Covalis Capital LLP: investment adviser

Covalis Capital LLP provides discretionary investment management services to qualified investors through the following private funds: (i) Covalis Capital Master Fund Ltd, and (ii) Covalis Capital Partners Master Fund Ltd (“Master Funds”), each of which is funded by dedicated offshore and onshore feeder funds (“Feeder Funds”). Covalis Capital LLP also provides sub-advisory services to certain private funds managed by an affiliated manager (“Affiliated Manager Sub-Advised Funds”) or third-party manager (“ThirdParty Manager Sub-Advised Fund”) (each a “Sub-Advised Fund” and collectively the “SubAdvised Funds”). The Master Funds, the Feeder Funds and the Affiliated Manager Sub-Advised Funds are each referred to as a “Fund” and collectively referred to as the “Funds”. Each Fund/Sub-Advised Fund will be managed in accordance with the terms of their respective Offering Documents (including the investment management agreement) for each respective Fund/ Sub-Advised Fund. Covalis Capital LLP also provides investment advisory services to one or more clients for which it does not exercise investment discretion and therefore in relation to which it has no regulatory assets under management (each an “Advisory Client” and together the “Advisory Clients”). The Funds, Sub-Advised Funds and Advisory Clients are each referred to as a “Client” and collectively referred to as the “Clients”. The Clients’ “Shareholders” or “Limited Partners” are hereafter collectively referred to as the “Investors” where appropriate. Our investment decisions and advice with respect to the Funds/Sub-Advised Funds are subject to the terms of each Fund’s/Sub-Advised Fund’s investment objectives and guidelines, as set forth in their respective offering memorandum, as well as other terms contained in their respective memorandum & articles of association, investment management agreement and/or subscription documents, together “Offering Documents.” Investors in each Fund/SubAdvised Fund should refer to the Offering Documents of the Fund/Sub-Advised Fund in which they are an Investor for information on the investment objective and investment restrictions with respect to such Fund/Sub-Advised Fund. The Firm does not currently participate in any Wrap Fee Programs.

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As of March 31, 2026, the Firm had approximately $4,788,894,748 in regulatory assets under management (“RAUM”), $4,558,207,935 of which are advised on a discretionary basis and $230,686,813 which are advised on a non-discretionary basis.

The management fee typically ranges from approximately 1.5% to 4.0% per annum of the net asset value of the shares or interests of each Fund held by Investors. Such fees are typically calculated monthly and paid in arrears in accordance with the Offering Documents of the applicable Fund. Alternatively, no management fee may be payable in respect of the shares/interests in the Funds held by Investors however, the respective Fund shall have the right to charge such management fee pursuant to agreement with a prospective investor at the rates agreed with such investor. Affiliate managers/advisers providing services to the Funds may receive compensation pursuant to agreements with the relevant Fund and/or an affiliated entity. Such compensation is typically paid out of the management fee received by the affiliated entity and does not represent an additional fee charged to Investors. Additionally, Covalis Capital LLP or its affiliates may receive performance-based compensation of the realized and unrealized net profits of a Fund (“Incentive Compensation”), in each case as provided for in the applicable Offering Documents. Certain Investors will not bear Incentive Compensation on profits until any respective aggregate net losses from any prior period are recovered. Additionally, some Clients and/or Investors may enter into agreements which do not include performance-based compensation provisions. Performance-based compensation may vary with each Fund/Sub-Advised Fund and is explained more fully in each Fund/SubAdvised Fund Offering Documents. Covalis Capital LLP, as applicable, may waive, modify or calculate differently the management fee and any performance-based compensation paid by any Client or Investor in a Fund on a case-by-case basis. Unless otherwise agreed upon with a Client, any management fees and performance-based compensation are generally paid from the relevant Client account. No Covalis Capital LLP member/employee is directly compensated for the sale of securities or other investment products.

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Other Types of Fees or Expenses As more fully described in each Fund’s Offering Documents, the feeder funds will bear their own expenses and the pro rata share of master funds’ expenses and indirectly, any asset holding vehicle’s expenses, which may include, without limitation; the Management Fee; expenses that are related to the investment of the master fund’s assets, whether or not such investments are consummated, such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expenses; investment-related travel expenses (which are travel expenses related to the purchase, sale or transmittal of the master funds’ investments) incurred by Covalis Capital LLP and/or its affiliates and approved by the Directors/directors of the General Partners; professional fees (including expenses of consultants, investment bankers, attorneys, accountants, professional advisors and other experts) relating to investments; administrative expenses (including fees and expenses of the Administrator, the Depositary Services Provider and other similar service providers); fees and expenses relating to the sourcing, researching, due diligence, monitoring and analyzing actual and prospective investments (whether or not consummated), research, news and market data (including, without limitation, Investment Research, any information or artificial intelligence-related technology hardware, software or other technology incorporated into the cost of obtaining such research and market data) and relating to the implementation and ongoing management costs of such technology; legal expenses; external accounting and valuation expenses (including the cost of accounting software packages); audit and tax preparation expenses; fees of the Directors/directors of the General Partners; costs of printing and mailing reports and notices; taxes; corporate licensing; regulatory expenses (including filing fees); organisational expenses; operational expenses, including, without limitation, the following: fees and expenses relating to information technology hardware, software, artificial intelligence or other technology (including, without limitation, costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate the monitoring, optimisation, reconciliation, and reporting of the Funds’ financing arrangements, facilitate compliance with the rules of any self-regulatory organization or applicable law (including, without limitation, reporting obligations), facilitate and manage the order execution of securities or otherwise manage the Funds or any trading subsidiary, such as Bloomberg terminals, portfolio management systems, risk management systems and order management systems; and fees and expenses related to compliance with the rules of any self-regulatory organization or applicable law in connection with the activities of the Funds or any trading subsidiary, including, without limitation, any governmental, regulatory, licensing, filing or registration fees or taxes (including, without limitation, fees and expenses incurred in connection with the preparation and filing of Annex IV, Section 13 filings, Section 16 filings and other similar regulatory filings); costs relating to the directors’ and officers’ liability insurance; expenses incurred in connection with the offering and sale of the Interests and other similar expenses related to the Funds; indemnification expenses; and extraordinary expenses. To the extent that fund expenses that are to be borne by the Funds are paid by Covalis Capital LLP and/or its affiliates, the Funds will reimburse such party for such expenses. Any fund expenses of the feeder funds may be paid by the master funds and allocated across the investors in the relevant feeder fund(s) pro rata based upon their relative net asset value. If any expense is incurred jointly for the account of the master fund and any other account, such expense will be allocated among the relevant Funds and such other accounts in

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proportion to their respective net asset value, or in such other manner as the Board of Directors considers fair and equitable. Pass-Through Expenses In addition to the management fee, performance-based compensation, and fund expenses, certain Funds and/or Sub-Advised Funds also bear and reimburse Covalis Capital LLP and/or its affiliates for its allocable share of Pass-Through Expenses. “Pass-Through Expenses” are the costs and expenses of Covalis Capital LLP and/or its affiliates attributable to, or associated with, the employment or engagement of the portfolio managers, investment analysts and other personnel of Covalis Capital LLP and/or its affiliates that are engaged in the development of the investment strategies and implementation of the investment objective of the relevant Fund(s) and/or Sub-Advised Fund(s) that are not otherwise considered fund expenses as described above and in the relevant Offering Documents or Client agreement, including those relating to: (i) direct and indirect compensation of such personnel, deferred compensation, grants, buy-out payments, severance and other awards; (ii) costs and expenses in connection with any dispute or proceedings relating to such personnel, including the costs of any compensation or settlement payments; and (iii) recruitment fees, retainers paid to recruiters and legal expenses incurred in connection with the hiring or termination of such personnel. The relevant Fund’s and/or Sub-Advised Fund’s allocable portion of the Pass-Through Expenses will generally be reimbursed by such Fund/Sub-Advised Fund when the applicable Pass-Through Expenses are paid by Covalis Capital LLP and/or its affiliates. Pass-Through Expenses may, however, be amortised over time in such manner as Covalis Capital LLP or its affiliates may determine in their sole discretion. There is no limitation on the amount of the Pass-Through Expenses that can be allocated to such Fund/Sub-Advised Fund and the amount of such Pass-Through Expenses to be borne by such Fund/Sub-Advised Fund is expected to be substantial.

Further, the variation of performance-based compensation structures among Covalis Capital LLP’s Clients may create an incentive for Covalis Capital LLP to direct the best investment ideas to, or to allocate or sequence trades in favor of, a Client that bears higher performance-based compensation or performance-based compensation providing for payment to Covalis Capital LLP at different times or over different time intervals than another Client. Covalis Capital LLP has procedures designed and implemented to provide reasonable assurance that all Clients are treated fairly. Specifically, Covalis Capital LLP maintains procedures designed to address the allocation of investment opportunities among Clients as well as the manner in which investments are valued. Our allocation policy seeks to ensure that we allocate investment opportunities across Clients fairly and equitably over time based upon our policies and procedures. -7-

In order to invest in any of the Funds, prospective and existing Investors must be “accredited investors” and, to the extent applicable, if subject to performance-based compensation, a “qualified client” as defined by Section 205 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and Rule 205-3 thereunder. Additionally, all prospective and existing Investors in the Funds exempted from the definition of investment company by virtue of Section 3(c)(7) of the Company Act must be “qualified purchasers” as defined in Section 2(a)(51) thereof and the rules thereunder. The Offering Documents of each Fund may set minimum amounts for investment by prospective Investors. Such minimum investments, however, may be (and have been) waived or modified by the Funds, in their sole discretion. Investment advice is provided directly to the Client and not individually to Investors in the Funds/Sub-Advised Funds. Covalis Capital LLP is under no obligation to accept any prospective client or investor and may decline acceptance of a prospective client or investor in its sole discretion.

Investment Objective The investment objective for each particular Client is set out in its Offering Documents. Investors should review those documents carefully before investing. Generally speaking, the Firm’s objective is to seek to achieve absolute, low volatility investment returns in both rising and declining market conditions. Funds are expected to invest predominantly in the equities of utilities, infrastructure, real estate, autos value chain, industrials, materials, energy, telecommunication and renewables sectors globally. The investable universe currently comprises over one thousand companies.

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Funds’ portfolios may also include investments in less liquid and unlisted securities from time to time. The Firm’s investment theses mainly originate from industry research, company meetings, periodic company and event calendar review. These theses will be subsequently quantified by its analysts and firmed up by the Firm’s senior investment professionals who will be engaged in meeting company executives and relevant local regulators. An investment idea will be generated when an internal view derived from this activity suggests a different outcome from market expectations. The Funds have the authority to borrow, trade on margin, utilize derivatives and otherwise obtain leverage from brokers, banks and others on a secured or unsecured basis. The Funds may offer different share classes for general subscription as described in the respective Offering Documents. Certain assets or securities (together with any related hedges, financings, reserves or similar investments) may be designated to the relevant share class interests as described in the respective Offering Documents. The Funds may invest in assets or securities that are not freely tradable or that the Firm determines should be held until the resolution of a special event or circumstance. The investment program of the Funds is speculative and may entail substantial risks. Market risks are inherent in all investments to varying degrees. There can be no assurance that the investment objective of the Funds will be achieved. Certain investment practices described above can, and in some circumstances, may potentially increase, the risk of an adverse impact on the Funds’ investment portfolio (see "Risk Factors"). Risk Management At the position level, risk management is incorporated by the Firm throughout the investment process. The most important risk to consider for the Funds and their respective Investors is permanent loss of capital. To seek to mitigate this risk, the Firm will perform extensive analysis and seek to make investments for each Fund with limited potential loss in the event the investment thesis fails to materialize as expected. As part of its risk management process, the Firm considers various risk scenarios, and (if applicable) will hedge identifiable risks. The Firm will perform in depth research in connection with its investment process, and only invests where there is a perceived identifiable advantage. Position sizing will be driven by the anticipated loss, adjusted for upside asymmetry, conviction level, catalyst profile, market technicals and expected liquidity conditions. As part of this process, the Firm discusses and documents thesis breakers up-front to help avoid any behavioural influences and biases when and if those events unfold. At the portfolio level, risk management starts with portfolio construction and asset allocation. The Firm determines the appropriate allocation to various investment strategies for each Fund. Risk exposures such as industry concentration, commodity exposure, interest rates, political or binary outcomes will also be considered. The Firm monitors each Fund’s investments so that the exposures are appropriate in size and an intentional result of an investment thesis. The Firm believes that managing risk at the portfolio level goes beyond the level of diversification and understanding of various exposures to also include analyzing how

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positions are correlated to each other and to broader market moves or macroeconomic trends. Understanding this correlation is a critical input to the portfolio’s risk/reward return profile. Risk of Loss Factors The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. An investment in the Funds involves significant risks, and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who have met the conditions set forth in the Offering Documents. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly-traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Offering Documents of the relevant Fund before deciding to invest. Risks Related to Investment Strategy Volatility Risk. The Funds’ investment programs may involve the purchase and sale of relatively volatile instruments such as derivatives, which are frequently valued based on implied volatilities of such derivatives compared to the historical volatility of underlying securities. Fluctuations or prolonged changes in the volatility of such securities, therefore, can adversely affect the value of investments held by the Funds. Long-Term Investments. The Funds are likely to pursue investment opportunities that seek to maximize asset value or create market opportunities on a long-term basis. In pursuing such long-term strategies, the Funds may forego value in the short term or temporary investments in order to be able to avail the Funds of additional and/or longer-term opportunities in the future. Consequently, the Funds may not capture maximum available value in the short term, which may be disadvantageous, for example, for Investors who withdraw all or a portion of their interest in the relevant Fund before such long-term value may be realized by the relevant Fund. Short Selling. A short sale in equity creates the risk of a theoretically unlimited loss, in that the price of the underlying security could theoretically increase without limit, thus increasing the cost to a Fund of buying those securities to cover the short position. In credit short sales the risk of loss is generally limited by spread tightening to risk free rate or zero bound in the case of CDS. There can be no assurance that a Fund will be able to maintain the ability to borrow securities sold short. In such cases, such Fund can be “bought in” (i.e., forced to repurchase securities in the open market to return to the lender). There also can be no assurance that the securities necessary to cover a short position will be available for purchase at or near prices quoted in the market. Purchasing securities to close out a short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. Short strategies can also be implemented synthetically through various instruments and be used with respect to indices or in the over-the-counter market and with respect to futures and other instruments. In some cases of synthetic short sales, there is no floating supply of an underlying instrument with which to cover or close out a short position and a Fund may be entirely dependent on the

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willingness of over-the-counter market makers to quote prices at which the synthetic short position may be unwound. There can be no assurance that such market makers will be willing to make such quotes. Short strategies can also be implemented on a leveraged basis. Lastly, even though a Fund secures a “good borrow” of the security sold short at the time of execution, the lending institution may recall the lent security at any time, thereby forcing such Fund to purchase the security at the then-prevailing market price, which may be higher than the price at which such security was originally sold short by such Fund. Hedging Transactions. The Funds may utilize financial instruments both for investment purposes and for risk management purposes in order to (i) protect against possible changes in the market value of the Funds’ investment portfolios resulting from fluctuations in the markets and changes in interest rates; (ii) protect the Funds’ unrealized appreciation in the value of its investment portfolio; (iii) facilitate the sale of any such investments; (iv) enhance or preserve returns, spreads or appreciation on any investment in the Funds’ portfolios; (v) hedge against a directional trade; (vi) hedge the interest rate, credit or currency exchange rate on any of the Funds’ investments; (vii) protect against any increase in the price of any investments the Funds anticipate purchasing at a later date; or (viii) act for any other reason that the Firm deems appropriate. The Funds will not be required to hedge any particular risk in connection with a particular transaction or its portfolios generally. While the Funds may enter into hedging transactions to seek to reduce risk, such transactions may result in a poorer overall performance for the Funds than if it had not engaged in any such hedging transaction. Moreover, it should be noted that the portfolio will always be exposed to certain risks that may not be hedged. Emerging Market Investments. The Funds may invest in securities of companies located in emerging countries or issued by the governments of such countries. Investing in such securities involves certain considerations not usually associated with investing in securities of companies located in developed countries or issued by the government of such countries, including security and economic considerations, such as greater risks of expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, other income or gross sale or disposition proceeds, limitations on the removal of funds, nationalization and general social, political and economic instability; the small size of the securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and in price volatility; fluctuations in the rate of exchange between currencies and costs associated with currency conversion; certain government policies that may restrict the Funds’ investment opportunities; and problems that may arise in connection with the clearance and settlement of trades. In addition, accounting and financial reporting standards that prevail in certain countries generally are not equivalent to standards in more developed countries and, consequently, less information is available to investors in companies located in these countries than is available to investors in companies located in more developed countries. There is also less regulation, generally, of the securities markets in emerging countries than there is in more developed countries. Placing securities with a custodian in an emerging country may also present considerable risks. Exchange Rate Fluctuations; Currency Risks. The Funds may invest in financial instruments denominated in non-U.S. currencies, the prices of which are determined with reference to currencies other than the U.S. Dollar. The Funds, however, value their financial instruments in U.S. Dollars. The Funds may or may not seek to hedge its non-U.S. currency exposure by entering into currency hedging transactions, such as treasury locks, forward contracts, futures contracts and cross-currency swaps. There can be no guarantee that financial instruments suitable for hedging currency or market shifts will be available at the time when the Funds

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wish to use them, or that hedging techniques employed by the Funds will be effective. Furthermore, certain currency market risks may not be fully hedged or hedged at all. To the extent unhedged, the value of the Funds’ positions in denominated currencies other than U.S. Dollars will fluctuate with U.S. Dollar exchange rates as well as with the price changes of the investments in the various local markets and currencies. In such cases, an increase in the value of the U.S. Dollar compared to the other currencies in which the Funds make investments will reduce the effect of any increases and magnify the effect of any decreases in the prices of the Funds’ investments in their local markets and may result in a loss to the Funds. Conversely, a decrease in the value of the U.S. Dollar will have the opposite effect on the Funds’ non-U.S. Dollar investments. Risks Related to Financial Instruments Equity Securities. The value of equity securities of public and private, listed and unlisted companies and equity derivatives generally varies with the performance of the issuer and movements in the equity markets. As a result, the Funds may suffer losses if they invest in equity instruments of issuers whose performance diverges from the Firm's expectations or if equity markets generally move in a single direction and the Funds have not hedged against such a general move. The Funds also may be exposed to risks that issuers will not fulfil contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. Preferred Stock. Investments in preferred stock involve risks related to preferred stocks priority in the event of bankruptcy, insolvency or liquidation of the issuing company and how dividends are declared. Preferred stock ranks junior to debt securities in an issuer's capital structure and, accordingly, is subordinate to all debt in bankruptcy. Preferred stock generally has a preference as to dividends. Such dividends are generally paid in cash (or additional shares of preferred stock) at a defined rate, but unlike interest payments on debt securities, preferred stock dividends are payable only if declared by the issuer's board of directors. Dividends on preferred stock may be cumulative, meaning that, in the event the issuer fails to make one or more dividend payments on the preferred stock, no dividends may be paid on the issuer's common stock until all unpaid preferred stock dividends have been paid. Preferred stock may also be subject to optional or mandatory redemption provisions. Convertible/Exchangeable Securities. A convertible security may be subject to redemption at the option of the issuer at a price established in the convertible security's governing instrument. If a convertible security held by the Funds are called for redemption, the Funds will be required to permit the issuer to redeem the security, convert it into the underlying common stock or sell it to a third party. Any of these actions could have an adverse effect on the Funds’ ability to achieve its investment objective. Investments in Initial Public Offerings. Investments in initial public offerings (or shortly thereafter) may involve higher risks than investments issued in secondary public offerings or purchases on a secondary market due to a variety of factors, including, without limitation, the limited number of shares available for trading, unseasoned trading, lack of investor knowledge of the issuer and limited operating history of the issuer. In addition, some companies in initial public offerings are involved in relatively new industries or lines of business, which may not be widely understood by investors. Some of these companies may be undercapitalized or regarded as developmental stage companies, without revenues or operating income, or the

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near-term prospects of achieving them. These factors may contribute to substantial price volatility for such securities and, thus, for the value of the Funds’ Interests. Unlisted Securities. Unlisted securities may involve higher risks than listed securities. Because of the absence of any trading market for unlisted securities, it may take longer to liquidate, or it may not be possible to liquidate, positions in unlisted securities than would be the case for publicly traded securities. Companies whose securities are not publicly traded may not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. Debt Securities. The Funds may invest in private debt securities and other similar instruments. The Funds may invest in debt instruments that are unrated, and whether or not rated, the debt instruments may have speculative characteristics. The issuers of such instruments, including sovereign issuers, may face significant ongoing uncertainties and exposure to adverse conditions that may undermine the issuer's ability to make timely payment of interest and principal. Such instruments are regarded as predominantly speculative with respect to the issuer's capacity to pay interest and repay principal in accordance with the terms of the obligations and involve major risk exposure to adverse conditions. The Funds may invest in bonds or other fixed income securities, including without limitation "higher yielding" (including non-investment grade) debt securities. Such securities are generally not exchange traded and, as a result, these financial instruments trade in the overthe-counter marketplace, which is less transparent and has wider bid/ask spreads than the exchange-traded marketplace. In addition, the Funds may invest in bonds of issuers that do not have publicly-traded equity securities, making it more difficult to hedge the risks associated with such investments. Also, the market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. High yield securities face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer's inability to meet timely interest and principal payments. High yield securities are generally more volatile and may or may not be subordinated to certain other outstanding securities and obligations of the issuer, which may be secured by substantially all of the issuer's assets. High yield securities may also not be protected by financial covenants or limitations on additional indebtedness. The market values of certain of these lower-rated and unrated debt securities tend to reflect individual corporate developments to a greater extent than do higher-rated securities which react primarily to fluctuations in the general level of interest rates and tend to be more sensitive to economic conditions than are higher-rated securities. Companies that issue such securities may be highly leveraged and may not have available to them more traditional methods of financing. Swap Agreements. The Funds may enter into swap agreements and options on swap agreements ("swaptions"). These agreements can be individually negotiated and structured to include exposure to a variety of different types of investments, asset classes or market factors. The Funds, for instance, may enter into correlation swaps, variance swaps, volatility swaps or other swap agreements with respect to interest rates, credit defaults, currencies, securities, indexes of securities and other assets or other measures of risk or return. Depending on their structure, swap agreements may increase or decrease the Funds’ exposure to, for example, equity securities, long-term or short-term interest rates, foreign currency values, credit spreads or other factors. Swap agreements can take many different forms and are known by a variety of names. The Funds are not limited to any particular form of swap agreement.

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Whether the Funds’ use of swap agreements or swaptions will be successful will depend on the Firm’s ability to select appropriate transactions for the Funds. Swap transactions may be highly illiquid and may increase or decrease the volatility of the Funds’ portfolio. Moreover, the Funds bear the risk of loss of the amount expected to be received under a swap agreement in the event of the default or insolvency of its counterparty. The Funds will also bear the risk of loss related to swap agreements, for example, for breaches of such agreements or the failure of the Funds to post or maintain required collateral. Many swap markets are relatively new and still developing. It is possible that developments in the swap markets, including potential government regulation, could adversely affect the Funds’ ability to terminate swap transactions or to realise amounts to be received under such transactions. Currencies and Currency-Related Instruments. A principal risk in trading currencies is the rapid fluctuation in the market prices of currency contracts. Prices of currency contracts traded by the Funds are affected generally by relative interest rates, which in turn are influenced by a wide variety of complex and difficult to predict factors such as money supply and demand, balance of payments, inflation levels, fiscal policy, and political and economic events. In addition, governments from time to time intervene, directly and by regulation, in these markets, with the specific effect, or intention, of influencing prices which may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. The Funds may invest in undervalued currencies. Identifying investment opportunities in undervalued currencies is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. Returns generated from such investments may not adequately compensate for the business and financial risks assumed. In addition, the Funds may be required to hold such currencies for a substantial period of time before realizing their anticipated value. During this period, a portion of the Funds’ assets would be committed to the currencies purchased, thus possibly preventing the Funds from investing in other opportunities. Further, the Funds may finance such purchases with borrowed funds and thus will have to pay interest on such funds during such waiting period. Like the writing of other kinds of options, the writing of an option on a currency constitutes only a partial hedge, up to the amount of the premium received. The Funds could be required, with respect to any option it has written, to purchase or sell currencies at disadvantageous exchange rates, thereby incurring losses. The purchase of an option on a currency may constitute an effective hedge against fluctuation in exchange rate, although in the event of rate movements adverse to the Funds’ position, the Funds could forfeit the entire amount of the premium plus related transaction costs. Futures Contracts. The value of futures depends upon the price of the financial instruments, such as commodities, underlying them. The prices of futures are highly volatile, and price movements of futures contracts can be influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. In addition, investments in futures are also subject to the risk of the failure of any of the exchanges on which the Funds’ positions trade or of its clearing houses or counterparties. Futures positions may be illiquid because certain commodity exchanges limit fluctuations in certain futures contract prices during a single day by regulations referred to as "daily price fluctuation limits" or "daily limits." Under such daily limits, during a single trading day, no

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trades may be executed at prices beyond the daily limits. Once the price of a particular futures contract has increased or decreased by an amount equal to the daily limit, positions in that contract can neither be taken nor liquidated unless traders are willing to effect trades at or within the limit. This could prevent the Funds from promptly liquidating unfavourable positions and subject the Funds to substantial losses or prevent it from entering into desired trades. In extraordinary circumstances, a futures exchange or regulator could suspend trading in a particular futures contract, or order liquidation or settlement of all open positions in such contract. Forward Trading. Forward contracts and options thereon, unlike futures contracts, are not traded on exchanges and are not standardized; rather, banks and dealers act as principals in these markets, negotiating each transaction on an individual basis. Forward and "cash" trading is substantially unregulated; there is no limitation on daily price movements and speculative position limits are not applicable. The principals who deal in the forward markets are not required to continue to make markets in the currencies or commodities they trade, and these markets can experience periods of illiquidity, sometimes of significant duration. There have been periods during which certain participants in these markets have refused to quote prices for certain currencies or commodities or have quoted prices with an unusually wide spread between the price at which they were prepared to buy and that at which they were prepared to sell. Disruptions can occur in forward markets due to unusually high trading volume, political intervention or other factors. General Risks General Economic and Market Conditions. The success of the Funds’ activities will be affected by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the Funds’ investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of investments' prices and the liquidity of the Funds’ investments. Volatility or illiquidity could impair the Funds’ profitability or result in losses. The Funds may maintain substantial trading positions that can be adversely affected by the level of volatility in the financial markets — the larger the positions, the greater the potential for loss. The economies of countries in which the Funds may invest may differ in such respects as growth of gross domestic product, rate of inflation, currency depreciation, asset reinvestment, resource self-sufficiency and balance of payments position. Further, certain economies are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. The economies of certain countries may be based, predominantly, on only a few industries and may be vulnerable to changes in trade conditions and may have higher levels of debt or inflation. Legal Risk. Many of the laws that govern private and foreign investment, equity securities transactions and other contractual relationships in certain countries, particularly in developing countries, are new and largely untested. As a result, the Funds may be subject to a number of unusual risks, including inadequate investor protection, contradictory legislation, incomplete, unclear and changing laws, ignorance or breaches of regulations on the part of other market participants, lack of established or effective avenues for legal redress, lack of

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standard practices and confidentiality customs characteristic of developed markets and lack of enforcement of existing regulations. Furthermore, it may be difficult to obtain and enforce a judgment in certain countries in which assets of the Funds are invested. There can be no assurance that this difficulty in protecting and enforcing rights will not have a material adverse effect on the Funds and their operations. Reliance on Service Providers. The Firm and Funds may retain service providers at any time and from time to time. As the Funds have no employees and the majority of the members of the board of directors of the General Partner and the members of the board of directors of the Funds have been appointed on a non-executive basis, the General Partner, Directors, and/or the Funds are reliant on the performance of third-party service providers, including the Firm, the Administrator, the Depositary Services Provider, the Prime Broker, the Custodian, McDermott, Will & Schulte, Maples and Calder, Walkers, Hassans and the Auditors and any other service provider to the Funds, the General Partner, Directors, and/or the Firm as described herein (the "Service Providers"). Each Investor’s relationship in respect of its investment is with the Funds only. Accordingly, absent a direct contractual relationship between the investor and the relevant Service Provider, no Investor will have any contractual claim against any Service Provider for any reason related to its services to the Funds. Instead, the proper plaintiff in an action in respect of which a wrongdoing is alleged to have been committed against the Funds, as the case may be, by the relevant Service Provider is, prima facie, the Funds, as the case may be. Assumption of Business, Terrorism and Catastrophe Risks. Opportunities involving the assumption by the Funds of various risks relating to particular assets, markets or events may be considered from time to time. The Funds’ portfolio is subject to the risk of loss arising from exposure that it may incur, directly or indirectly, due to the occurrence of various events, including, without limitation, hurricanes, earthquakes and other natural disasters, terrorism, public health crises (such as pandemics and epidemics) and other catastrophic events, and events that could adversely affect the health or life expectancy of people. These risks of loss can be substantial, could greatly exceed all income or other gains, if any, received by the Funds in assuming these risks and, depending on the size of the loss, could adversely affect the return of the Funds. Furthermore, any such event may also adversely impact one or more individual Investors' financial condition, which could result in substantial withdrawal requests by such Investor as a result of their individual liquidity situations and irrespective of Funds performance. Cybersecurity Risk. As part of its business, the Firm processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Funds and personally identifiable information of the Investors. Similarly, service providers of the Firm, or the Funds, especially the Administrator, may process, store and transmit such information. The Firm has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Firm may be susceptible to compromise, leading to a breach of the Firm’s network. The Firm’s systems or facilities may be susceptible to member/employee error or malfeasance, government surveillance, or other security threats. On-line services provided by

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the Firm to the Investors may also be susceptible to compromise. Breach of the Firm’s information systems may cause information relating to the transactions of the Funds and personally identifiable information of the Investors to be lost or improperly accessed, used or disclosed. The service providers of the Firm and the Funds are subject to the same electronic information security threats as the Firm. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of the Funds and personally identifiable information of the Investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Firm’s, or the Funds’ proprietary information may cause the Firm or the Funds to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on the Funds’ and the Investors' investments therein. Artificial Intelligence and Machine Learning Risks. The emergence of recent technology developments in generative artificial intelligence such as ChatGPT and similar large language models and chatbots (collectively, “Generative AI”) can pose risks to the Firm, and the Funds’ investments. The Firm expects to use Generative AI in various processes, including potentially in connection with its investment research process. The Firm is likely to be further exposed to the risks of Generative AI through third parties (including the Firm’s or the Funds’ Service Providers or counterparties) that use Generative AI, and the Firm may not always be aware of such use. The Firm cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Furthermore, due to the rapidly evolving nature of Generative AI and its widespread potential uses, the Firm expects that its policies and procedures will continue to evolve in response to any unique challenges. Generative AI is often highly reliant on the collection and analysis of large amounts of data, and in many instances it may not be possible or practicable to incorporate all potentially relevant data into the data set that Generative AI utilizes or to evaluate the source and the reliability of the data being analyzed. Further, the outputs of Generative AI may be inaccurate or unreliable and are also susceptible to errors in such outputs' subsequent analysis. Additionally, the use of Generative AI may involve (i) cybersecurity risks (including the increased likelihood that the Firm, and Funds, or the underlying issuers in which they are invested become a victim of cybercrime), (ii) threats to proprietary and confidential information, (iii) intellectual property violations, (iv) access to, or disclosure of, personal information in violation of applicable data protection laws, and (v) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats and/or violations could have adverse impacts on the Firm or the Funds’ investments. Generative AI continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments. Risks Relating to Virtual Currency and Virtual Currency Derivatives Trading. The Funds may invest in virtual currencies (also known as "cryptocurrencies" or "digital currencies"), or similar assets that utilise blockchain technology, and virtual currency derivatives, although the Funds expect that any such investment is likely to constitute only a small proportion of its portfolio. Virtual currencies are relatively new, evolving products based upon new and evolving technologies. An investment in any virtual currency is subject to a variety of risks, including technological, cybersecurity, risks associated with “Digital Wallets”, price volatility risks, risks associated with virtual currency exchanges, competition risks and regulatory risks

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as well as associated uncertainties over the future existence, support and development of such virtual currency. Virtual currencies may also experience unusual volatility. Any such investment is highly speculative and subject to the risk that the entirety or a material portion of such investment or its value may be lost. Virtual currency derivatives, such as futures or options on futures on a virtual currency, are also a relatively new asset class, and trading in these instruments, like trading in the virtual currencies themselves, carries a high level of risk. Investments in virtual currency derivatives, like direct investments in virtual currencies, should be considered substantially more speculative and significantly more likely to result in a total loss of capital than many other investments. The foregoing risks are not exhaustive. Additional risks are described in each Client’s Offering Documents. Investors should review those documents carefully before investing.

These affiliates may act as investment managers, investment advisers or sub-advisers to certain Funds/Sub-Advised Funds or provide advisory services to other client accounts. Such arrangements may create potential conflicts of interest, including the allocation of investment opportunities, resources or expenses among the Firm, the Funds, Sub-Advised Funds and their affiliates. The Firm has adopted policies and procedures designed to allocate investment opportunities and expenses in a manner it believes to be fair and equitable over time. Covalis Capital LLP and its affiliate advisers have adopted a Code of Ethics concerning trading by personnel of Covalis Capital LLP that is designed to detect and prevent potential conflicts of interest between Covalis Capital LLP and the Clients and Investors. Please refer to Item 11 below for additional information regarding Covalis Capital LLP’s Code of Ethics. Covalis Capital LLP and its affiliate advisers have certain non-U.S. group entities that (i) perform a variety of services (including portfolio advisory services, research, risk analysis and certain operations services), which services from time to time may be rendered for the benefit of Covalis Capital LLP and its affiliate advisers’ U.S. clients; and/or (ii) have overlapping personnel, (together the “Participating Affiliates”). Certain of these Participating Affiliates have entered into service agreements with Covalis Capital LLP and its affiliate advisers. None of the Participating Affiliates is registered with the SEC as an investment adviser. Instead, each

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of the Participating Affiliates will conduct its business in relation to Covalis Capital LLP subject to the terms of a so-called participating affiliate agreement (“Participating Affiliate Agreement”) pursuant to which, and consistent with the conditions set forth in a series of noaction letters issued by the SEC, the Participating Affiliates will remain subject to the regulatory supervision of both Covalis Capital LLP and, in certain respects, the SEC.

Members and employees must at all times place the interests of the Clients and Investors first; Members and employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Personal Investment Policy (described below); and Members and employees should not take inappropriate advantage of their position at the Firm.

Members and employees must report their personal securities holdings and transactions to Covalis Capital LLP’s Chief Compliance Officer or her designee. The Code requires each brokerdealer used by a member or an employee to provide duplicate personal account statements and trade confirmations directly to Covalis Capital LLP. The Code also requires Covalis Capital LLP to review these reports periodically. Covalis Capital LLP does not permit any member or employee to participate in initial public offerings (“IPOs”) or purchase private placements without the prior approval of the Chief Compliance Officer or her designee. Members and employees are also prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. Covalis Capital LLP’s personal trading policy is designed in part to prevent Covalis Capital LLP members and employees (which includes, for purposes of the policy, spouses, children or other dependents residing with the member or employee) from purchasing or selling securities on or about the time that such securities are purchased or sold by a Covalis Capital LLP Client. However, it is important to note that, at any given time, affiliated entities (other than members or employees) of Covalis Capital LLP may (on behalf of their clients) own the same securities owned by Covalis Capital LLP Clients. Covalis Capital LLP has adopted policies and procedures governing gifts and business entertainment, which includes disclosure of gifts and business entertainment in excess of

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certain de minimis thresholds and pre-clearance by its Chief Compliance Officer (or a delegate) prior to giving/receiving gifts above a certain de minimis threshold. Covalis Capital LLP or its related persons, in the course of their investment management and other activities, may come into possession of confidential or material nonpublic information about issuers, including issuers in which Covalis Capital LLP or its related persons have invested or seek to invest on behalf of clients. Covalis Capital LLP is prohibited from disclosing or using such information in violation of applicable law for its own benefit or for the benefit of any other person, regardless of whether such other person is a Client. Covalis Capital LLP maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Covalis Capital LLP is meeting its obligations to its Clients and remains in compliance with applicable law. In certain circumstances, Covalis Capital LLP may possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security, but Covalis Capital LLP will be prohibited from communicating such information to the Client or using such information for the Client’s benefit. In such circumstances, Covalis Capital LLP will have no responsibility or liability to the Client for not disclosing such information to the Client (or the fact that Covalis Capital LLP possesses such information), or not using such information for the Client’s benefit, as a result of following Covalis Capital LLP’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. We will provide a copy of our Code of Ethics to our Investors, or any prospective investor, upon request, to be viewed on the premises.

Best Execution In selecting an appropriate broker-dealer to effect Fund/Sub-Advised Fund trades, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a Fund/Sub-Advised Fund in such a manner that a Fund’s/Sub-Advised Fund’s total costs or proceeds in the transaction are most favourable under the circumstances. The Firm considers many factors in determining whether it obtains Best Execution, only one of which is actual commission rate or price paid or received. Best execution is qualitative, and quantitative, and the Firm will weigh a combination of criteria to determine whether the transaction in question represents the best overall execution for the Fund/Sub-Advised Fund. Those factors include but are not limited to their reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas, analysis, and investment strategies), special execution and block

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positioning capabilities, clearance, settlement, and custodial services. The Firm’s “Best Execution Policy” requires that all trades are executed through approved broker- dealers and that the Firm reviews the performance of its broker-dealers to evaluate whether the Firm is obtaining Best Execution for its Fund’s/Sub-Advised Fund’s trades. The Firm maintains policies and procedures to review the quality of executions, including periodic reviews by its trading and investment professionals. Soft Dollars Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide appropriate assistance in the investment decision-making process. The Firm does not receive “Soft Dollars” in connection with its use of broker-dealers. Should the Firm engage in soft dollar arrangements at any point, the Firm will comply with the safe harbor requirements of Section 28(e) of the Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). Neither Covalis Capital LLP nor any related person receives client referrals from any brokerdealer or third party. The provision by a broker of research and other services to us creates an incentive for us to select such broker since we would not have to pay for such research and other services as opposed to solely seeking the most favourable execution for a client. Any research, services or property provided by a broker may benefit any client and such benefits may not be proportionate to commission dollars related to the provision of such research, services or property. Order Aggregation and Allocation Covalis Capital LLP and its affiliates will only aggregate orders if doing so is consistent with: (i) its duty to Clients to seek best execution, and (ii) the relevant terms of the investment guidelines and restrictions of each participating Client. Each Client that participates in an aggregated order will participate at the average execution price for each such order (or group of orders with the same executing broker) and will bear its proportionate share of the transaction costs. Any other terms negotiated for an aggregated order will also apply equitably to each participating Client. Covalis Capital LLP and its affiliates will endeavour to aggregate all appropriate orders in the same security and allocate them fairly and equitably to ensure all Clients obtain the same average execution price. The Firm has established a set of allocation rules that apply to its trades. Rules defining target allocation percentages for each Client are established and approved at the beginning of each calendar month. Target allocations are based on each Client’s beginning-of-month AUM, adjusted for leverage, where applicable. Various trade allocation schemes have been established to account for the various investment mandates. Certain Clients may only participate in certain mandates. If necessary, the trade allocation target percentages may be amended intra month, if approved. If a non-standard allocation is needed, this must be approved. Trade allocations are reviewed each day and any non-standard allocations are highlighted. When target allocations cannot be achieved, for example due to minimum lot size or rounding limitations, Covalis

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Capital LLP and its affiliates will allocate to Clients in a fair and equitable manner, aiming to minimize exposure differences. Consideration should also be given to pre-existing positions in each account. Occasionally position sizes may drift from target allocations across Clients due to a prior exception as delineated above or capital activity, and a rebalance trade may be required. Trade Error Policy A Client may on occasion experience a trade error. Trade errors may include, for example, (i) the placement of orders (either purchases or sales) in excess of, or less than, the amount of securities the Client intended to trade; (ii) the sale of a security when it should have been purchased; (iii) the purchase of a security when it should have been sold; (iv) the purchase or sale of the wrong security; (v) the purchase or sale of a security contrary to regulatory restrictions or Client investment guidelines or restrictions; and (vi) incorrect allocations of securities. All reasonable efforts should be made to promptly correct trade errors to minimize the disruption to affected Clients. Action should be appropriate for the facts and circumstances at hand and should be carefully executed so as not to worsen the situation. To the extent that a trade error is caused by a counterparty, such as a broker or agent, the Firm shall seek to recover any related trade error losses from such counterparty. Once an incident has been determined to be a trade error, the financial impact of the error is calculated and verified. The basis for each calculation is related to the facts and circumstances of the trade error.

In limited circumstances, we will refrain from voting Proxies where we believe that doing so would be in the best interests of our Clients, taking into consideration the cost of voting the Proxies and the anticipated benefit to our Clients. Conflicts of interest may arise between the interests of the Clients on the one hand and us or our affiliates on the other hand. If we determine that we have, or are perceived to have, a conflict of interest when voting proxies, we will vote in accordance with our proxy voting policies and procedures.

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Generally, Clients may not direct our vote in a particular solicitation. Clients or Investors may obtain a copy of our Proxy voting policies and procedures upon request. Investors may obtain any of our Proxy voting records upon request.