Breach Inlet Capital Management, LLC: investment adviser

B. Types of Advisory Services Portfolio Management Services Partnerships BICM is investment manager with respect to Breach Inlet Capital, LP (the “Partnership”) a private investment fund organized as a Delaware limited partnership. BICM is responsible for investing and reinvesting the capital of the Partnership in securities, financial instruments and/or other assets in accordance with the investment objectives, policies and guidelines set forth in the offering and governing documents of the Partnership. Information about the Partnership is set forth in its offering document. Services Limited to Specific Types of Investments BICM generally limits its investment advice to equities, exchange-traded funds (ETFs) and non-U.S. securities, although BICM primarily recommends domestic equities to its clients. BICM may use other securities as well to help diversify a portfolio when applicable.

C. Client Tailored Services and Client Imposed Restrictions We generally provide investment advice to the Partnership in accordance with the investment objectives, policies and guidelines set forth in the offering and governing documents, and not in accordance with the individual needs or objectives of any particular investor in the Partnership. Investors generally are not permitted to impose restrictions or limitations on the management of the Partnership. The Partnership has created and offers, and will in the future offer, various classes of interests with different terms and conditions, including, without limitation, fees, performance allocations and withdrawal rights. The Partnership had previously created a Founders Class made up of limited partners holding Founders Class Capital Accounts (as defined in the Partnership’s limited partnership agreement). The Founders Class is not being offered. The Partnership had previously created an Anchors Class made up of limited partners holding Anchor Class Capital Accounts (as defined in the Partnership’s limited partnership agreement). The Anchors Class is not being offered. The Partnership had previously created a Class C made up of limited partners holding Class C Capital Accounts (as defined in the Partnership’s limited partnership

agreement). The Class C is not being offered. Class D Interests are issued to current limited partners (in the case of additional subscriptions) and new limited partners. The Partnership and BICM may also enter into side letter agreements and other arrangements with certain investors that alter, modify or change the terms of the interests held by those investors. Among other things, these agreements or arrangements may entitle certain investors to specific reports or notice of specified events, including reports listing positions and related risk statistics at a level of detail or frequency not provided to other investors.

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

E. Assets Under Management BICM has the following assets under management: Discretionary Amounts: $227,650,975

Non-discretionary Amounts: $0

Date Calculated: December 31, 2025

such limited partner’s loss carry forward account for such Founders Class capital account and (ii) 10% per annum of the amount by which, generally, the Partnership’s net profits allocated to the limited partner’s Anchor Class capital account for the current calendar year exceeds the balance in such limited partner’s loss carry forward account for such Anchor Class capital account and (iii) 20% per annum of the amount by which, generally, the Partnership’s net profits allocated to the limited partner’s Class C and/or Class D capital account for the current calendar year exceeds the balance in such limited partner’s loss carry forward account for such Class C or Class D capital account (explained further within the Partnership’s private placement memorandum). Net profit includes unrealized appreciation or depreciation of both marketable and non-marketable investments. BICM has received capital from an initial strategic investor (the “Initial Strategic Investor”). The Initial Strategic Investor has invested in the Partnership and was subject to an extended lock-up period and, in return, the Initial Strategic Investor is entitled to receive a portion of the Management Fee and any Performance Allocation.

The Partnership’s general partner and its affiliates have made contributions to the Partnership’s investment program through an investment in the Partnership. Such affiliated investors will not bear any Management Fee or Performance Allocation but will share pro rata in all other applicable expenses of the Partnership.

B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the limited partner’s capital accounts in an amount equal to one fourth of 1.00% of the account balance, which amount is calculated and paid in advance on the first business day of each calendar quarter based on the account balance as of such day. Performance-based fees are withdrawn directly from the limited partner’s capital accounts at the end of each calendar year generally equal to 5.00% with respect to Founder Class interests; 10.00% with respect to Anchor Class interests; and 20.00% with respect to Class C and Class D interests, of the increase in value above the high water mark.

C. Client Responsibility for Third Party Fees The Partnership bears the expenses of its organization and offering, as further described in the Partnership’s Limited Partnership Agreement (including legal and accounting fees, printing costs, travel, “blue sky” filing fees and expenses and out-of-pocket expenses). The Partnership bears all (i) costs and expenses related to its investment program, including expenses related to proxies, underwriting and private placements, data feed hardware and software, research, trade publications, brokerage commissions, interest on debit balances or borrowings, custody fees and any withholding or transfer taxes imposed on the Partnership; and (ii) all out-of-pocket costs of the administration of the Partnership, including accounting, audit and legal expenses, costs of any litigation or investigation involving the Partnership’s activities and costs associated with reporting and providing information to existing and prospective limited partners; provided, however, that the amount of fund Expenses (including, for this purpose, the amount of amortized organizational expenses, but not including the Management Fee, the trading expenses, borrowing expenses or direct costs associated with the Partnership’s portfolio) shall not exceed 0.50% of annual average net asset value of the Partnership (applied to each capital account of a limited partner on a pro rata basis for the portion of such year the capital account was in existence). The Partnership does not have its own separate employees or office, and it does not reimburse the general partner or BICM for salaries, office rent and other general overhead costs of the general partner or BICM.

D. Prepayment of Fees Asset-based portfolio management fees are collected in advance. Generally, for asset-based fees paid in advance, the fee refunded is determined on a pro rata basis for the amount of time such withdrawal amount was invested during the calendar quarter.

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

We address these conflicts through full and fair disclosure in the applicable governing, offering and/or account documents and this Brochure as well as by having policies and procedures designed to ensure that all clients treated fairly duty in terms of investment allocation, brokerage execution and valuation and in keeping with BICM’s fiduciary duty. Side-By-Side Management The terms of performance-based compensation for the Partnership and other client accounts, including private funds that BICM may manage in the future, may differ. Such differences could incent us to favor a client account over another with respect to investment allocations. These potential conflicts would be mitigated by the fact that such accounts will generally invest and trade pari passu with the Partnership. BICM may in the future also manage accounts that are not assessed performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because BICM and/or its supervised persons have an incentive to favor accounts for which BICM receives a performance-based fee. BICM addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. BICM seeks best execution and upholds its fiduciary duty for all clients.

Investment Strategies BICM may use long-term trading, short-term trading, short sales and options trading (including covered options, uncovered options, or spreading strategies). Except as otherwise set forth in investment management agreements (and subject to the terms, conditions, restrictions and limitations set forth therein), BICM will generally also use the methods of analysis and investment strategies described for the Partnership. The Partnership The investment objective of the Partnership is to seek long term capital appreciation and to outperform the Russell 2000 Value Index over the long term by investing in undervalued securities of companies having catalysts to grow intrinsic value. BICM seeks to achieve the Partnership’s objective by creating a portfolio primarily of “small cap transformations”, as discussed below, and generally expects the Partnership to hold positions for at least one year. BICM’s investing principles act as the backbone of the Partnership’s strategy. First, BICM views securities as ownership stakes in businesses, and not merely tradable pieces of paper. Second, BICM believes that market prices are often determined by irrational trading, causing securities to be mispriced and markets to be inefficient in the short-term. BICM plans to identify these mispriced securities through a disciplined process and estimate their fair values with fundamental analysis. Additionally, BICM intends to concentrate the Partnership’s investments in securities that it best understands and that it believes are most severely mispriced. BICM also believes that the chances of higher returns should be improved with multiyear targeted holding periods. Further, to reduce the impact of bear markets and recessions until portfolio

securities approach fair values, BICM intends to apply relatively conservative portfolio management, which may include holding cash and utilizing hedges. BICM believes that the Partnership’s core positions possess several key attributes. First, BICM believes that these portfolio companies have market-leading positions with protective barriers to entry that allow for relatively high returns on invested capital (“ROIC”). Second, these companies generally are led by experienced, properly incentivized management teams with proven track records of allocating capital. BICM believes that companies having high ROIC and managed by proven capital allocators often experience substantial growth in intrinsic value. BICM intends to focus on securities trading at significant discounts relative to peers and historical valuations. These investments also typically have visible catalysts that should ultimately close these discounts in valuation. BICM generally avoids sectors where it has less expertise or is otherwise uncomfortable with estimating potential downsides (e.g., energy, health care, and technology). BICM generally targets “small cap transformations”, which it defines as companies that (1) have less than $5 billion of market capitalization and (2) are experiencing transformative changes with potential to create substantial value. BICM generally favors small cap companies because it views these companies as being subject to less research coverage and as having a smaller pool of potential buyers, creating the potential for an informational edge. While small cap companies may have less market liquidity and greater price volatility, BICM believes that these conditions also allow for the greater potential for mispricing and trading opportunities. Additionally, BICM believes that investments in small cap companies are more likely to open direct access to companies’ senior management. Lastly, BICM believes that small cap companies tend to operate with less complexity, allowing for relevant risks to be more easily quantified. BICM believes that “transformations” often go unrecognized or unappreciated by the general market because it is difficult to quantitatively screen for such events, and that these “transformation” catalysts provide visible paths to grow intrinsic value, often over a period of more than one year. In addition to “small cap transformations”, BICM may opportunistically supplement the Partnership with special situations when it believes these are significantly mispriced. The Partnership’s portfolio generally consists of two components: (1) cash and (2) securities. BICM views cash as a valuable call option on every asset since cash has no expiration date or strike price. At any time, as much as 25% of the Partnership’s net asset value may be comprised of cash if, for example, compelling opportunities are scarce. BICM intends to concentrate the Partnership’s securities in a relatively small number of “small cap transformations” in North America. BICM also shorts securities that it believes are overvalued. BICM generally expects the Partnership’s net exposure to range between 30% and 80%. BICM uses what it believes to be a robust and repeatable process to identify, evaluate and position the Partnership’s investments. Candidates for research may come from a variety of sources, including BICM’s network, periodicals, proprietary screens, watch lists, and recycled past investments. Through fundamental analysis, BICM determines whether the investment opportunity is actionable or should be placed on its watch list. This fundamental analysis includes a careful review of public information followed by discussions with the company’s management, suppliers, customers and competitors, as available, in order to garner a full understanding of the economic drivers, industry dynamics, potential catalysts and risk factors. If the investment’s expected risk-adjusted return is identified as being above BICM’s threshold, the size of the Partnership’s potential investment is then determined based on risk-adjusted return, liquidity, and existing exposures within the Partnership. A position may be sold when, in BICM’s opinion, an exposure limit or price target is reached, the company’s fundamentals change, or sale is otherwise appropriate to allow for an alternative opportunity. BICM generally defines “risk” as the potential for the permanent loss of capital. BICM accepts short-term price volatility and seeks long-term returns. BICM’s principal sources of internal risk management are (1)

security selection, (2) portfolio construction and (3) transparent infrastructure. When selecting securities, BICM seeks to apply conservative assumptions, require substantial margins of safety, hedge undesired risks, regularly reassess its own theses, and diversify across sectors. In order to construct a conservative portfolio, BICM intends to limit industry net exposure to 30%. Additionally, BICM intends to avoid recourse leverage, while often maintaining cash and shorting securities. BICM overlays careful security selection and conservative portfolio management with a transparent infrastructure that includes monthly third-party valuations, quarterly reports to limited partners, and annual audited financials, the latter two which are further described below. The Partnership may employ the investment strategies and methods of analysis listed above, but its strategies and analysis are further described in its Private Placement Memorandum. Investors are encouraged to carefully review that document.

B. Material Risks Involved There can be no assurance that we will achieve our investment objective or that our investment strategies will be successful. Our investment program involves a substantial degree of risk, including risk of complete loss. Nothing in this Brochure is intended to imply, and no one is or will be authorized to represent, that our or the Partnership’s investment program is low risk or risk free. Our investment advisory services are appropriate only for sophisticated persons who fully understand and are capable of bearing the risks of investment, including the risk of complete loss of their investment. The various risks outlined below are not the only risks that may be associated with our investment strategies and processes. Prospective investors and clients are urged to consult with their own independent financial, legal and tax advisors before making an investment decision. With respect to the Partnership, the following risks are qualified in their entirety by the risks set forth in the applicable offering documents. Investing in securities involves a risk of loss that you, as a client or investor, should be prepared to bear. General Risks Related to Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Position Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. General Risks Related to Investment Strategies Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the longterm investment strategy can expose clients and investors to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited

to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. See below for additional description of the risks entailed with short sales. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Use of short sales and options trading generally holds greater risk, and clients and investors should be aware that there is a material risk of loss using any of those strategies. The Partnership Investment Judgment; Market Risk The profitability of a significant portion of the Partnership’s investment program depends to a great extent upon correctly assessing the future course of the price movements of securities and other investments. There can be no assurance that BICM will be able to predict accurately these price movements. With respect to the investment strategy utilized by the Partnership, there is always some, and occasionally a significant, degree of market risk. Illiquidity The investments made by the Partnership may be very illiquid, and consequently the Partnership may not be able to sell such investments at prices that reflect the Partnership’s general partner’s assessment of their value, or the amount paid for such investments by the Partnership. Illiquidity may result from the absence of an established market for the investments as well as legal, contractual or other restrictions on their resale by the Partnership and other factors. Furthermore, the nature of the Partnership’s investments may require a long holding period prior to profitability. The Partnership agreement authorizes the general partner to make distributions in kind of securities in lieu of or in addition to cash. In the event the general partner makes distributions of securities in kind, such securities could be illiquid or subject to legal, contractual and other restrictions on transfer. Short Sales The Partnership will enter into transactions, known as “short sales,” in which it sells a security it does not own in anticipation of a decline in the market value of the security. Short sales by the Partnership that are not made “against the box” theoretically involve unlimited loss potential since the market price of securities sold short may continuously increase. The Partnership may mitigate such losses by replacing the securities sold short before the market price has increased significantly. Under adverse market conditions, the Partnership might have difficulty purchasing securities to meet its short sale delivery obligations and might have to sell portfolio securities to raise the capital necessary to meet its short sale obligations at a time when fundamental investment considerations would not favor such sales. Economic and Political Risks A portion of the Partnership’s assets may be invested in countries where the market economy is relatively less developed. Although the recent general trend in such countries has been towards more open markets and the promotion of private business initiatives, no assurance can be given that the governments of these countries will continue to pursue such policies or that such policies may not be altered significantly. Political instability, economic distress, the difficulties of adjustment to a market

economy, social instability, organized crime, or other factors beyond BICM’s control could have a material adverse effect on the performance of the Partnership. Leverage Subject to applicable margin and other limitations, the Partnership may borrow funds in order to make additional investments and thereby increase both the possibility of gain and risk of loss. Consequently, the effect of fluctuations in the market value of the Partnership’s portfolio would be amplified. Interest on borrowings will be a portfolio expense of the Partnership and will affect the operating results of the Partnership. In addition, the Partnership could potentially create leverage via the use of instruments such as options and other derivative instruments. Turnover The Partnership may invest on the basis of short-term market considerations. The portfolio turnover rate of the Partnership may be significant, potentially involving substantial brokerage commissions and fees. Currency Risk The Partnership may invest its capital in securities that are custodied in different countries, the prices of which are determined with reference to currencies other than the U.S. dollar. The Partnership values its securities in U.S. dollars and therefore may be affected by fluctuations in currency values. Concentration of Holdings Although BICM has adopted informal guidelines on diversification, those guidelines are subject to change by BICM, and there are no limits on BICM’s investment discretion that require diversification by issuer, industry, or market or that impose position size limitations. At any given time, it is therefore possible that BICM may select positions that are concentrated in a particular market or industry, or in a limited number or type of securities. Limited diversity could expose the Partnership to losses disproportionate to general market movements if there are disproportionately greater adverse price movements in those positions. Diversification Since the Partnership’s portfolio will not necessarily be widely diversified, the investment portfolio of the Partnership may be subject to more rapid changes in value than would be the case if the Partnership were required to maintain a wide diversification among companies, securities and types of securities. Counterparty Risk The Partnership is subject to the risk that counterparties of derivative contracts and other instruments in which it invests and trades may default on their obligations under those instruments and that certain events may occur that have an immediate and significant adverse effect on the value of those instruments. Some of the markets in which the Partnership effects its transactions are over-thecounter or inter-dealer markets. The participants in such markets are typically not subject to credit evaluation by an exchange or clearing organization and regulatory oversight as are members of exchangebased markets. The Partnership therefore is exposed to a greater risk that a counterparty will not timely settle a transaction or otherwise perform its obligations in accordance with contractual terms and conditions because of a dispute over the terms of the contract (whether or not bona fide), or because of a credit or liquidity problem, thus causing the Partnership to suffer a loss. Such counterparty risk is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Partnership has concentrated its transactions with a single or small group of counterparties. These risks may differ materially from those entailed in exchange-traded transactions, which generally are backed by clearing organization guarantees, daily marking-to-market and settlement of positions and segregation and minimum capital requirements applicable to intermediaries. Although the Partnership intends to enter into transactions only with counterparties that BICM believes to be creditworthy, will attempt to reduce the Partnership’s exposure by obtaining collateral in appropriate cases and will pursue any available remedies under any of these contracts, there can be no assurance that a counterparty will not default and that the Partnership will not sustain a loss on a transaction as a result. The Partnership is not restricted from dealing with any particular counterparty or from concentrating any or all of its transactions with one counterparty. Concentration of transactions with a limited number of counterparties could

increase the potential for losses by the Partnership. The Partnership is subject to the risk of failure of any of the exchanges on which its positions trade or of their clearinghouses. Cybersecurity Risk, Information Technology & Electronic Communications BICM; the Partnership; respective affiliates; and service providers, including Abacus Group LLC, which is BICM’s information technology service provider; and other market participants increasingly depend on information technology and electronic communications systems to conduct business functions, including through expanded remote work activities. These systems are subject to a number of different threats or risks that could adversely affect the Partnership and investors, despite efforts of BICM and the Partnership’s service providers to adopt technologies, processes and practices intended to mitigate these risks and protect the security of their computer systems, software, networks and other technology assets, as well as the confidentiality, integrity and availability of information belonging to the Partnership and investors. Moreover, notwithstanding the diligence that BICM or its affiliates may perform on service providers, it may not be able to verify the risks or reliability of such information technology systems. BICM, the Partnership and respective affiliates and service providers are subject to risks associated with a breach in cybersecurity. “Cybersecurity” is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage and disruption to hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. BICM, its affiliates and its information and technology systems are vulnerable to damage or 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. Although BICM has implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, BICM or an affiliate may have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in BICM’s, the Partnership’s or any of BICM’s respective affiliates’ 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 BICM’s or its affiliates’ reputation, subject any such entity and their respective affiliates to legal claims and otherwise affect its business and financial performance. Such damage or interruptions to information technology systems may cause losses to the Partnership or individual investors by interfering with the operations of BICM and its affiliates (or service providers). The Partnership may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, adverse investor reaction, the dissemination of confidential and proprietary information and reputational damage. Any such breach could expose BICM, the Partnership, and BICM’s respective affiliates to civil, legal or regulatory liability as well as regulatory inquiry and/or action, and the Partnership may be required to indemnify BICM and its affiliates against any losses incurred in connection therewith. Cybersecurity issues and risks are currently a major focus area of regulatory authorities. Force Majeure & Catastrophic Risks BICM and the Partnerships may be subject to operational risk from unforeseeable and uncontrollable catastrophic events, including fires, floods, earthquakes, adverse weather conditions and related power outages, water shortages or other damage caused by such events, changes in law, eminent domain, wars, riots, terrorist attacks, epidemics, pandemics, and other public health issues, and other similar risks, which may be uninsurable or insurable at rates that the Firm deems uneconomic. These events could result in loss and litigation, among other potentially detrimental effects. Certain force majeure events, including an outbreak of an infectious disease or armed conflict, could have a broader negative impact on the world economy and international business activity generally. In response to recent armed conflicts and terrorist events, for example, the United States, the European Union and various other countries have announced, and continue to announce and expand, sanctions against or targeting certain

jurisdictions, persons, and companies. These sanctions currently include, among others, restrictions or bans on selling or importing goods, services or technology in or from specified jurisdictions, bans on certain energy imports, and travel bans and asset freezes impacting connected individuals and political, military, business and financial organizations in specified jurisdictions. Such conflicts have led to, and may continue to lead to, significant political, geopolitical, economic and market turmoil and volatility, including dramatic increases in oil and gas prices and supply chain disruptions. Supply chain disruptions have resulted in increased shipping costs, freight surcharges, shipment delays, reduced shipping capacity and caused other significant supply chain impacts. It is not possible to predict the broader consequences of such conflicts or the sanctions imposed or applied as a result thereof, which could include further sanctions, embargoes, regional instability, geopolitical shifts, conflicts and adverse effects on macroeconomic conditions, currency exchange rates and financial markets, all of which could impact the Partnership’s or any portfolio investment’s business, financial condition and results of operations. Disruption in the Financial Services Industry BICM’s ability to make and consummate investments and engage in other activities and transactions could be adversely affected by the actions and stability of banks and other financial institutions. Banks and financial institutions are interrelated as a result of trading, clearing, counterparty and various other relationships. As a result, defaults or failures by, or even rumors or questions about or regarding, one or more banks or financial institutions, or the industry generally, have historically led to market-wide liquidity and other problems. Losses of depositor, creditor and counterparty confidence could lead to losses or defaults by clients and their investments and other banks and financial institutions (including banks and financial institutions that clients and their investments deal or interact with). There is no guarantee that the Department of Treasury, Federal Deposit Insurance Corporation, Securities Investor Protection Corporation and/or the Federal Reserve will provide access to uninsured funds in the future in the event of the closure of other financial institutions (or do so in a timely fashion), and it is uncertain whether these steps by the government will be sufficient to calm the financial markets, reduce the risk of significant depositor withdrawals at other institutions and thereby reduce the risk of additional bank failures. AI Tools Risk. BICM utilizes AI tools to assist in its research and analysis, including both standalone tools such as publicly-available large language models (LLMs) and AI-driven functionalities embedded within third-party research products to which the firm subscribes. These AI tools leverage statistical machine learning techniques that have inherent limitations. For example, AI-generated outputs may include inaccuracies, misinterpretations, or "hallucinations," wherein the model presents fabricated information as fact. To mitigate these risks, the firm employs a structured research process that incorporates multiple safeguards, such as cross-referencing AI-generated insights against original source documents, verifying data through independent analysis, and applying human oversight to evaluate the reliability of AI-assisted outputs. However, despite these precautions, the potential for errors, omissions, or biases remains. Accordingly, the firm cannot guarantee that all AI-generated insights will be entirely accurate or free from error, nor can it eliminate the risk that such errors may inadvertently impact research conclusions or investment decisions. Clients and investors should be aware of these limitations when considering the firm’s research and advisory services. The Partnership’s risks are further described in its Private Placement Memorandum. Investors are encouraged to carefully review that document.

C. Risks of Specific Securities Utilized Use of short sales and options trading generally holds greater risk of capital loss. Clients and investors should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency.

Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (up to a 100% loss). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Private Partnerships often engage in leveraging and other speculative investment practices that may increase the risk of investment loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; may involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Derivatives Derivative instruments, or “derivatives,” include futures, options, swaps, structured securities and other instruments and contracts that are derived from, or the value of which is related to, one or more underlying securities, financial benchmarks, currencies or indices. Derivatives allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark currency or index at a fraction of the cost of investing in the underlying asset. The value of a derivative depends largely upon price movements in the underlying asset. Therefore, many of the risks applicable to trading the underlying asset are also applicable to derivatives of such asset. However, there are a number of other risks associated with derivatives trading. For example, because many derivatives are “leveraged,” and thus provide significantly more market exposure than the money paid or deposited when the transaction is entered into, a relatively small adverse market movement can not only result in the loss of the entire investment but may also expose the Partnership to the possibility of a loss exceeding the original amount invested. Derivatives may also expose investors to liquidity risk, as there may not be a liquid market within which to close or dispose of outstanding derivatives contracts, and to counterparty risk. The counterparty risk lies with each party with whom the Partnership contracts for the purpose of making derivative investments. In the event of the counterparty’s default, the Partnership will only rank as an unsecured creditor and risks the loss of all or a portion of the amounts it is contractually entitled to receive. Foreign Securities Investments in foreign securities involve certain factors not typically associated with investing in U.S. securities, such as risks relating to (i) currency exchange matters, including fluctuations in the rate of exchange between the U.S. dollar (the currency in which the books of the Partnership are maintained) and the various foreign currencies in which the Partnership’s portfolio securities will be denominated and costs associated with conversion of investment principal and income from one currency into another; (ii) differences between the U.S. and foreign securities markets, including the absence of

uniform accounting, auditing and financial reporting standards and practices and disclosure requirements, and less government supervision and regulation; (iii) political, social or economic instability; (iv) imposition of foreign income, withholding or other taxes; and (v) the extension of credit, especially in the case of sovereign debt. Commodities and Futures The Partnership may trade on a limited basis in commodities and futures. Such trading activity is regulated by the Commodity Futures Trading Commission (the “CFTC”). Pursuant to an exemption from registration under CFTC regulations, neither the general partner nor BICM is required to register, and is not registered, with the CFTC or the National Futures Association (“NFA”) as a commodity pool operator or as a commodity trading advisor. To comply with the exemption, the general partner and BICM are subject to specific limitations on the amount of commodities and futures that they can trade on behalf of the Partnership. Should the Partnership’s investments in commodities or futures instruments exceed the limits provided by the applicable exemption from registration, the general partner and/or BICM will either have to register with the NFA or cease providing commodity interest trading advice to the Partnership and liquidate the Partnership’s holdings of commodities and futures which could result in losses and additional costs to the Partnership. The Partnership may invest in those types of securities described above, as well as others more fully detailed in its private placement memorandum. Investors should carefully review the private placement memorandum regarding the types of securities applicable to the Partnership’s investing approach and the associated risks. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client or investor, should be prepared to bear.

C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Chris Colvin is the Manager of the Partnership, a hedge fund. Chris Colvin is also the principal of CDC Equity, LLC, the general partner of the Partnership’s general partner, Breach Inlet Genpar, LP. Mr. Colvin also controls the Partnership’s general partner, Breach Inlet Genpar, LP. As a fiduciary, BICM has an obligation to provide investment management services to each Fund or client in accordance with the investment objectives, policies, guidelines, restrictions and limitations set forth in the applicable Fund or client governing, account and/or disclosure documents. However, except as otherwise provided in the Firm’s offering and governing documents, BICM and its Supervised Persons do engage, and may in the future engage, in other business activities.

D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections BICM neither utilizes nor selects third-party investment advisers. All assets are managed by BICM management.

Subject to the terms of the code of ethics, we generally impose restrictions on employees relating to the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons. The Code of Ethics covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. BICM's Code of Ethics is available free upon request to any client or prospective client and any investor or prospective investor in the Partnership. We also maintain certain

policies and procedures designed to prevent supervised persons from misusing material non-public information.

B. Recommendations Involving Material Financial Interests Chris Colvin is the Manager of the Partnership, a hedge fund. Chris Colvin is also the principal of CDC Equity, LLC, the general partner of the Partnership’s general partner, Breach Inlet Genpar, LP. Currently, the Partnership is BICM’s only client. However, should BICM obtain additional clients, BICM will recommend investments in the Partnership to those clients for which investment in the Partnership is suitable. This presents a conflict of interest in that BICM or its related persons may receive more compensation from investment in the Partnership than from other investments. Nevertheless, BICM acts in the best interest of the client consistent with its fiduciary duties. Issuers, or affiliates of issuers, whose securities are holdings of the Partnership’s portfolio can and may be investors in the Partnership. Such issuers or their affiliates who are also investors in the Partnership do not receive favorable treatment relative to other investors, such as additional transparency or terms. In addition, BICM acts in the best interest of the Partnership in making investment decisions with respect to investments in such issuers.

C. Investing Personal Money in the Same Securities as Clients Supervised persons of BICM do not generally buy or sell securities for themselves that they also recommend to clients, although supervised persons do and may invest in the Partnership. BICM will always document any transactions in single name equities and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold.

D. Trading Securities At/Around the Same Time as Clients’ Securities Supervised persons of BICM do not generally buy or sell securities that they also recommend to clients, although supervised persons do and may invest in the Partnership. BICM will never engage in trading that operates to the client’s disadvantage if representatives of BICM buy or sell securities at or around the same time as clients.

BICM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. We may cause our clients to pay higher commissions to brokers believed to offer superior service under the circumstances, including brokers that provide investment research and analysis to their clients. Accordingly, when we determine in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the overall services provided to our clients, including internally-developed research and other services provided by such

broker, we may cause our clients to pay commissions to such broker in an amount greater than the amount another broker might charge. BICM will generally recommend clients use and effect transactions through the Partnership’s prime broker. Research and Other Soft-Dollar Benefits BICM has no formal soft dollar program or arrangement. BICM has arrangements with certain brokers where a portion of the commissions paid for execution is allocated for research and other services. BICM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and BICM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. BICM benefits by not having to produce or pay for the research, products or services, and BICM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that BICM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Brokerage for Client Referrals From time to time, our third-party brokers may provide opportunities for us to be introduced to potential investors. Brokers or their affiliates may provide capital introduction or other placement services to the Partnership and BICM (with or without separate charges for such other services). Such “capital introduction” opportunities may influence our decision to use (or continue to use) the services of these brokers, rather than selecting brokers solely based on the Partnership’s interest in receiving most favorable execution. BICM may select broker-dealers that provide capital introduction opportunities provided BICM is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of investors. Clients Directing Which Broker/Dealer/Custodian to Use BICM does not permit its clients to direct it to execute transactions through a specified broker-dealer.

B. Aggregating (Block) Trading for Multiple Client Accounts If BICM buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, BICM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. BICM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). The Partnership is currently BICM’s only client. We generally allocate investment opportunities among our clients in a fair and equitable manner based upon, among other things, the investment objectives, guidelines and restrictions, risk profiles, financial conditions and tax status of each client. If each participating client receives less than its full allocation, then each participating client generally receives its pro rata portion of the executed order. Under certain circumstances, we have discretion to utilize alternative allocation procedures, provided that all participating clients are treated fairly and equitably.

C. Content and Frequency of Regular Reports Provided to Clients We generally provide (or cause the administrator or auditor to provide) to investors, as soon as reasonably practicable after the end of each fiscal year, annual reports containing financial statements audited by the Partnership’s independent auditor and any other information that any investor reasonably requests relating thereto. We also provide investors with monthly performance updates, quarterly investor letters, and may provide other periodic notices and reports relating to the performance and activities of the Partnership. All such statements and reports are written.

However, an adviser need not comply with such requirements with respect to pooled investment vehicles subject to audit and delivery if each pooled investment vehicle: (i) is audited at least annually by an independent public accountant; and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to their investors, all limited partners, members or other beneficial owners within 120 days of its fiscal year-end. BICM will ensure that such audits are conducted of the Partnership and that the resulting financial statements are distributed to investors. Investors should carefully review those statements for accuracy.

Our general policy is to vote regularly recurring matters as recommended by the issuer’s board of directors, but certain circumstances may cause us to vote against such proposals (which we will decide on a case-by-case basis). Investors generally may not direct or otherwise influence our vote with respect to any particular proxy solicitation. BICM generally will promptly review proxy materials to evaluate issues presented including the identification of any material conflicts of interest involving us and the proxy voting process and make all determinations with respect to the proxy voting policy. BICM will analyze and determine whether any conflict of interest is material. A conflict of interest will be considered material to the extent that such conflict has the potential to influence our decision-making in voting a proxy. If a material conflict of interest is identified, we may use one or more methods to resolve or otherwise mitigate such conflict, including: (i) disclosing the conflict to the applicable client and investors and obtaining its consent before voting (ii) suggesting to client that it engage another party to vote the proxy on its behalf, (iii) engaging a third party

to recommend a vote with respect to the proxy based on the application of our proxy voting guidelines, or (iv) such other method as is deemed appropriate under the circumstances, given the nature of the conflict. We will maintain a written record of the method used to resolve or otherwise mitigate any material conflict of interest. Clients may obtain copies of our proxy voting policy, together with information regarding how we have voted past proxies, by contacting us.