Maple Rock Capital Partners Inc.: investment adviser

The Funds are currently organized as a master-feeder structure with each of Maple Rock US Fund LP, a Delaware limited partnership (the “Onshore Fund”); and Maple Rock Offshore Fund LP, a Cayman Islands limited partnership (the “Offshore Fund” and together with the Onshore Fund, the “Feeder Funds”); investing substantially all of their assets in Maple Rock Master Fund LP, a Cayman Islands limited partnership (the “Master Fund”). Each Fund is governed by a limited partnership agreement or similar governing document (each, a “Fund Agreement”) that specifies the investment guidelines and investment restrictions applicable to the Fund. In addition, investors in each Fund (“Investors”) are provided with a confidential offering memorandum prior to their investment, which contains information regarding the intended investment program for such Fund. Affiliates of the Investment Manager serve as the general partners of the Funds (the “General Partners”). The General Partners are under common control with, and are related persons of, the Investment Manager. The General Partners retain management authority over the business and affairs of the Funds but have delegated the responsibility of managing the Master Fund’s investment portfolio to the Investment Manager. This Brochure sometimes refers to the General Partners and the Investment Manager, together with their management affiliates, as “Maple Rock.” In the future, Maple Rock may provide investment advisory services to additional private funds, including feeder funds to the Master Fund. Maple Rock pursues a value-oriented and opportunistic strategy focused on compounding capital at high rates of return with lower volatility and risk to principal than usually associated with equity markets. Please see Item 8 of this Brochure for a more detailed description of Maple Rock’s investment strategy, methods of analysis, and the types of securities Maple Rock will generally invest in and the material risks of loss. The Investment Manager has full discretionary authority to manage the Funds. Among other things, this means that the Investment Manager is authorized to make purchase and sale decisions for the Funds. The Investment Manager has wide latitude in choosing investments and trading activities. Although the Investment Manager intends to pursue the strategy and processes described in the Fund Agreements, such agreements do not expressly require it to do so. The Fund Agreements specify certain investment limitations that are intended to limit the Funds’ risk exposure.

Maple Rock does not tailor its advisory services to the individual needs of Investors and does not accept Investor-imposed investment restrictions on the Master Fund. Notwithstanding the above, Maple Rock and/or the Funds could enter into side letter agreements (“Side Letters”) that provide some Investors with additional and/or different substantive rights or terms than those described in the Funds’ confidential offering memorandum. Maple Rock has not and will not enter into Side Letters that provide Limited Partners with different management fees, incentive fees or allocations, liquidity, and/or transparency terms than those described in the Funds’ confidential offering memorandum. Maple Rock will provide letters to Investors that confirm its existing policies. As of December 31, 2025, the Investment Manager had approximately $6,340,993,380 of client regulatory assets under management, all of which is managed on a discretionary basis.

Generally, Maple Rock deducts the Management Fee and Incentive Allocation directly from the Master Fund. Employees of Maple Rock are not subject to the Management Fee or Incentive Allocation. The General Partners of the Funds and/or the Governance Committee have waived or reduced the Management Fee or Incentive Allocation paid as to particular Investors. Management Fees are payable quarterly in advance. If an Investor is required or otherwise permitted to redeem or withdraw from a Fund during the middle of a quarter, the Investor may be eligible for a refund of any Management Fees paid in advance for that quarter under certain circumstances, as further specified in the Fund Agreements. Expenses Expenses and fees are generally paid by the Master Fund or the Feeder Funds directly, or the Investment Manager advances costs and is reimbursed by the Funds. The Master Fund will generally allocate the economic effects of its activities between the Feeder Funds in proportion to the Feeder Funds’ ownership interests, but it will specially allocate certain expenses differently to reflect the proportions in which the Feeder Funds would bear them if the Feeder Funds had incurred and paid them directly, as specified in the Fund Agreements. The Investment Manager’s decision to bear any expenses out of its own assets or revenues as to some expenses or for some periods will not obligate it to do so as to any other expenses or to continue doing so for any other periods. Each of the Feeder Funds will generally bear its ongoing operating costs, as well as its share of the Master Fund’s operating costs, either directly or by reimbursing Maple Rock. The Funds’ operating costs include but are not limited to: •

brokerage commissions and other transaction-related compensation and charges arising out of transactions involving Fund assets, including outsourced trading costs;

•

interest and borrowing charges on securities sold short and margin and other borrowings;

•

custodial and bank service fees;

•

auditing, accounting, third-party administration (including the administrator’s), bookkeeping, tax preparation and reporting, third-party legal, and other professional fees and costs (including fees and costs paid to Maple Rock’s counsel for services relating to the Funds’ legal affairs);

•

fees and costs in connection with any lawsuits, arbitrations, or other controversies and in connection with, among other things, the Funds’ indemnification obligations owed to Maple Rock and its affiliates;

•

costs of the Funds’ and its affiliates’ (other than the Investment Manager’s) registration and filings with and licensing by governmental and self-regulatory organizations and costs associated with regulatory and other filing and reporting requirements by the Master Fund and/or the Feeder Funds;

•

transfer, withholding, income, stamp, and other taxes and duties (which may, in certain circumstances, be specially charged by the Funds to one or more Investors);

•

costs of reporting to Investors and of Fund meetings and other governance activities;

•

fees of the Governance Committee Members (“GC Members”) that are not affiliated with Maple Rock, reimbursable expenses of GC Members, and the cost of D&O, E&O and possibly other types of insurance attributable to the GC Members;

•

costs directly related to acquiring, holding, and/or monitoring and administering Master Fund investments, including research-related expenses, reasonable travel expenditures that are solely investment-related, costs of third-party investigative services and costs of membership on creditors’ or equity-holders’ committees (both formal and informal) and participating in deliberations and negotiations regarding Master Fund investments; and

•

all other costs related to the Fund’s operation or to the purchase, sale or transmittal of Fund assets, all in the Investment Manager’s discretion.

Please refer to Item 12 of this Brochure for a description of Maple Rock’s brokerage practices. It is critical that Investors refer to a Fund’s confidential offering memorandum and Fund Agreement for a complete understanding of how Maple Rock is compensated for its advisory services and the associated fees and expenses. The information contained in this Brochure is a summary only and is qualified in its entirety by those documents.

Generally, Investors in the Feeder Funds are subject to a minimum investment of $10,000,000, subject to waiver by the General Partner and/or Governance Committee, as the case may be (but not below Cayman Islands minimums in the case of the Offshore Fund). The General Partner and/or Governance Committee intends to waive most such requirements for Maple Rock, its affiliates, employees, and owners, and those affiliates’, employees’, and owners’ family members.

The Investment Manager has a disciplined investment process for investment ideas from sourcing, analyzing and decision making. Potential investment opportunities are prioritized based on Maple Rock’s history and experience of seeing similar opportunities, also known as pattern recognition. The Investment Manager sources ideas from internally and externally generated sources. The next step in the Investment Manager’s investment process is identification of the various investment traits that the Investment Manager has identified as typical drivers of superior risk-adjusted returns. The Investment Manager believes mispricings are typically driven by either fundamental (e.g. earnings) or technical causes (e.g. psychology) and both offer ample investment opportunities. When a mispricing is caused by an event where the outcome is “unknowable”, the Investment Manager believes it is critical to understand what probability the market is pricing into these types of situations and that the market tends to discard “unknowable” investment opportunities creating potential mispricings. Risk of Loss There can be no assurance that the Funds will achieve their investment objective. An investment in the Funds may be deemed speculative and is not intended as a complete investment program. Neither the Funds nor the Investment Manager can provide any assurance that the Funds will achieve their objectives over any particular period or at all, or that the Funds will not incur losses. Investments in the Funds are designed only for experienced and sophisticated persons who are able to bear the risk of substantial impairment or total loss of their investment. For a complete explanation of all relevant risks, Investors and potential Investors should review the applicable confidential offering memorandum, which discusses the factors below as well as other risk factors. GENERAL INVESTMENT RISKS Market Conditions and Disruptions; Interconnected Markets. Market disruptions could cause the Funds to incur major losses, particularly if they cause historical pricing relationships to become materially distorted or previously liquid positions to become illiquid. Market disruptions can result in otherwise historically low-risk strategies performing with unexpected volatility and risk. Changes in Investment Strategies. The Investment Manager has broad authority to expand, contract, or otherwise change the Funds’ activities without notice to, or the consent of, the Investors. Over time, the strategies the Funds implement can be expected to expand, evolve, and change, perhaps materially. Any change in strategies could expose the Funds’ capital to additional risks. Concentration of Investments. The Funds will not be as diversified as many other investment funds. While the Investment Manager intends to limit investments that could create excessive

concentration in a particular company or industry sector in accordance with the exposure limits described in the Fund Agreements, it is not required to do so. The Funds may at times have a relatively large portion of their capital exposed to a relatively small number of positions and/or a particular industry. Losses in one or more large positions, or a downturn in an industry in which the Funds are concentrated, could materially adversely affect the Funds’ performance and could have a materially adverse effect on the Funds’ overall financial condition. Information Sources. The Investment Manager relies heavily on the accuracy and completeness of information on which it bases investment decisions, but as to much of that information, it is not in a position to confirm that completeness or accuracy; critical, and apparently reliable, information may be inaccurate or incomplete. Reliance on erroneous or incomplete information could cause the Investment Manager to make investments that lead to losses in the Funds’ portfolio or to refrain from making investments that would have resulted in gains. Artificial Intelligence Engines and Machine Learning (collectively “AI”). AI is used as an umbrella term that encompasses a broad spectrum of different technologies and applications. While the Investment Manager intends to utilize AI in connection with its business activities, including investment activities, the Investment Manager continues to evaluate and adjust internal policies governing use of AI by its personnel. As part of its investment activities, Maple Rock uses AI to assist in gathering and analyzing general market data. AI and its applications continue to develop rapidly, and it is impossible to predict the future risks that may arise from such developments. Additionally, various governmental entities have been increasingly active in considering laws and/or market restrictions related to AI. The timing of the passage, and the ultimate effect of the implementation, of such laws and market restrictions is impossible to predict but the additional regulation may increase the costs associated with, and may limit the ability of the Investment Manager to implement, AI in connection with the management of the Funds, which could have an adverse impact on the Funds’ performance. Force Majeure. Portfolio investments 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, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, etc.). Some force majeure events may adversely affect the ability of a party (including a counterparty to an advisory client) to perform its obligations until it is able to remedy the force majeure event. These risks could, among other effects, adversely impact asset prices, valuations and cash flows, cause personal injury or loss of life, damage property, or instigate disruptions of service. Force majeure events that are incapable of or are too costly to cure may have a permanent adverse effect on an advisory client. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally, or in any of the countries in which the client funds would invest. Additionally, a major governmental intervention into industry, including the nationalization of an industry or the assertion of control over certain assets, could result in a loss to advisory clients, including if the investment in such assets is canceled, unwound or appropriated (which could be without adequate compensation).

RISKS ARISING FROM PARTICULAR ACTIVITIES OR TYPES OF SECURITIES All investment and trading activities risk the loss of capital. The following paragraphs describe some of the risks to which the Funds will, or may, be subject (either directly for the Master Fund or indirectly for the Feeder Funds). Investments Based on Valuation. The Funds will invest in securities the Investment Manager believes are undervalued and may sell short securities the Investment Manager believes are overvalued. Identifying investment opportunities of these kinds is a difficult task, and neither the Funds nor the Investment Manager can provide any assurance that the Investment Manager will succeed at it. While investments in undervalued securities offer opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses and short sales based on expectations that market participants will come to agree that a stock is overpriced can theoretically involve even higher risks. The Funds may be required to hold positions for a substantial period before market prices reflect the Investment Manager’s beliefs about their value. Returns generated from the Funds’ investments may not adequately compensate for the business and financial risks assumed. Equity Investments. The Funds’ equity investments may involve substantial risks and may be subject to wide and sudden fluctuations in market value, with a resulting fluctuation in the amount of profits and losses. Small and Medium Capitalization Stocks. The Funds may invest in stocks of companies with relatively small- or medium-sized market capitalizations. While the Investment Manager believes these stocks can provide significant potential for appreciation, they can involve higher risks than investments in stocks of larger companies. Timing of Gains and Losses; Volatility. The Funds may need to hold some of their positions for significant periods before their success or failure becomes apparent or any gains can be realized. It may take longer for successful positions to realize their potential than for unsuccessful ones to reveal their weaknesses. Market prices of portfolio positions may be expected to fluctuate significantly over the Funds’ holding periods, causing the Funds’ performance to be volatile over the short term. Limited Liquidity of Investments. Many of the Funds’ investments may be relatively illiquid. An investment may be illiquid because it is thinly traded or because the Funds’ position in it is large in relation to the overall market for the security. The Funds may own (or have a short position in) securities that are relatively liquid when acquired (or sold short) but that later become illiquid. The Funds may not be able to liquidate illiquid positions if the need were to arise; rapid sales of such securities could depress the market value of those securities, reducing the Funds’ profits, or increasing their losses, in the positions (and rapid purchases to cover short positions could have the corollary effect). In addition, the Funds may buy securities that are not immediately saleable in the public markets. Short Selling. The Funds may sell securities short as a regular part of their investing activities. In a short sale, the Funds sells securities it does not own, in the expectation that the market price will decline, and the Funds will be able to buy replacement securities later at a lower price. The Funds may experience losses on short positions that are not offset by gains on long positions.

Non‐Controlling Investments; Investments with Third Parties. The Funds may hold a noncontrolling interest in certain investments and, therefore, may have a limited ability to protect their position in such investment. The Funds may co-invest with third parties through consortiums of private equity investors, joint ventures or other similar arrangements. Distressed Investments. The Funds may invest in “distressed” securities – claims and obligations of issuers that are experiencing significant financial or business difficulties. Investments may include loans, loan participations, trade claims held by trade or other creditors, stocks, partnership interests and similar financial instruments, executory contracts, and options or participations therein not publicly traded. The Funds may lose a substantial portion or all of their investments in a distressed situation or may be required to accept cash or securities with a value less than their investments. Special Situations. The Funds expect that among their distressed securities investments will be investments in companies involved in or undergoing work-outs, liquidations, spin-offs, reorganizations, bankruptcies or other catalytic changes or similar transactions. As with other distressed company investments, The Funds could lose their entire investments in special situation investments. Debt Instruments. The Funds may invest significantly in debt or other fixed-income instruments, including bonds and debentures. Particular types of debt instruments are subject to various risks that are specific to the ways in which they are structured, the industries and markets in which their issuers participate, the assets underlying the instruments, the impact of applicable tax or regulatory factors, and numerous other specific factors. Convertible Securities, Rights and Warrants. The Funds may invest in hybrid securities that may be exchanged for, converted into, or exercised to acquire a predetermined number of shares of an issuer’s common stock at the option of the holder during a specified time period (such as convertible preferred stocks, convertible debentures, stock purchase rights, and warrants). Convertible securities generally pay interest or dividends and provide for participation in the appreciation of the underlying common stock but at a lower level of risk because the yield is higher, and the security is senior to common stock. Convertible debt securities purchased by the Fund that are acquired for their equity characteristics are not subject to minimum rating requirements. Active or Suggestive Investing. Particularly in connection with distressed investments, the Investment Manager may communicate with the issuer of a security in an attempt to influence the issuer’s decisions or strategies and enhance the value of the Funds’ investment. This could occur when the Funds and other Accounts, together, have or seek to take a position in an issuer’s securities that is material relative to other holders of the issuer’s outstanding securities. The Funds may be unable to exit their position at a favorable price. Hedging. The Investment Manager may use hedging strategies to the extent it considers appropriate in light of current circumstances and portfolio composition. Hedges are often imperfectly inversely correlated with the underlying exposure the Fund seeks to hedge and, to the extent that is the case, can subject the Fund to additional risk, if prices involved in the hedging position move against the Fund.

Portfolio Leverage. Leverage in the Funds’ portfolio could increase both the possibilities for profit and the risk of loss. If the Funds were to borrow to leverage their investments (margin borrowing), that borrowing would probably be secured by the Funds’ securities and other assets. Margin borrowings typically allow the lender to demand an increase in the collateral that secures the Funds’ obligations, and if the Funds were unable to provide additional collateral, the lender could liquidate the collateral to satisfy the Funds’ obligations. Forced liquidation could have extremely adverse consequences, including sales at disadvantageous times and prices and the acceleration of tax consequences. Risks of Investing in Non‐U.S. Securities. The Funds may invest and trade in securities of non-U.S. companies or governmental entities, and in securities, commodity interests, and derivative contracts and instruments denominated in currencies other than U.S. dollars, which can subject the Funds to risks not typically associated with investing in securities and commodity interests in the United States. Investments in non-U.S. securities, especially in those of developing economies, may present certain special risks, including: political or economic instability; the possibility of governmental actions such as expropriation, nationalization or confiscatory taxation; currency controls; withholding taxes on dividends, interest and gains; less robust bankruptcy laws and practice; fluctuating currency exchange rates and restrictive regulations. As compared to U.S. entities, some nonU.S. entities may generally disclose less financial and other information publicly, and may be subject to less stringent and less uniform accounting, auditing and financial reporting standards. Currencies and Foreign Exchange. The Funds may take positions in currencies, either directly or through the use of derivative instruments. The foreign exchange markets can be news-driven, can be unexpectedly volatile, and can be affected by non-market forces such as actions of various governments, as described elsewhere in this memorandum. Options. Trading options is highly speculative and may entail risks greater than investing in other securities. Option prices are generally more volatile than other securities’ prices. Derivatives in General. The Funds’ investments in derivative instruments could include, among other things, options, contracts for differences, participatory notes, swaps (including on interest rate, credit default, total return and equity swaps), futures and forward contracts. While specific types of derivatives involve specific risks, all derivative instruments can involve a variety of material risks, including leverage, limited liquidity, and correlation error and change. Over‐the‐Counter Derivatives. Over-the-counter or “OTC” derivatives have historically been individually-negotiated, non-standardized agreements entered into directly and privately between two parties—rather than on an exchange—to make/receive payments based on changes in underlying reference instruments or values. OTC derivatives involve risks such as counterparties’ failure to perform, loss in counterparties’ creditworthiness, payment obligations periodically or upon changes in the prices of underlying instruments or rates or indices, less liquidity than listed options or futures and difficulties in interpreting legal terms of the relevant agreements. Futures/Commodities Activities. The Funds could buy futures on securities indices, commodities, or currencies, and trade in other commodity interests. Trading in futures is highly speculative and may entail risks that are greater than investing in securities, including: increased volatility relative to other securities; increased exposure resulting from the leverage aspects of futures trading; and the potential illiquidity of futures positions. The Investment Manager is not registered as either a “commodity pool operator” or a “commodity trading adviser.”

Securities Lending. The Funds may lend portfolio securities either directly or through programs operated by financial intermediaries. As a creditor, the Funds run the risk that borrowers of their securities may fail to return borrowed securities on demand or at all. Exchange Traded Funds and Other Pooled Investment Vehicles. The Funds may invest or trade in Exchange Traded Funds (“ETFs”), index-related instruments, and other instruments or pooled vehicles as a way of hedging risks related to particular industries, sectors, or markets in connection with their other investments. Doing so will subject the Fund to hedging-related risks and may also include the risk that an ETF or index-related instruments may not effectively reflect the performance of the index, industry, or other market it is intended to replicate. Trading Errors. The Funds will bear the burdens, and enjoy the profits, from any trading errors, unless those errors constituted an act or omission as a result of gross negligence, willful misconduct, willful violation of law or a material breach of a Fund Agreement by the Investment Manager. Limited Liquidity. An investment in the Fund is illiquid and is not suitable for an investor who needs liquidity. There is no public market for Interests and there are limitations on Investors’ abilities to transfer their Interests. Although Investors may withdraw capital, their ability to do so is subject to several limitations. Cybersecurity. Maple Rock and the Funds generally rely on information technology systems for current and planned operations. Information and technology systems of Maple Rock may be vulnerable to damage and interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. If any systems designed to manage such risks are compromised, become inoperable for extended periods of time or cease to function properly, Maple Rock or the Funds may have to make a significant investment to fix or replace them. Any disruption in any of these systems or the failure of any of these systems to operate as expected could, depending on the magnitude of the problem, adversely affect a Fund’s investment results and its ability to make distributions to its partners. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Maple Rock’s and/or the Funds’ operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to investors (and the beneficial owners of investors). Such a failure could harm Maple Rock or the Funds’ reputation, subject them to legal claims and otherwise affect their business and financial performance. The foregoing list of risk factors does not purport to be a complete statement of the risks involved in an investment in the Funds. Please refer to the confidential offering memorandum.

An employee of Maple Rock has a familial relation with an investment manager at a non-profit foundation. Maple Rock believes that through its policies and procedures, including its personal trading policy and compliance monitoring, it has sufficient controls in place to mitigate the risk of any conflicts arising from this relationship.

The Code sets forth a standard of business conduct that takes into account Maple Rock’s status as a fiduciary to its clients and requires Access Persons to place the interests of the clients above their own interests. The Code requires Access Persons to comply with applicable federal securities laws. Further, Access Persons are required to promptly bring violations of the Code to the attention of Maple Rock’s Chief Compliance Officer. All Access Persons are provided with a copy of the Code and are required to acknowledge receipt of, and agreement to abide by, the Code. The Code also sets forth reporting and pre-clearance requirements for personal trading by Access Persons. Access Persons must provide Maple Rock’s Chief Compliance Officer with a list of their personal accounts and an initial holdings report promptly upon becoming an Access Person. In addition, Maple Rock’s Access Persons must provide annual holdings reports and quarterly transaction reports in accordance with Advisers Act Rule 204A-1. The Code also seeks to ensure the protection of non-public information about the activities of the Funds. In accordance with the Code, Access Persons are not permitted to trade in Reportable Securities except for (1) the purchase or sale of any private placement security and (2) the sale of securities that were held prior to the later of becoming an Access Person or December 1, 2021; in each case subject to pre-trade approval by the Chief Compliance Officer. Such approval will only be granted if approval would not be contrary to what is in the interest of the Funds. As such, for item 8(A)(2) in Maple Rock’s Form ADV Part 1, Maple Rock has answered in the positive. The Chief Compliance Officer or his or her designee also periodically reviews Access Persons’ personal transaction and holdings reports to make sure each Access Person is conducting his or her personal securities transactions in a manner that is consistent with the Code. The CCO or his designee logs and investigates any breaches and their disposition, and sanctions are applied based on the CCO’s judgment consistent with the Code. Maple Rock’s Code of Ethics also contains policies and procedures designed to ensure that its Access Persons do not engage in insider trading. Insider trading is generally understood to be trading on the basis of material non-public information. The Code addresses the principal elements of insider trading, including materiality, and the procedures Access Persons must follow if they come into possession of material non-public information. Maple Rock maintains a Restricted List, which is a key component of its insider trading procedures. Clients or prospective clients may obtain a copy of the Code by contacting Maple Rock’s Chief Compliance Officer at (416) 619-0705.

Participation or Interest in Client Transactions The Investment Manager and General Partners have financial ownership interests in the Funds and will receive a Management Fee and/or incentive-based compensation for their services to the Funds. Also, as explained in Item 10 and elsewhere in this Brochure, certain affiliated investors invest in the Funds, but such investments generally are not subject to the same Management Fees or incentivebased compensation described in Item 5 that may be applicable to other Investors. The fact that Maple Rock, its principals and employees have financial ownership interests in the Funds creates a potential conflict in that it could cause Maple Rock to make different investment decisions than if such parties did not have such financial ownership interests. Further, Maple Rock receives Management Fees and/or incentive-based compensation. The Management Fees are payable without regard to the overall success or income earned by the Funds and therefore create an incentive on the part of Maple Rock to raise or otherwise increase assets under management to a higher level than would be the case if Maple Rock were receiving no Management Fee. Incentivebased compensation creates an incentive for Maple Rock to make investments that are riskier or more speculative than in the absence of such compensation. Maple Rock addresses these potential conflicts through regular monitoring of client portfolios. If Maple Rock begins to manage other advisory clients beyond the current Funds, it will implement additional policies and procedures for allocating transactions and opportunities among the Funds and those other advisory clients in a manner it believes to be equitable, taking into account similarities and differences among the various accounts, and in particular relating to activities of the other advisory clients in which Maple Rock or its personnel or affiliates have material interests.

Selection Criteria Consistent with its duty to seek best execution, Maple Rock takes into account the full range and quality of brokerage services, including research and other services that benefit its clients. Maple Rock will work with its outsourced trader to effect transactions with brokerage firms which Maple Rock believes provide favorable net prices and are capable of providing efficient executions. The Investment Manager typically considers a range of factors, including: historical prices; Transacting Parties’ execution, clearance and settlement, and error correction capabilities generally and in connection with instruments of the type and in the amounts to be bought or sold; their reliability and financial stability; the size of the transaction; the availability of securities to borrow for short sales; the market for the instrument in question; and the nature, quantity, and quality of research and other services and products the Transacting Party provides. The clients may at times pay more than the lowest transaction cost available in order to obtain services and products other than the execution of securities transactions. Soft Dollars Section 28(e) of the Securities Exchange Act of 1934 provides a “safe harbor” to investment advisers who use commission dollars of their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to the manager in the performance of investment decision-making responsibilities. Maple Rock utilizes soft dollars within the parameters of Section 28(e). In acquiring services and products using soft dollars, the Investment Manager has an incentive to cause the Master Fund to pay higher compensation, use different Transacting Parties, and effect more transactions than it might otherwise do, possibly at the Funds’ expense. The Investment Manager intends to use soft dollars only to acquire services and products that constitute “research” and “brokerage” within the meaning of Section 28(e). The Investment Manager acquires the following types of “research” from Transacting Parties: reports on or other information about particular companies or industries; economic surveys and analyses; recommendations as to specific securities; financial and industry publications; portfolio evaluation services; financial database software and services; computerized news, pricing and statistical services; analytical software and services; proxy analysis services and systems; quotation services; and other products or services that may enhance the Investment Manager’s investment decisionmaking. “Brokerage” services and products beyond “actual” execution may include computer systems and facilities (including hardware) used for such things as communicating orders and settlementrelated information electronically to executing Transacting Parties, post-trade matching of trade information, communicating allocation instructions, and other clearance and settlement functions.

When Maple Rock uses client commissions for research, it receives a benefit because it does not have to furnish or pay for the research itself. Because the relevant Funds may pay higher commissions to generate soft dollars, Maple Rock faces a conflict of interest between the benefit it receives to access the research and the Funds’ possible interest in paying the lowest commission rates available. Maple Rock addresses this conflict by reviewing the factors noted above when selecting the Transacting Parties it uses, and by considering the reasonableness of the commissions paid in relation to the research or brokerage services received. Although the Funds use Transacting Parties that provide research on an ad hoc basis, Maple Rock will not enter into any traditional cash soft dollar arrangements, such as establishing a soft dollar account with a brokerage firm in order to direct payments to acquire products or services, even if those arrangements would be protected by Section 28(e). The Investment Manager also does not intend to choose a Transacting Party in recognition of referrals of investors, including investors in other investment funds the Investment Manager manages (including use of prime broker capital introduction services), referrals of advisory clients, or the potential for future referrals. Aggregation of Orders At this time, the Investment Manager has discretionary investment authority only with respect to the Master Fund and the Feeder Funds which invest by means of a master-feeder structure. To ensure fairness in the allocation of investment opportunities among the Funds and any other funds it manages in the future, Maple Rock will allocate investment opportunities with consideration to the suitability of such investments for each client. If an investment opportunity is suitable for more than one client, the Firm will allocate investment opportunities fairly and equitably (generally pro rata based on net asset value of accounts for accounts with the same investment objectives and risk profile).

The Chief Compliance Officer and Chief Financial Officer, with certain designees, perform reviews covering such areas as Maple Rock’s restricted trading list, personal trading, beneficial ownership levels and reporting obligations, trade errors, short selling and proxy voting, preparation of monthly accounts and annual financial statements, portfolio and net asset valuation, cash management and reconciliation, books and records maintenance and other matters. All Maple Rock Fund investors receive audited financial statements of the Funds annually, in addition to account statements and reports of estimated investment performance on a monthly basis.

There may be times when refraining from voting is in the Funds’ best interests, taking into account associated costs, benefits, and interests of the clients. In such cases, Maple Rock will document its decision not to vote the proxy. Maple Rock has engaged the services of Broadridge’s ProxyEdge platform to vote and maintain records of proxy votes. Maple Rock keeps a record of its proxy voting policies and procedures, proxy statements received, votes cast, all communications received, and internal documents created that were material to voting decisions and each request for proxy voting records and Maple Rock’s response for the previous five years. Clients may obtain (i) a copy of Maple Rock’s proxy voting policies and procedures and/or (ii) information on how Maple Rock has voted proxies with respect to the Funds’ securities by contacting the Chief Compliance Officer.