework governing development, training and use of AI Technology continues to evolve and change, including at the state, national and international levels. These laws and regulations, to the extent applicable, may result in a change to Atlas’s practices and create additional regulatory uncertainty. AI Technology and its applications, including in the private investment and financial sectors, continue to develop rapidly, and it is impossible to predict the future risks that may arise from such developments. Atlas’s use of evolving AI Technology may result in consequences that are unknown or are not currently foreseeable. Political Uncertainty: The rise of populist political parties and economic nationalist sentiments have led to increasing political uncertainty and unpredictability throughout the world that may adversely affect the price, validity and/or liquidity of the Funds’ investments. Terrorist Action, Natural Disasters and Epidemics: Companies or assets may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fires, floods, earthquakes, outbreaks of infectious disease, pandemics or any other serious public health concerns, wars, terrorism and labor strikes). Natural disasters, epidemics and other acts of God, which are beyond the control of Atlas and the General Partner, may negatively affect the economy, infrastructure and livelihood of people throughout the world. For example, southeast Asia and many countries in Asia, including China, Japan, Indonesia and Australia have been affected by earthquakes, floods, typhoons, drought, heat waves or forest fires. Disease outbreaks have occurred in Asia in the past (including severe acute respiratory syndrome, or SARS, avian flu, H1N1/09 flu and COVID-19 and other pandemics), and any prolonged occurrence of infectious disease, or other adverse public health developments or natural disasters, in any country related to Atlas’s investments may have a negative effect on the Funds. In addition, there are increased risks relating to Atlas’s (and its portfolio companies’ and service providers’) reliance on its computer programs and systems if Atlas’s personnel are required to work remotely for extended periods of time as a result of events such as the outbreak of infectious disease or other adverse public health developments or natural disasters, including an increased risk of cyber-attacks and unauthorized access to Atlas’s computer systems. Additionally, there is a risk of terrorist attacks on the United States and elsewhere, which could cause a significant loss of life and property damage and disruptions in global markets. For example, as a result of any terrorist attack, economic and diplomatic sanctions may be in place or imposed on certain countries and military action may be commenced. Some force majeure events may negatively affect the ability of a party (including a Fund or a counterparty to a Fund) to perform

its obligations until it is able to remedy the force majeure event. In addition, the cost to the Funds of repairing or replacing damaged assets resulting from such force majeure event could be considerable. Certain force majeure events (such as war or an outbreak of infectious disease) could have a broader negative impact on the world economy and international business activity generally, or otherwise negatively impact any country related to the Funds’ investments. Any of the foregoing may therefore negatively affect the performance of the Funds. Losses resulting from any of the foregoing may either be uninsurable or only insurable at such high rates as to make such coverage impracticable. If any such major uninsured loss were to occur with respect to any Fund’s investments, such Fund could incur substantial losses. General Economic Conditions and Recent Geopolitical Events: Various sectors of the global financial markets intermittently experience periods of adverse conditions, including pandemics, significant disruptions in global supply chains, natural disasters due to climate change, high inflation, changes in global leadership, and wars. Market conditions in the United States and Europe can be uncertain, and adverse market conditions have expanded to other markets. These conditions have resulted in disruption of the global credit markets, periods of reduced liquidity, high inflation, greater volatility, general widening of credit spreads and a lack of price transparency. These volatile and often difficult global credit market conditions have episodically adversely affected the market values of equity, fixed-income and other financial instruments and these circumstances may continue or potentially deteriorate even further. The Funds’ investments are expected to be sensitive to the performance of the overall global economy. A negative impact on economic fundamentals and consumer and business confidence would likely increase market volatility and reduce liquidity, both of which could have a material adverse effect on the performance of the Funds and these or similar events may affect the ability of the Funds to execute their investment strategies. Inflation Risk: High rates of inflation and rapid fluctuations in inflation rates have had, and may continue to have, a significant impact (often negative or adverse) on the financial markets and the broader economy. Inflation rates may continue to increase in the future, and government measures to control inflation, adopted presently or in the future, often have corresponding impacts (often negative or adverse) on the level of economic activity. Inflation could significantly increase the costs of operations of the Funds, adversely impact the availability of suitable investments or the performance thereof, and otherwise significantly adversely impact the financial condition of the Funds. Banking Industry Disruption: As a result of increasing interest rates, reserves held by banks and other financial institutions in bonds and other debt securities could face a significant decline in value relative to deposits and liabilities which, coupled with general economic headwinds resulting from a changing interest rate environment, creates liquidity pressures at such institutions. As a result, certain sectors of the credit markets could experience significant declines in liquidity, and it is possible that Atlas (with respect to Clients), and/or the management and other personnel of the portfolio investments owned by Clients, will not be able to manage this risk effectively. Climate Change: The Funds could acquire investments that are susceptible to the effects of climate change. For example, any portfolio companies with operations or assets located in coastal regions could be affected by any future increases in sea levels or in the frequency or severity of hurricanes

and tropical storms, whether such increases are caused by global climate changes or other factors. There could be significant physical effects of climate change that have the potential to have a material effect on the Funds’ business and operations. Physical impacts of climate change could include increased storm intensity and severity of weather (e.g., floods or hurricanes), sea level rise and extreme temperatures and wildfires. As a result of these physical impacts from climate-related events, the Fund could be vulnerable to the following: risks of property damage to the Funds’ investments; indirect financial and operational impacts from disruptions to the operations of the Funds’ investments from severe weather; increased insurance premiums and deductibles or a decrease in the availability of coverage for investments in areas subject to severe weather; decreased net migration to areas in which investments are located, resulting in lower-than-expected demand for the products and services of the investments, increased energy cost impacting operational returns, changes in the availability or quality of water or other natural resources on which the business depends, decreased consumer demand for consumer products or services resulting from physical changes associated with climate change; incorrect long-term valuation of an equity investment due to changing conditions not previously anticipated at the time of the investment and economic disruptions arising from the foregoing. Regional Conflicts. There are currently ongoing regional military conflicts in various regions of the world that have caused, and are expected to continue to cause, disruption to global financial systems, trade and transport, among other things. In response, multiple countries have put in place global sanctions and other severe restrictions or prohibitions on the activities of individuals and businesses connected to these regions. However, the ultimate impact of these conflicts and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of the Funds or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. These conflicts continue to have a significant impact and could result in significant losses to the Fund and its investors. The impact may include reductions in revenue and growth, unexpected operational losses and liabilities and reductions in the availability of capital. These conflicts could also limit the ability of a Fund to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy which any Fund intends to pursue, all of which could adversely affect a Fund’s ability to fulfill its investment objectives. Additional regional conflicts could arise in the future, which may raise similar or additional risks. Trade Wars: The tariffs imposed by the U.S. government on countries such as Mexico, Canada and the People’s Republic of China (“PRC”) as well as the European Union, corresponding retaliatory tariffs and the potential of trade wars between the U.S. and these countries (and certain other countries in the future), and on a larger scale, internationally, may dampen global growth. It remains unclear what additional actions, if any, the governments of the U.S. and Mexico, Canada, the PRC or the European Union (and certain other countries which may become subject to tariffs in the future) will take in respect of their bilateral trade, and what the timing may be of any such actions. The actions previously taken, as well as any future tariffs, new regulations or other burdens on international trade, may cause escalating responses through the use of local regulations, tariffs

or other requirements on exports and imports. If the U.S. government, in the future, subjects the services that any of the Funds’ portfolio companies provide, or the goods used for such portfolio companies to carry out their businesses, to proposed tariffs, the business operations and revenues of such portfolio companies, and, by extension, the returns of the Funds, may be negatively impacted. The political relationships between Mexico, Canada, the PRC, the European Union (and certain other countries which may become subject to tariffs in the future) and the U.S., as well as changes to international trade agreements, tariffs and import/export regulations, may affect the business operations of the Funds’ portfolio companies. Sustained tension between the United States and Mexico, Canada, the PRC, the European Union and other countries over trade policies could significantly undermine the stability of the global economy. Any prolonged slowdown in the global economy may have a negative impact on the Funds and their portfolio companies and their respective results of operations and financial condition, and continued turbulence in the international markets may adversely affect the Funds’ or their portfolio companies’ ability to access the capital markets to meet liquidity needs. If any new legislation and/or regulations are implemented, or if existing trade agreements are renegotiated, or if the U.S. or Mexico, Canada, the PRC or the European Union (or certain other countries which may become subject to tariffs in the future) impose additional burdens on international trade that negatively affect the ability of companies in the U.S. and Mexico, Canada, the PRC or the European Union (or certain other countries which may become subject to tariffs in the future) to import and export goods, it may lead to a decline in demand for the services of the companies in which the Funds invest. In addition, new legislative or regulatory changes or additional burdens focused on particular industries may make it time-consuming and expensive, and, ultimately, impracticable, for companies to alter their business operations to adapt to or comply with such changes, and such operational changes, if implemented, could have a negative effect on the business and financial condition of the companies in which the Funds invest. Difficulty of Locating Suitable Investments; Highly Competitive Market for Investment Opportunities: There can be no assurance that there will be a sufficient number of suitable investment opportunities to enable the Funds to invest all of their capital contributions in opportunities that satisfy the Funds’ investment objectives, or that such investment opportunities will lead to completed investments by the Funds. The process of identifying attractive investment opportunities is difficult and involves a high degree of uncertainty. The Funds will compete for investment opportunities with many other investors, some of which will have greater resources than the Funds. Some of these competitors may have more relevant experience, greater financial, technical, marketing, and other resources, more personnel, higher risk tolerances, different risk assessments, lower return thresholds, lower cost of capital, a greater ability to achieve synergistic cost savings than the Funds, a need to invest expiring capital commitments, a longer investment horizon than the Funds and access to funding sources unavailable to Atlas. Such competitors may include other private investment funds as well as, business development companies, special purpose acquisition corporations, firms that have historically been limited partners in private equity firms, venture capital firms, individuals, financial institutions, strategic or scaled acquisition firms, family offices and other institutional investors. Furthermore, the availability of investment opportunities generally will be subject to market conditions as well as, in some cases, the prevailing regulatory or political climate.

In addition, competition for appropriate investment opportunities may increase, thus reducing the number of opportunities available to the Funds and adversely affecting the terms upon which investments can be made. Outsourced Services: Consistent with what Atlas believes to be typical industry practice, Atlas from time to time outsources to third parties certain of the services performed for a Client and/or its portfolio companies, including services (such as administrative, legal, accounting, certain elements or portions of investment diligence and certain ongoing monitoring, tax or other related services) that could be expected to be performed in-house by Atlas and its personnel. In addition, certain services that are currently performed for Clients and/or their portfolio companies by Atlas, and which fees, costs and expenses are not currently borne by the Clients, may in the future be outsourced to such third-party services providers. Further, the decision by Atlas to initially perform a service for the Clients in-house does not preclude a later decision to outsource such services (or any additional services) in whole or in part to a third-party service provider in the future, and Atlas has no obligation to inform such Clients or investors of such a change. The fees, costs and expenses of such third-party service providers will be borne by the Clients as Operating Expenses, even if the costs of such services would not have been charged to Clients if performed in house. The decision to engage a third-party service provider and the terms (including economic terms) of such engagement will be made by Atlas in its discretion, taking into account such factors as it deems relevant under the circumstances, including for efficiency and economic considerations. Atlas will have an incentive to outsource services to third parties due to a number of factors, including because the fees, costs and expenses of such service providers will be borne, subject to a Client’s constituent documents, by Clients as operating expenses (with no reduction or offset to Atlas’s management fees), and retaining third parties could reduce Atlas’s internal overhead, compensation and benefits costs for employees who would otherwise perform such services inhouse. Such incentives likely exist even with respect to services where internal overhead, compensation and benefit costs are permitted to be charged to a Client in accordance with such Client’s constituent documents. The involvement of third-party service providers may present a number of risks due to Atlas’s reduced control over the functions that are outsourced. There can be no assurances that Atlas will be able to identify, prevent or mitigate the risks of engaging thirdparty service providers. Clients could suffer adverse consequences from actions, errors or failures to act by such third parties, and will have obligations, including indemnity obligations, and limited recourse against them. Outsourcing may not occur uniformly for all Clients and, accordingly, certain costs could be incurred by (or allocated to) certain Clients through the use of third-party (or internal) service providers that are not incurred by (or allocated to) other Clients for similar services. Selection of Service Providers: The Clients’ advisors and service providers (including accountants, administrators, lenders, bankers, brokers, attorneys, tax counsel, consultants, order management system, and investment or commercial banking firms) or their affiliates may provide goods or services to, or have business, personal, financial or other relations with Atlas, its employees (or their family members), affiliates, Clients, and/or portfolio companies. Such advisors and service providers may be investors in one or more of the Clients, sources of investment opportunities or

co-investors or commercial counterparties or entities in which Atlas or its employees (or their family members) or affiliates have an investment. Except as required by a Client’s Governing Documents, Atlas will generally have the discretion to select service providers independent of review by investors or consent by any relevant Client or limited partner advisory committee. The Clients, unless otherwise specified or agreed, will bear the cost of all such service providers, as appropriate. The service providers that Atlas selects for one or more of the Clients may also provide services to Atlas and/or its affiliates, or a portfolio company in a different capacity and/or at different rates. Fee discounts may be granted to Atlas, its affiliates in connection with such engagement and not the Clients or a portfolio company, or vice versa. This creates a potential conflict of interest where the interests of the parties are not aligned where, for example, a law firm may be at the same time engaged to provide services to both Atlas and one or more of the Clients or a portfolio company. Additionally, certain investors or employees of Atlas may have family members or relatives employed by such advisors and service providers. These relationships could influence Atlas or its affiliates or the applicable general partners in deciding whether to select or recommend such service providers to perform services for the Clients or portfolio companies (the cost of which will generally be borne directly or indirectly by the Clients or such entities, as applicable). Atlas attempts to mitigate the conflicts of interest associated with the selection of service providers through the use of reasonable diligence to select service providers, including without limitation, law firms, taking into account such factors as expertise, availability and quality of service, competitiveness of compensation rates, operational and regulatory controls, and comparing those factors with other similar service providers. Capitalized Transaction Costs: Any transaction expenses relating to unconsummated investments generally will be borne by the relevant Fund(s), except to the extent borne by co-investors or other third parties. Transaction-related expenses associated with consummated investments can, in certain circumstances, be charged to the relevant portfolio company rather than paid by the relevant Fund(s). Depending on the circumstances, such transaction-related expenses may be paid directly by the portfolio company or capitalized into the cost of the transaction. In some cases, transactionrelated expenses can include all or a portion of the actual or estimated interest expense associated with the use of a Fund’s subscription line of credit to consummate its investment in a portfolio company. The practice of causing a portfolio company to be bear transaction-related expenses can have the effect of reducing the overall amount of such expenses borne by a Fund (insofar as it results in other investors in the portfolio company, such as co-investors and management-related investors, bearing a portion of the expenses that might otherwise be borne solely by the Fund (and indirectly, by the Fund’s investors)), but can also result in an increase in the value of the portfolio company for purposes of calculating the Management Fee payable to Atlas during periods when a Fund’s Management Fee is calculated on the basis of actively invested capital. If transactionrelated expenses relating to consummated investments are not paid directly by such portfolio company or capitalized in the manner described above, then they will be paid by the applicable Fund(s) and included in the cost of investment, including for purposes of determining a Fund’s actively invested capital for Management Fee calculations). The inclusion of transaction-related expenses in the determination of a Fund’s actively invested capital increases the basis upon which

Management Fees are calculated, and Atlas therefore has a conflict of interest in determining whether certain expenses are in fact transaction-related and the extent to which they may be included in the determination of a Fund’s actively invested capital. This conflict may, however, be mitigated insofar as the inclusion of such amounts in actively invested capital increases the value of the Fund’s interest in a portfolio company for purposes of the Fund’s carried interest waterfall and contributes towards the preferred return that must be received on an investment before the General Partner is able to receive carried interest in connection with the investment’s realization. Agreements with Certain Investors: Certain investors in the Funds have been granted and in the future additional investors may be granted one or more of the following rights with respect to their investments: (i) a reduced management fee and/or performance-based compensation and/or operating expense; (ii) the right to receive improved fees, liquidity, information rights and other terms received by other investors; (iii) the right to receive certain additional information with respect to certain funds, including position-level portfolio information or events related to Atlas; (iv) the right to reserved capacity for a certain fund; (v) notification to the investor with respect to the investor’s ownership percentage of a certain fund; (vi) limitation on the investor’s ownership percentage of a certain fund below certain thresholds; (vii) notification to the investor with respect to the ownership by benefit plan investors of a certain fund’s equity classes; (viii) certain limitations on an investor’s confidentiality obligations under a certain fund’s organizational documents pursuant to laws or regulations to which the investor is subject (such as the public information or “sunshine” laws); and (ix) an acknowledgement that such investor is entitled to sovereign status under U.S. federal, state or non-U.S. law. In addition to the above, certain investors in the Funds have been granted and in the future additional investors may be granted one or more additional rights with respect to their investments, including, but not limited to: (i) the right to opt out of the requirement to fund capital calls or otherwise be excused from participating in certain investments due to regulatory, tax or public policy or the investor’s internal considerations; (ii) the right to designate one or more members of an investor advisory or oversight committee; (iii) rights with respect to distributions in kind; (iv) rights with respect to transfers of interests; (v) the right to receive information regarding the investment and/or disposition strategy of the relevant Fund; (vi) an acknowledgement that such investors are interested in learning about potential co-investment opportunities; (vii) the right to provide selected confidential information to certain other recipients, (viii) the right to modifications to an investor’s subscription agreement, (ix) arrangements with respect to waivers of certain obligations, and (x) agreements by a general partner (or similar governing body) to refrain from exercising certain remedies or taking certain actions against an investor (including in connection with a default by such investor). Such rights can be, and have been, granted on the basis of (i) the size, nature, timing or other features of the investor’s investment in, or commitment made to, a Fund, (ii) the type, category, nature, specificity or other features of the investor, (iii) the involvement or participation in Fund’s, Atlas’s or the applicable general partner’s management or activities (whether past, present and/or future; in each case only to the extent permitted under applicable laws), or (iv) any other criteria, element or feature as may be determined from time to time by, and in the discretion of, Atlas or the applicable general partner, to extent that such is not inconsistent with applicable laws and regulations.

Certain investors are granted “most favored nation” rights (an “MFN”) in their side letter, which gives such investors the right to review and/or elect the benefit of certain side letter rights granted to other investors that have made the same or smaller commitments to the Fund. However, certain provisions will not be subject to disclosure or election, in all cases in accordance with the terms of the MFN. Atlas will make certain decisions regarding how to implement the MFN, including what information to redact when side letters are shared, whether an investment policy or practice is unique to a limited partner (and therefore not disclosable or electable) and whether certain affiliated, related or commonly advised investor commitments should be aggregated for purposes of the MFN. Further, the terms agreed with certain investors, including investors that are affiliated with or managed by Atlas, will be carved out in accordance with the terms of the MFN. Certain investors may engage investment consultants to evaluate a potential investment by such investors in a Fund and/or monitor such investment on an ongoing basis. Such Fund could have an incentive to agree to provide additional information to such investment consultants, offer fee breaks to clients advised by such investment consultant (including by aggregating such investors for purposes of the MFN) or provide other benefits because such investment consultants may refer additional investors to the Funds. Strategic Investors: Atlas has entered, and may continue to enter, into strategic partnerships directly or indirectly with investors, including investors that (i) commit significant capital to a range of products and investment ideas sponsored by Atlas, (ii) provide services to Atlas, its affiliates or portfolio companies in which Funds invest or (iii) early stage seed investors. Such arrangements include, and may in the future, include Atlas granting certain preferential terms to such investors, including blended advisory fee rates that are lower than those applicable to other investors that invest in one or more of the same products. Such preferential terms are generally not subject to the MFN provisions of the Governing Documents of a particular Fund and may be implemented through the use of a managed account or similar vehicle that invests in or alongside such Fund. Investors may not be able to elect to benefit from such arrangements due to the fact that the strategic partnerships are likely to be developed on a case-by-case basis to accommodate particular investor requests and investment mandates. Purchase or Transfer of LP Interests: Purchase of limited partnership interests in any Fund should be considered a long-term investment. Subject to the terms set forth in each Fund’s Governing Documents, Limited Partners generally may not sell, redeem or transfer their interests in a Fund without the consent of the General Partner. Each Fund is not obligated to, nor does it intend to, register the interests or create any form of secondary market in order to permit the resale or transfer thereof by Limited Partners. Because of these restrictions and the absence of a secondary market for the interests, Limited Partners may be unable to liquidate their investments even though financial circumstances would make liquidation advisable or desirable. To the extent that the General Partner or Adviser has discretion over approving a transfer of interests in a Fund or is asked to identify potential purchasers in a transfer, the General Partner or Adviser will do so in its discretion, and is permitted to take into account a variety of factors, including but not limited to its own interests including: the financial resources of the potential purchaser, including its ability to meet capital commitment obligations; past experiences and relationships with the potential purchaser, including its belief that the potential purchaser would

help establish, recognize, strengthen and/or cultivate relationships that may provide indirectly longer-term benefits to current or future funds and/or Atlas and the expected amount of negotiations required in connection with a potential purchaser’s investment; whether the potential purchaser would subject Atlas, the applicable Fund, or their affiliates to legal, regulatory, reporting, public relations, media or other burdens; requirements in such Fund’s organizational documents; a potential purchaser’s investment into another Fund (including any commitment to a future fund or a co-investment); and such other facts as it deems appropriate under the circumstances in exercising such discretion. Valuation of Investments and Changing Accounting Standards: Investments will be valued in accordance with the applicable Governing Documents. Generally, Atlas will determine the value of Client investments for which market quotations are available based on publicly available quotations. However, market quotations will generally not be available for all Clients’ investments because, among other things, the securities of portfolio companies held by the Clients generally will be illiquid and not quoted on any exchange and the valuation of certain Clients’ assets are subjective, based on various assumptions and inherently imprecise. Atlas will determine the value of all Clients’ investments based on generally accepted accounting principles as promulgated in the U.S. and in accordance with the relevant Governing Documents. There can be no assurance that Atlas will have all the information necessary to make valuation decisions in respect of these investments, or that any information provided by third parties on which such decisions are based will be correct. There can be no assurance that the valuation decision of Atlas with respect to an investment will represent the value realized by the relevant Client on the eventual disposition of such investment or that would, in fact, be realized upon an immediate disposition of such investment on the date of its valuation. Accordingly, the valuation decisions made by Atlas may cause it to ineffectively manage the relevant Client’s investment portfolios and risks, and may also affect the diversification and management of such Client’s portfolio of investments. Regulatory Developments Relating to Investment Advisers and Private Funds: Legal, tax and regulatory changes, as well as judicial decisions, could adversely affect Atlas and its Clients, particularly those Clients that are private funds. In particular, the regulatory environment relevant to private investment funds is evolving and may entail increased regulatory involvement in Atlas’s business or result in ambiguity or conflict among legal or regulatory schemes applicable to Atlas’s business, all of which could adversely affect the investment strategies pursued or the value of investments held by a Client. In recent years, the SEC and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) voted to adopt new rules and amendments including new rules and amendments regarding Anti-Money Laundering/Countering the Financing of Terrorism, Beneficial Ownership under the Corporate Transparency Act, Dealer Registration, Conflicts of Interest in Securitizations, Regulation S-P, Form PF, and Short Position and Short Activity Reporting (some of which are in flux). These rules and amendments are likely to have a significant effect on Atlas, the Funds and their operations, including increasing compliance burdens and associated regulatory costs and enhancing the risk of regulatory action, including public regulatory sanctions and may result in a change to Atlas’s practices and create additional regulatory uncertainty. These rules and amendments could increase the risk of exposure of the Fund, its investments and Atlas to additional regulatory scrutiny, litigation, censure and penalties for noncompliance or perceived non-compliance, which in turn would be expected to be adversely

(potentially materially) affect the reputation of Atlas and its clients (including the Funds), and to negatively impact Atlas in conducting its business (thereby materially reducing returns to investors). The cost of implementing the rules could be substantial and may, to the extent permitted by the relevant governing documents and applicable regulations, be borne by Atlas, the Funds, and/or portfolio investments of the Funds. Regulation and Litigation: The growth of the private equity industry, and the increasing size and reach of transactions, as well as the increasing attention to private funds, has prompted additional governmental and public attention to the private equity industry and its practices. Regulation generally, as well as regulation more specifically addressed to the private equity industry, including tax laws and regulation, whether in the United States or abroad, could increase the cost of acquiring, holding, or divesting portfolio companies, the profitability of enterprises, and the cost of operating the investors. Additional regulation could also increase the risk of third-party litigation. The transactional nature of the business of the investors exposes the investors and Atlas generally to the risks of third-party litigation. Under the Funds’ governing documents, the Funds will generally be responsible for indemnifying Atlas and related parties for costs incurred with respect to such litigation not covered by insurance, subject to certain limitations. SEC Regulation: Changes in law or regulations could adversely affect the value of investments held (directly or indirectly) by the Funds, affect the ability of the Funds to pursue their respective investment strategies, restrict Atlas’s ability to operate as it has in the past, and increase the amount of fees or expenses borne by the Funds and the limited partners of the Funds indirectly. The time and attention as well as the financial costs associated with compliance with any proposed or adopted changes in law or regulations could divert Atlas’s resources away from managing the investment programs of the Funds, which could adversely affect both the Funds and their portfolio companies. Similarly, the cost of any new compliance obligations attributable to the Funds are expected to increase the financial burden on the Funds. Pay-to-Play Laws, Regulations and Policies: A number of states and public pension plans have adopted “pay-to-play” laws, regulations or policies which prohibit, restrict or require disclosure of payments and certain contacts with state officials by individuals and entities seeking to do business with state entities, including investments by or advising public retirement funds. The SEC also has adopted rules that, among other things, prohibit an investment adviser from providing advisory services for compensation to a government plan investor for two years after a contribution is made by the adviser or certain of its executives or employees to certain elected officials or candidates. If Atlas or its employees or certain personnel fail to comply with pay-to-play rules, whether or not such non-compliance is intentional, any such non-compliance could have an adverse effect on a Funds by, for example, providing the basis for the withdrawal of the affected government plan investor and could be the basis for a violation of an applicable regulation. Enhanced Scrutiny and Certain Effects of Potential Regulatory Changes: Certain media, regulatory and political discourse has been and continues to be focused on enhancing governmental scrutiny of and/or increasing regulation of the private fund industry. There can be no assurance that any such scrutiny or regulation will not have an adverse impact on Atlas and the activities of the Funds, including the ability to effectively and timely address such regulations, implement

operating improvements or otherwise execute its investment strategy or achieve its investment objectives. Atlas and the Funds may be required to incur additional costs and expenses in implementing structural changes in the conduct of Atlas’s business, including establishing greater substance in certain jurisdictions in which the Funds invest. The combination of such scrutiny of alternative asset managers and their investments by various politicians, regulators and market commentators, and the public perception that certain alternative asset managers (including private fund investment firms) contributed to prior downturns and/or volatility in the U.S. may negatively impact Atlas’s efforts to structure, consummate and/or exit investments, both in general and relative to competitors outside of the alternative asset space. As a result, the Funds may make fewer investments, incur greater expenses or delays in completing or exiting investments and/or realize lower proceeds on the disposition of investments than it otherwise would have. Many regulators, including governmental agencies and self-regulatory organizations, are empowered to conduct investigations and administrative proceedings that can result in fines, suspensions of personnel or other sanctions, including censure, the issuance of cease and desist orders or the suspension or expulsion of applicable licenses or members. Even if an investigation or proceeding did not result in a sanction against a Fund, the General Partner, Atlas or their respective affiliates, or if a resulting sanction were small in monetary amount, the adverse publicity relating to the investigation, proceeding or imposition of these sanctions could harm the reputation of such Fund, the General Partner, Atlas or their respective affiliates, which could adversely affect the Fund’s ability to obtain favorable financing or consummate potentially profitable investments. Additional global legislative and regulatory action is possible. Such risks are often difficult or impossible to predict, avoid or mitigate in advance. Additional regulation could also increase the risk of third-party litigation. It is anticipated that, in the normal course of business, Atlas will have contact with regulators and governmental authorities and/or could be subjected to responding to inquiries or examinations. Additionally, the SEC has enacted, and potentially will enact in the future, changes to areas of law and regulations that would impact Atlas’s business. Any new regulations, including any proposed regulation regarding investor privacy and anti-money laundering, are expected to increase the expenses of Atlas and the Funds and in particular may result in increased expenses associated with the Fund’s activities and additional resources of Atlas being devoted to such regulatory reporting and compliance-related obligations. Increased reporting, registration and compliance requirements may divert the attention of personnel of Atlas and may furthermore place the Fund at a competitive disadvantage to the extent that Atlas is required to disclose sensitive business information. Significant time and resources may be required to comply with new regulations, which potentially will detract from the time and resources dedicated to the Funds.

Thus, the General Partners, all of their employees and the persons acting on their behalf would be “persons associated with” the registered investment adviser so that the SEC could enforce the requirements of the Advisers Act on the General Partners. One SPAC that is incorporated as a Delaware corporation and formed for the purpose of effecting a merger, share exchange, asset acquisition, share repurchase, reorganization or similar business combination with one or more businesses (the “SPAC”) is sponsored by an entity affiliated with Atlas. The SPAC’s sponsors and management include certain of Atlas’s employees who stand to benefit from their direct and/or indirect ownership in the SPAC. The SPAC is currently in the process of closing a business combination with a non financial services company therefore eliminating any potential conflict of interest with the current and any future PE Funds. Rorschach I LLC, a Delaware LLC, was formed for the purpose of effecting a merger and share exchange with an existing publicly traded company. On December 3, 2025, Rorschach I LLC merged with Sonnet BioTherapeutics Holdings, Inc. and was renamed Hyperliquid Strategies Inc. (“Hype”). Hype’s adviser Rorschach Advisers LLC, its Chief Executive Office and Chairman of the Board of Directors include certain of Atlas’s employees who stand to benefit from their roles and direct and/or indirect ownership in Hype. Any compensation received by the Principals or any Atlas employees for serving as directors or officers of Hype are not Transaction Fees. The Principals and Atlas employees may serve as directors and officers of, and provide advice to, publicly traded companies and private companies. Investors should be aware that receipt of material non-public information by such persons regarding these companies could preclude Atlas from effecting transactions in the securities of such companies. Compensation for directorships with portfolio companies of the Funds are Transaction Fees, as discussed under “Fees and Compensation” above. Any compensation received by the Principals or any Atlas employees for serving as directors or officers of the SPAC are not Transaction Fees. Certain of the related persons of Atlas may have personal investments in companies. The Funds are generally not prohibited from acquiring or otherwise engaging in transactions with companies in which affiliates of Atlas have a pre-existing financial interest. It is also possible that Atlas may occasionally utilize the services of entities that have, directly or indirectly, or whose affiliates have, investments in the Funds. Such services will only be used on an arm’s length basis and when they are in the best interest of the Funds. To the extent that conflicts arise, they will be resolved pursuant to Atlas’s policies and procedures and the Governing Fund Documents.

Atlas and its employees will devote such time as shall be necessary to conduct the business affairs of the Clients in an appropriate manner. However, the Firm’s employees may work on other projects, including being employed by other business entities, and therefore, conflicts may arise in the allocation of personnel. Any such conflicts will be managed in accordance with the Clients’ governing documents.

In addition, the Code sets forth formal policies and procedures with respect to the personal securities trading activities of Atlas’s employees. The Code prohibits personal securities transactions of issuers who have been placed on the Firm’s restricted list, and requires written pre-approval for all initialpublic offerings, private placements, and transactions in “Reportable Securities”. The Code requires employees to report all securities transactions and provide a summary of securities holdings initially upon hire and on an annual basis thereafter. The Code also addresses outside activities of employees, conflicts of interest, policies and procedures concerning the prevention of insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and the pre-clearance and reporting of political contributions. Atlas will provide a complete copy of the Code to any investor or prospective investor upon request sent to the CCO. Atlas and certain of its affiliated parties and employees will make commitments to the Funds. As such, Atlas and certain of its affiliated parties and employees will have a direct financial interest in the transactions of each of the Funds. While investments by such related parties are intended to align the interests of Atlas and the related parties with those of the Funds, such investments may create conflicts of interest. To address such conflicts, the investment arrangements are described and agreed upon in the Governing Fund Documents of each Fund. Generally, investments and dispositions are made on the same terms for all Fund investors, including Atlas and its related parties, and each investment is made pro rata among the investors of each Fund, including Atlas’s related parties who are investors, so that Atlas and its related parties may not receive more favorable terms or greater exposure to select investments. Allocation of Investment Opportunities: Atlas expects that the universe of potential investments and other activities of Atlas’s business could overlap with the investments and activities of the Funds and, as a result, may create conflicts of interest. Atlas will allocate investment opportunities among its Clients pursuant to its allocation policy and the Governing Fund Documents. With respect to any investment opportunity falling within the investment mandate of both a Fund and a SPAC affiliated with the Firm, such opportunity will be allocated to the Fund first.

Restrictions on Transactions Due to Other Atlas Businesses: From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of Atlas and its personnel. Atlas will endeavor to resolve conflicts of interest with respect to investment opportunities in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Atlas may invest, on its own behalf, in securities and other instruments that would be appropriate for, held by, or may fall within the investment guidelines of a Client. Atlas may give advice or take action for its own account that may differ from, conflict with, or be adverse to, advice given or action taken for Clients. Potential conflicts of interest also may arise due to the fact that certain of Atlas’s executives may have investments in some Clients but not in others, or may have different levels of investment in the various Clients, and that the Clients may bear different levels of fees and incentive compensation in favor of Atlas. Atlas, together with its Clients, engages in a broad range of business activities and invests in portfolio companies whose operations may be substantially similar to and/or competitive with the portfolio companies in which the Clients have invested. The performance and operation of such competing businesses could conflict with and adversely affect the performance and operation of a Client’s portfolio companies, and may adversely affect the prices and availability of business opportunities or transactions available to such portfolio companies. Atlas will seek to resolve conflicts in a manner that Atlas determines to be fair and equitable and in accordance with its written allocation policy. Atlas may also have ongoing relationships with issuers whose securities have been acquired by, or are being considered for investment by, its Clients. No Client will be prohibited from acquiring, or otherwise engaging in transactions with respect to, securities of an entity in which another Client has a financial interest (whether in the same or a different class of securities) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities of such entity, including following a coinvestment. The conflicts in any such transaction will be addressed pursuant to the Code and the applicable Governing Fund Documents. Allocation of Expenses: The General Partners, Atlas, the Principals and/or one or more of their respective affiliates may from time to time incur expenses on behalf of the Funds, other affiliated entities and one or more existing or subsequent entities established by the Principals. Although attempts will be made to allocate such expenses on an equitable basis, there can be no assurance that such expenses will in all cases be allocated appropriately. Material Non-Public Information; Information Barriers: Atlas generally operates without ethical screens or information barriers that other investment management firms implement to separate persons who make investment decisions from others who might possess material non-public information that could influence such decisions. In the event that employees of Atlas obtain such material non-public information, Atlas may be restricted in acquiring or disposing of investments on behalf of the Clients, which could impact the returns generated for the Clients. In addition, Atlas’s investment professionals or other employees may acquire, in their capacities as investment professionals or otherwise of one or more Clients (including the Fund), non-public

information regarding investment opportunities, business methodologies, strategies and other proprietary information In such instances, Atlas endeavors to maintain ethical screens and/or information barriers in order to limit use of such information for other portfolio companies or other Clients. Although Atlas will endeavor to ensure that such information sharing and use does not prejudice one or more such other Clients, there can be no assurance that such endeavors will be sufficient or successful. Management Team: Atlas and its personnel may have conflicts of interest in allocating their time and services among Clients. Although the Principals intend to be actively involved in the management of each Client, Atlas’s personnel (including the Principals) will work on other projects, including other Clients and Atlas’s other existing and potential business activities. For example, in addition to providing advisory services to the Funds, Atlas provides non-advisory services to other entities in which certain Atlas Principals have invested. In addition, Atlas’s personnel will concurrently participate in the management of the investment activities of Atlas and the other Clients. Conflicts of interest may arise because Atlas employees will serve as directors of certain of the portfolio companies. In those instances where a Client is not the sole shareholder of the applicable portfolio company, in addition to any fiduciary duties Atlas employees owe to the Client, as directors of portfolio companies, such employees owe fiduciary duties to the shareholders of the portfolio companies. Management Fee / Carried Interest Related Conflicts: The Management Fee payable by each Fund to Atlas and the carried interest that Atlas or its affiliates will receive, each as set forth under the Governing Fund Documents, have not been established on the basis of an arm’s-length negotiation and may affect the determinations of Atlas and its affiliates in various ways. The Management Fee may incentivize Atlas to cause a Fund to continue to hold an investment longer than it may have in the absence of the Management Fee. The existence of the performance-based carried interest with respect to the Funds may create an incentive for Atlas to (i) make riskier or more speculative investments on behalf of the Funds than it might otherwise make in the absence of such performance-based compensation and (ii) dispose of a Fund’s investments at a time and in a sequence that would generate the most carried interest. In addition, the terms of the carried interest distribution in favor of the General Partners could incentivize Atlas, as an affiliate of the General Partners, to make decisions regarding the timing and structure of realization transactions that may not be in the best interests of investors. The right to receive carried interest distributions also creates a potential conflict of interest in the valuation of investments. Atlas has prepared accounting guidelines regarding the recognition of asset impairment and has also adopted written valuation policies and procedures intended to address conflicts of interests that arise in respect of the valuation of the Funds’ assets. In general, following the investment period defined in the applicable Governing Fund Documents, the Management Fee will be based upon the cost basis of portfolio investments that have not been the subject of a disposition, write-off or a permanent write-down, and will be payable in advance, irrespective of any disposition, write-off or write-down during such applicable period. Depending

on the circumstances, Atlas may be afforded substantial discretion in determining whether or not the value of a particular portfolio investment should be permanently written down or written off. As a result, Atlas has an incentive to (i) make more speculative investments prior to the end of such investment period and/or any Management Fee payment date, (ii) hold investments, or retain and not distribute proceeds longer, or (iii) postpone the decision to dispose of, write off or permanently write down the value of an investment, in each case than it otherwise would have if the Management Fee were solely based on capital commitments. Atlas and its personnel’s capital commitments to a Fund should tend to reduce this incentive. The due date in the funding notice to the limited partners for the payment of the Management Fees may be on a date later than the Management Fee payment date for the applicable period, at which time one or more portfolio investments for which the Management Fee will be payable may have already been disposed of, written off and/or written down. In addition, under the Governing Fund Documents, Atlas is afforded discretion to determine the timing and nature of certain transactions and characterize the proceeds received in respect thereof, and will at times have a conflict of interest in making such determinations. By way of example, in the event of a partial disposition of a portfolio investment, Atlas has the ability to determine, in an equitable manner, the portion of the investment that has been disposed of and the capital contributions investors that are attributable to such portion. Atlas may have an incentive to make these allocations in a way that benefits Atlas’s ability to receive, or that increases the amount of, carried interest. In addition, at certain times and in certain circumstances involving transactions that do not entail the disposition of shares or other securities relating to a portfolio investment, such as certain recapitalizations, extraordinary dividends or similar events, Atlas may elect to treat all or any portion of the proceeds of such transactions as a return of capital (and potentially receive carried interest on such amounts) while not reducing the amount of actively invested capital upon which the Management Fee is calculated. Other Fees Paid to Atlas: The General Partners, Atlas, certain of their partners and employees and their affiliates are permitted to receive Transaction Fees in connection with actual or contemplated investments in portfolio companies. Fund investors will receive the benefit of the portion of such fees allocated to their Fund only, as described above under “Fees and Compensation.” Although a percentage of any Transaction Fees may be applied to reduce the Management Fee payable by the investors in the Funds, the investors may not receive the benefit of all of such fees, and conflicts of interest may arise in connection with the payment of such fees. Personal Relationships: Personnel of Atlas can be expected to have friendships or other personal relationships with personnel and other individuals associated with entities with which Atlas does or may seek to do business, including individuals who serve as directors, principals or employees of investors, Clients, and existing and prospective portfolio investments, as well as service providers to the foregoing. Personal relationships may develop out of business-related or other professional interactions, or vice versa. The existence of personal relationships may serve to benefit Clients (for example, by providing networking opportunities through which Adviser personnel could be introduced to potential service providers for Clients) but also create a potential conflict of interest, by giving rise to incentives for the parties to share business or other professional opportunities, including those relating to the business of Atlas, investors, Clients and portfolio companies, in order to enhance or otherwise further their personal relationship, or vice

versa, even when doing so may not be in the best interest of the Client. Atlas expects conflicts of interest of this nature generally to be mitigated by Atlas’s Code of Ethics, which generally requires supervised persons of Atlas to act in the best interest of Clients, without regard to an individual’s own interest, it is unlikely that the potential for conflicts of interest relating to personal relationships can be fully mitigated. Gifts and Entertainment: Atlas maintains a policy regarding the giving and receiving of gifts and entertainment. This policy generally permits employees to give and receive gifts and entertainment, so long as such items are not lavish or excessive, and do not give the appearance of being designed to influence the recipient. In general, employees are required, where possible, to obtain approval from Atlas’s Chief Compliance Officer prior to giving or receiving gifts or entertainment having a value in excess of $500, but are not required to report or obtain approval for gifts or entertainment valued at $500 or less. From time to time, Atlas personnel have, and in the future can be expected to, accept gifts or entertainment from service providers to the Funds and/or portfolio companies of the Funds, including items that (individually or in the aggregate) have a value in excess of $500. This creates a conflict of interest, because the receipt of such gifts or entertainment, and/or the prospect of receiving future gifts or entertainment, can incentivize employees to direct business to such service providers on a basis other than the cost and quality of the services offered, even in situations where Atlas does not consider such items to be lavish or excessive or designed to influence the recipient.

The following discussion applies to the PE Funds and the Regional Depository Fund in the circumstances where Atlas purchases or sells public securities as part of a transaction or has such securities as a result of a portfolio company going public. Factors Considered in Selecting Broker-Dealers Accordingly, the prices and commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Funds by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Atlas need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Atlas nor the Funds separately compensate any broker or dealer for any of these other services. Best Execution In selecting an appropriate broker-dealer to effect a client trade, Atlas seeks to obtain best execution, taking into consideration the price of a security offered by the broker-dealer, as well as a broker-dealer’s full range and quality of services including, among other things, its facilities,

reliability and financial responsibility, execution capability, commission rates, responsiveness to Atlas, brokerage and research services provided to Atlas (e.g., research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. If Atlas decides, based on the factors set forth above, to execute transactions on an agency basis through Electronic Communications Networks (“ECNs”), it will also consider the following factors when choosing to use one ECN over another: the ease of use, the flexibility of the ECN compared to other ECNs, and the level of care and attention that will be given to smaller orders. Atlas maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Research and Other Soft Dollar Benefits From time to time, Atlas receives advice and research reports from broker-dealers who may execute portfolio transactions. This research may be used to service one or more of Atlas’s Clients. Research or brokerage services may include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities or other instruments, online quotations, news and research services, access to an electronic communication network for order entry and account information, participation in broker-dealer sponsored research conferences and other services providing lawful and appropriate assistance to Atlas in the performance of its investment decision-making responsibilities on behalf of its Clients. If a particular broker-dealer’s research contributed to the investment research process, transactions may be directed to such broker-dealer, assuming such broker-dealer meets the aforementioned criteria. Atlas does not formally commit to provide any particular level of commissions (or markups or markdowns) to broker-dealers who provide research services. Atlas understands that the benefits received through its relationship with broker-dealers generally do not depend upon the amount of transactions directed to, or the amount of assets custodied by, such broker-dealers. Receipt of such research or other products or services may create an incentive for Atlas to select or direct more business to particular broker-dealers. However, Atlas will execute trades in accordance with the best execution principles outlined above. Atlas may also pay certain brokerdealers for research services provided, including in connection with compliance with the Markets in Financial Instruments Directive II in Europe. Aggregation of Orders Please see Item 6 for a discussion of Atlas’s practice concerning the aggregation of Client orders. Trade Errors On occasion, trade errors may occur with respect to trades executed, directly or indirectly, on behalf of one or more Clients. The General Partner, Atlas and their respective affiliates and directors, partners, members, shareholders, officers, employees, agents and any other person who serves at the request of the General Partner on behalf of a Client as a director, partner, member, officer, employee, agent or agent of any other entity (in each case, an “Indemnitee”), will typically not be liable to such Client or to its investors for (i) any act taken or omitted to be taken in good faith and in a manner reasonably believed to be in, or not opposed to, the best interests of the Client, any issuer, any subsidiary of an issuer, any alternative investment vehicle or any special

purpose investment vehicle, including any negligent act performed or omission made by it, in the absence of the Indemnitee’s fraud, gross negligence (as interpreted pursuant to the laws of the State of New York) or willful misconduct, or (ii) losses due to the negligence of brokers or other agents of the Client. Even though such exculpation and indemnifications do not constitute a waiver of any non-waivable Advisers Act fiduciary duties of the Indemnitees, subject to the Governing Fund Documents of a Client, this standard of care will result in a Client bearing the costs of any trade errors committed by an Indemnitee, so long as the errors do not evidence fraud, gross negligence or willful misconduct. From time to time, Atlas or its affiliates may voluntarily reimburse a Client for losses suffered as a result of a trade error. However, notwithstanding the previous sentence, investors should not carry the expectation that a reimbursement will ever take place, and in evaluating the Funds, no decisions should be made in reliance on Atlas making any reimbursements to the Funds for losses suffered as a result of such trade errors. Any decision to reimburse is not precedential and should not create the expectation of any reimbursement in the future. Examples of trade errors that may be committed by investment advisers include executing a purchase instead of a sale (or vice versa), marking a short sale as a long sale, purchasing or selling a security or other instrument in the incorrect amount, or purchasing or selling the wrong security or other instrument.

Atlas maintains a strong focus on the ongoing monitoring of industry dynamics and companies across all sectors of the financial services industry, and will develop customized operating metrics for each of its private equity investments. Atlas sends all Fund investors: (i) audited financial statements within 120 days of the end of each fiscal year of the Funds; (ii) where applicable, unaudited financial statements and other information on a quarterly basis; and (iii) tax information related to the Funds necessary for the completion of any applicable federal tax returns.

Atlas’s CFO is responsible for arranging for annual audits of the Funds by an independent auditor that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board within 120 days of the Funds’ fiscal year end and for obtaining audited financial statements prepared in accordance with GAAP. Atlas will arrange for the delivery of such audited financial statements to investors of the Clients within 120 days of the Funds’ fiscal year end.

Atlas and the General Partners of, and investors in, the Funds are authorized, without the approval of any investor, to enter into side letters or similar written agreements with investors that have the effect of establishing rights under, or altering or supplementing the terms of, the Governing Fund Documents of the applicable Fund with respect to such investor, without entitling any other investor of such Fund to such waiver, modification or new rights. Rights that may be established and terms that may be altered or supplemented include, without limitation, rights and terms relating to greater portfolio transparency, fee waivers or reductions, minimum investment amounts, reports and other information, confidentiality, timing of funding, expenses, distributions, legal or regulatory requirements (e.g., tax and ERISA), advisory committee membership, as applicable, and other more favorable investment terms such as withdrawal rights. To the extent that compliance with any of the provisions of any side letters or similar written agreements would cause Atlas and/or its affiliates to violate their respective fiduciary duties or obligations or to violate any applicable laws, any non-compliance with any such provision will not be deemed to be a breach of such written agreements. Similarly, strategic investors of Atlas may receive certain preferential information and rights not available to other investors in the Funds.

The Proxy Voting Policy generally provides that Atlas or the applicable General Partner will vote proxy proposals, amendments, consents or resolutions relating to securities, including interests in pooled investment vehicles, if any (collectively, “Proxies”), in a manner that serves the best interests of the Clients, as determined by Atlas in its discretion, taking into account the following factors: (i) the impact on the value of the investments; (ii) the views of management; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. In addition, Atlas may not vote Proxies in certain situations where the associated costs outweigh the anticipated benefits to Clients. If a material conflict of interest exists between the interests of Atlas and those of the relevant Client with respect to any issue to be voted on, Atlas will base its voting decision exclusively on Atlas’s judgment of what will best serve the financial interests of the Client that beneficially owns the securities that are the subject of the vote. Investors may obtain a copy of the proxy voting record for a given Client, or a copy of the Proxy Voting Policy, by contacting the Firm’s CCO.