Settian Capital LP: investment adviser

Investment management duties were transferred to Settian Capital LP in May of 2018. All entities referenced above are or were, as applicable, under the common control of Karl K. Segerberg (“Kristofer Segerberg”). The investment mandate of the Private Fund is described in the fund’s Private Placement Memorandum or other offering document, as applicable (“Offering Document”). Settian Capital provides discretionary investment advisory services to both the Private Fund and its separate account clients pursuant to applicable investment management agreements. A separate account client may impose restrictions upon investing in certain securities or types of securities at the inception of the relationship with Settian Capital or at any other time by writing to Kristofer Segerberg using the address provided on the front of this Brochure or by email at segerberg@settian.com. As of December 31, 2025, Settian Capital managed approximately $156 million in discretionary assets under management.

Settian Capital may also receive annual performancebased compensation as disclosed in the relevant SMA agreement and in accordance with all applicable laws. Management fees and performance-based fees are negotiable. Unless otherwise specified in the client agreement, client fees are generally deducted from client investment accounts. However, any client who wishes to be billed separately may contact Settian Capital at the number on the front of this Brochure. In the event of the termination of an investment management agreement between Settian Capital and a client, the client will receive a refund of pre-paid fees attributable to any period after termination, pursuant to the terms of such investment management agreement. Management fee refunds on intraperiod and partial withdrawals are based on the number of days left in the period and the amount withdrawn. These refunds are credited against the next management fee charged. Management fees on intra-period and partial withdrawals are not refunded where the cost of processing exceeds the amount due, as determined solely by Settian Capital.

Client assets, which are from time to time not invested in other securities, are generally invested in cash equivalents including demand deposits, time deposits, money market instruments or other short-term investment vehicles. In such cases, the client may pay the money market fund or other short-term investment vehicle an advisory fee on the assets invested in the fund or short-term investment vehicle in addition to the advisory fee paid to Settian Capital. The Private Fund and SMAs will generally bear expenses in connection with their trading and investment activities, which will generally include brokerage costs and other fees and expenses involved with their respective trading activities. Please see Item 12 below for a more detailed discussion of brokerage expenses and practices. The Private Fund also bears additional expenses associated with organizing, administering and continually offering the fund. Such expenses include legal, accounting, escrow, auditing, recordkeeping, administration, fund accounting, computer, clerical expenses, insurance, expenses incurred in preparing reports and tax information to investors and regulatory authorities, expenses of printing and dispatching materials and reports to investors, duplicating expenses, mailing costs, courier costs and filing fees, where applicable. These expenses are in addition to those also assessed for Settian Capital firm expenses. From time to time, Settian Capital may invest client accounts in an ETF or another pooled investment vehicle. Such investments are most likely to occur for cash management reasons, but Settian Capital may also choose to utilize these funds for other investment reasons when it believes that doing so is in the best interest of the clients. When Settian Capital invests an account in a pooled investment vehicle, the portion of each account that is invested in the fund will also be subject to additional fund-level expenses that would not exist for direct investments, including the fund-level expenses discussed in the paragraph above.

The variation of performance-based compensation structures among Settian Capital’s clients may create an incentive for Settian Capital to direct the best investment ideas to, or to allocate or sequence trades in favor of, clients that pay or allocate performance-based compensation. Settian Capital has procedures designed and implemented to provide reasonable assurance that all clients are treated fairly. Specifically, Settian Capital maintains procedures designed to address the allocation of investment opportunities among clients as well as the manner in which investments are valued. See Item 12. In addition, the Private Fund retains a third-party administrator which independently calculates, among other things, profit/loss allocations, management fees and performance-based fees.

While Settian Capital has not determined a specific minimum investment for a separately managed account, Settian Capital’s services are generally geared towards family offices, institutional investors and platforms, wealthy individuals and others sophisticated investors whose assets under management allow Settian Capital to fully implement its investment management strategy.

Settian Capital may employ leverage in its investment program. Settian Capital’s approach to portfolio management may be categorized by: 1. Fundamental Stock Selection: Settian Capital pursues a disciplined equity selection process emphasizing fundamental analysis of a company’s prospects for delivering improving returns on capital. In selecting equity securities for investment, Settian Capital may consider a number of different factors including, without limitation, one or more of the following: •

Review of fundamental characteristics indicating financial strength or weakness, such as profit growth analysis, business franchise characteristics, residual/transfer asset values, market position analysis, review of distribution systems, assessments of intellectual property assets and similar characteristics;

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Consideration of fundamental value strategy characteristics, such as cash flow or asset value analysis, review of exit alternatives, and non-traditional assessments of underappreciated, undervalued or hidden assets or future opportunities identified through research;

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Identification of catalysts for value realizations on a micro basis such as management changes, restructurings, new product cycles, or other micro developments and considerations; and

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Review of opportunities in light of business cycles (including, without limitation macro boom-bust reflexive sequences or cycles, the credit cycle, central bank behavior, currency markets and other critical global macro influences).

2. Concentration: Settian Capital intends to be invested on a more concentrated basis, which may cause investment performance to be significantly more volatile than would otherwise be the case.

The Investment typically expects the top 10 positions to be 40-60% of Settian Capital’s portfolio, though this may fluctuate over time. 3. Net exposure management: Settian Capital believes that portfolio net exposure may vary as may be appropriate in different market conditions. The relative mix between long and short positions may vary over time depending on the investment opportunities that are identified and Settian Capital’s view concerning the prospects for global economies and overall direction of global markets. Settian Capital believes that +60-100% net long may be appropriate in sustainable bull markets and (-20%) to (+20%) may be appropriate in sustainable bear markets; however, decisions of net exposure are left to the discretion of Settian Capital. There is no guarantee that Settian will choose to pursue short positions over any time horizon. In addition to the foregoing, in support of its fundamental research, Settian Capital may utilize technical analysis and any other methodology determined by Settian Capital as part of its research and investment selection process. In carrying out Settian Capital’s investment strategy, Settian Capital may invest in exchange traded funds and exchange traded notes, including commodity and fixed-income related exchange traded funds and exchange traded notes. Settian Capital may also purchase or sell exchange traded options for hedging purposes and/or as part of Settian Capital’s objective of obtaining exposure to the equity markets. In addition to, or in connection with, the foregoing, Settian Capital may use leverage in its investment program. The amount of leverage that may be employed by Settian Capital at a given time will be determined by Settian Capital. There are no material limitations on the securities or instruments in which Settian Capital may invest, the markets in which Settian Capital may trade, the market sectors in which the underlying issuers may operate, or the trading strategies that Settian Capital may utilize. However, Settian Capital expects to invest primarily in liquid equities and equity-linked instruments. Settian Capital will generally not invest more than 20% of Settian Capital’s assets in any long or short position of any one single issuer and will typically invest not more than 10% of a client’s account in any single long position at cost and not more than 4% of a client’s account in any single short position at cost. Securities representing multiple issuers, such as equity index ETFs, that may be used in hedging market risks and adjusting portfolio net exposure, are not considered subject to single position numerical limits. Settian Capital will generally not exceed 200% gross exposure (long exposure plus short exposure), 150% long exposures, and 100% short exposure.

Overview of Risk Factors Risks Applicable to all Settian Capital Clients: Arbitrage. Settian Capital may engage in various types of arbitrage. Arbitrage involves the purchase of an asset and the concurrent sale of that asset in a different market, or the sale of a related asset, in order to capture small price discrepancies between markets or related assets. Arbitrage strategies involving related assets carry the risk that the value of the related assets will not track or affect each other in the manner anticipated by Settian Capital. Arbitrage strategies generally assume the price of related assets will converge to some historic or quantitative relationship and that price discrepancies from this relationship will disappear. In the event the price discrepancies do not disappear or if the price discrepancies increase, a client’s investment account could lose money on an arbitrage trade. Depending upon the investment strategies employed and market conditions, a client’s investment account may be adversely affected by unforeseen events involving such matters as political crises, changes in currency exchange rates, interest rates, forced redemptions of securities or acquisition proposals.

Settian Capital may determine that the offer price for a security that is the subject of a tender offer is likely to be increased, either by the original bidder or by another party. In those circumstances, Settian Capital may purchase securities above the offer price, thereby exposing a client’s investment account to an even greater degree of risk. When Settian Capital determines that it is probable that a previously announced transaction involving a company will not be consummated, it may sell the securities of the target company short, at times significantly below the announced price for the securities in the transaction. If the transaction (or another transaction, such as a defensive merger or a friendly tender offer) is consummated at the announced price or a higher price, Settian Capital may be forced to cover the short positions in the market at a higher price than the short sale price, resulting in a loss. The consummation of mergers, exchange offers and cash tender offers can be prevented or delayed by a variety of factors. Offers for tender or exchange offers customarily include a reservation of the right to cancel such offers in a variety of circumstances, including an insufficient response from shareholders of the target company. Even if the defensive activities of a target company or the actions of regulatory authorities fail to defeat an acquisition, they may result in significant delays, during which an investment account’s capital will be committed to the transaction and interest charges may be incurred on funds borrowed to finance its arbitrage activities in connection with the transaction. Exchange offers or cash tender offers are often made for less than all of the outstanding securities of an issuer, with the provision that, if a greater number is tendered, securities will be accepted on a pro rata basis. Thus, after the completion of a tender offer, and at a time when the market price of the securities has declined below the price at which they were acquired, Settian Capital may have returned to it, and be forced to sell at a loss, a portion of the securities it had previously tendered. Settian Capital may make certain speculative purchases of securities. Such purchases may include securities of companies that are involved in, or which Settian Capital believes will be involved , corporate restructurings, that they believe are undervalued because of an extraordinary event, or that are expected to undergo a change in value because of an expected occurrence. Settian Capital may also make concentrated investments in securities of companies that may be or may become targets for takeovers. If Settian Capital purchases securities in anticipation of an acquisition attempt or reorganization or with the intention of influencing the management and policies of the issuer of the securities, and an acquisition attempt or reorganization does not in fact occur or they are not able to so influence the issuer of the securities, Settian Capital may have to sell the securities at a material loss. In most forms of corporate reorganization, there exists the risk that the reorganization either will be unsuccessful (for example, as a result of the failure to obtain requisite approvals), will be delayed (for example, until various liabilities, actual or contingent, have been satisfied) or will result in a distribution of cash or a new security the value of which will be less than the purchase price to Settian Capital of the security in respect of which such distribution was made. The securities industry, and the arbitrage business in particular, is extremely competitive. Settian Capital competes with firms, including many of the larger investment banking firms, which have substantially greater financial resources than does Settian Capital and substantially greater research staffs and more securities traders than does Settian Capital. In any given transaction, arbitrage activity by other firms may narrow the spread between the price at which a security may be purchased for a client account and the price it expects to receive upon consummation of the transaction. Accordingly, a client’s investment account may not achieve substantial profits on such transactions. Below Investment Grade Fixed Income Securities. Settian Capital may invest or hold securities rated lower than Baa by Moody’s, BBB by S&P’s, or the equivalent rating of another nationally recognized statistical rating organization (“NRSRO”), which are considered below investment grade, or in

comparable unrated securities. Settian Capital may continue to hold previously acquired securities that subsequently become rated below investment grade. Below investment grade securities are commonly known as “high yield” or “junk bonds.” Securities which are in the lower-grade categories generally offer a higher current yield than is offered by higher-grade securities of similar maturities, but they also generally involve greater risks, such as greater credit risk, greater market risk and volatility, and greater liquidity concerns. These investments are generally considered to be speculative based on the issuer’s capacity or inability to pay interest and repay principal. High yield securities may be more susceptible to real or perceived adverse economic and competitive industry conditions than investment grade securities. The prices of high yield securities have in the past been found to be less sensitive to interest-rate changes than higher-rated investments, but more sensitive to adverse economic downturns or individual corporate developments. A projection of an economic downturn or of a period of rising interest rates, for example, could cause a decline in high yield security prices because the advent of a recession could lessen the ability of a highly leveraged company to make principal and interest payments on its debt securities. If an issuer of high yield securities defaults, in addition to risking payment of all or a portion of interest and principal, a client’s investment account may incur additional expenses to seek recovery. In the case of high yield securities structured as zero-coupon or pay-in-kind securities, their market prices are affected to a greater extent by interest rate changes and therefore tend to be more volatile than securities which pay interest periodically and in cash. The markets for high yield securities may be less liquid than the markets for investment grade securities. To the extent that there is no established retail market for high yield securities in which a client’s investment account may invest, trading in such securities may be relatively inactive. Prices of high yield securities may decline rapidly if a significant number of holders were to decide to sell their holdings in those securities. Changes in expectations regarding an individual issuer of high yield securities generally could reduce market liquidity for such securities and make their sale for a client account more difficult. In addition, adverse publicity and investor perceptions about lower-rated securities, whether or not based on fundamental analysis, could contribute to a decrease in the value and liquidity of such lower-rated securities. Concentration Risk. Clients should consider the greater risk of a client account’s concentration versus the reduced volatility that comes with a more diversified portfolio. Settian Capital’s assets may, from time to time, be concentrated in an industry or group of industries. By concentrating its assets in a single industry or group of industries, a client’s investment account is subject to the risk that economic, political, regulatory or other conditions that have a negative effect on that industry or group of industries will negatively impact a client’s investment account to a greater extent than if a client account’s assets were invested in a larger variety of industries. Credit Risk. Settian Capital is also subject to credit risk (i.e., the risk that an issuer or guarantor of a debt security or a counterparty to a transaction involving a debt security will be unable or unwilling to make timely principal and/or interest payments, or otherwise will be unable or unwilling to honor its financial obligations, or that the value of the security will suffer because investors believe the issuer is less able to pay). If the issuer, guarantor, or counterparty fails to pay interest, income from the security may be reduced. If the issuer, guarantor, or counterparty fails to repay principal, the value of the debt security may be reduced. Credit risk is particularly significant for investments in debt securities rated below investment-grade (e.g., “junk bonds” or “high yield” bonds). Credit risk is broadly gauged by the credit ratings of the securities in which a client’s investment account invests. However, ratings are only the opinions of the agencies issuing them, may change less quickly than relevant circumstances and are not absolute guarantees of the quality of the securities. Furthermore, a client account’s assets may not be rated by any rating agency or may be below investment grade. Clients will be more dependent upon the judgment of Settian Capital as to the credit quality of such unrated securities.

Current Market Conditions. Certain market events can increase volatility and exacerbate market risk, such as changes in governments’ economic policies, political turmoil, environmental events, wars, and epidemics, pandemics or other public health issues. Such events may result in closing borders, quarantines, cancellations, and disruptions to supply chains and other business and customer activity, changes in demand for goods and services, as well as general concern and uncertainty, thus causing significant disruptions to (and volatility in) global and domestic business activity and financial markets, the broad effects of which are currently difficult to assess. For example, the outbreak and prolonged effects of COVID-19, the ongoing conflict between Russia and Ukraine, and the conflict between Israel and militant groups in the Gaza Strip have resulted in in disruptions and volatility in business activities and financial markets. Any such change can have a profound negative impact on market and business conditions (including market and business conditions that may affect a client’s investment account) and may result in a period of prolonged economic downturn. No assurance can be made regarding the ultimate financial impact that any such events will have on a client’s investment account; however, any negative economic impact resulting from such events could adversely affect the performance of a client’s investment account in the future. Settian Capital cannot reasonably estimate the ultimate impact such events may have the revenues, results of operations, cash flow, and financial condition of any business in which it is invested. The impact of any such event will depend on, among other things, the duration of such event, the impact of government actions in response to any such event, the effectiveness of actions taken, and changes to consumer and customer behaviors as a result of the applicable event. Dollar Rolls. Settian Capital may enter into dollar rolls in which a client’s investment account sells securities and simultaneously agrees to repurchase substantially similar securities on a specified future date. During the roll period, a client’s investment account does not receive interest and principal payments paid on the securities sold but is compensated by the difference between the current sales price of the securities sold and the price for the securities to be purchased and by any interest earned on the proceeds of the securities sold. Economic Risk. The valuations of investments held in a client’s investment account are sensitive to general economic conditions. Accordingly, a client’s investment account may be negatively affected by changes in general economic conditions outside the control of Settian Capital. General economic conditions may be negatively affected by, among other things, changes in the macroeconomic environment, interest rates, inflation rates, employment conditions, competition, and technological developments, political and diplomatic events and trends, economic downturns, recessions, pandemics or epidemics, terrorism, war, and tax laws. Equity Markets Correlation. In general, the value of equities fluctuate in response to the activities of their underlying companies, investor behaviors and in response to general market and economic conditions. Stock markets tend to be cyclical, with periods of generally rising prices and periods of generally declining prices. Settian Capital’s investments are exposed to the volatility of the equity markets. The equity markets tend to be highly correlated and therefore returns on a client account’s portfolio may provide less market diversification than may otherwise be the case with a portfolio that is diversified across different types and categories of asset classes. Equity Securities. Prices of equity securities in which a client’s investment account may be invested will fluctuate in response to many factors, including, but not limited to, the activities of the individual companies whose securities a client’s investment account owns, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject a client’s investment account to potential losses. In addition, regardless of any one company’s particular prospects, a declining stock market may produce a decline in prices for equity securities for all companies in the market, which could also result in losses for a client’s investment account. Market declines may continue for an indefinite period of time, and the investor should understand that from time to time during temporary or extended declining markets, the value of a client account’s equity securities will decline. Accordingly, a client’s

investment account may suffer significant losses on investments in equity securities, including common stocks. Exchange Traded Products and Other Investment Company Risk. Settian Capital may invest in ETFs, exchange traded notes (“ETNs”), closed-end funds, other exchange traded products (“ETPs”) or other investment companies. Through its positions in ETFs and other investment companies, a client’s investment account will be subject to the risks associated with such vehicles’ investments, including the possibility that the value of the securities or instruments held by an ETF or other investment company could decrease (or increase). Certain of the ETFs or other investment companies in which a client’s investment account may invest may hold common portfolio positions, thereby reducing any diversification benefits. Exchange Traded Funds. The shares of an ETF may be assembled in a block (typically 50,000 shares) known as a creation unit and redeemed in-kind for a portfolio of the underlying securities (based on the ETF’s net asset value) together with a cash payment generally equal to accumulated dividends as of the date of redemption. Conversely, a creation unit may be purchased from the ETF by depositing a specified portfolio of the ETF’s underlying securities, as well as a cash payment generally equal to accumulated dividends of the securities (net of expenses) up to the time of deposit. There is a risk that the underlying ETFs in which a client’s investment account invests may terminate due to extraordinary events that may cause any of the service providers to the ETFs, such as the trustee or sponsor, to close or otherwise fail to perform their obligations to the ETF. Also, because the ETFs in which a client’s investment account invests may be granted licenses by agreement to use the indices as a basis for determining their compositions and/or otherwise to use certain trade names, the ETFs may terminate if such license agreements are terminated. In addition, an ETF may terminate if its entire net asset value falls below a certain amount. Although Settian Capital believes that, in the event of the termination of an underlying ETF, it will be able to invest instead in shares of an alternate ETF tracking the same market index or another market index with the same general market, there is no guarantee that shares of an alternate ETF would be available for investment at that time. Investments in ETFs and other investment companies are also subject to the following additional risks: Expenses. To the extent a client’s investment account invests in shares of ETFs or other investment companies, your cost of investing in a client’s investment account will generally be higher than the cost of investing directly in ETFs or other investment companies, because you will indirectly bear fees and expenses charged by the underlying ETFs and investment companies in which a client’s investment account invests in addition to a client account’s direct fees and expenses. Furthermore, investments in ETFs or other investment companies could affect the timing, amount, and character of a fund’s distributions and therefore may increase the amount of your tax liability. Commodity ETFs. Shareholders of ETFs that are registered under the Securities Act, but not the Investment Company Act, such as ETFs that track commodities prices or invest in commoditiesrelated securities, do not have the protections of the Investment Company Act. Market Value Risk. The market value of an ETF’s shares may differ from its net asset value (“NAV”). This difference in price may be due to the fact that the supply and demand in the market for ETF shares at any point in time is not always identical to the supply and demand in the market for the underlying basket of securities. Accordingly, there may be times when an ETF trades at a premium (creating the risk that a client’s investment account pays more than NAV for an ETF when making a purchase) or discount (creating the risks that a client account’s net asset value is reduced for undervalued ETFs it holds, and that a client’s investment account receives less than NAV when selling an ETF).

Tracking Risk. Index-based ETFs may not be able to replicate exactly the performance of the indices they track because the total return generated by the securities will be reduced by transaction costs incurred in adjusting the actual balance of the securities. In addition, ETFs may incur expenses not incurred by their applicable indices. Certain securities comprising these indices may, from time to time, temporarily be unavailable, which may further impede an ETFs’ ability to track its applicable indices or match its performance. Sampling Risk. Index-based ETFs may utilize a representative sampling approach to track their respective underlying indices. Index-based ETFs that utilize a representative sampling approach are subject to an increased risk of tracking error because the securities selected for the ETF in the aggregate may vary from the investment profile of the underlying index. Additionally, if using a representative sampling approach, an ETF will typically hold a smaller number of securities than the underlying index, and as a result, an adverse development to an ETF could result in a greater decline in a client account’s net asset value than would be the case if the ETF held all of the securities in the underlying index. Fixed Income ETFs. There are risks associated with the potential investment of a client account’s assets in fixed income ETFs which may include credit risk, interest rate risk and maturity risk as described below: Credit Risk. Credit risk is the risk that the issuer or guarantor of a fixed income security or counterparty to a transaction involving one or more bonds in an ETF’s portfolio will be unable or unwilling to make timely principal and/or interest payments or otherwise will be unable or unwilling to honor its financial obligations. If the issuer, guarantor, or counterparty fails to pay interest, an ETF’s income may be reduced. If the issuer, guarantor, or counterparty fails to repay principal, the value of that security and of the particular ETF’s shares may be reduced. ETFs may be subject to credit risk to the extent that they invest in fixed income securities which involve a promise by a third party to honor an obligation with respect to the fixed income security. Securities rated BBB by Standard & Poor’s (“S&P”) or Fitch Ratings, Ltd. (“Fitch”) or Baa by Moody’s Investors Service, Inc. (“Moody’s”) are considered investment-grade securities, but are somewhat riskier than more highly-rated investment-grade obligations (those rated A or better) because they are regarded as having only an adequate capacity to pay principal and interest, are considered to lack outstanding investment characteristics, and may be speculative. Such investment-grade securities will be subject to higher credit risk and may be subject to greater fluctuations in value than higher-rated securities. Credit risk is particularly significant for investments in “junk bonds” or lower than investment-grade securities. Interest Rate Risk. The price of a bond or a fixed income security is dependent upon interest rates. Therefore, the share price and total return of an ETF, when investing a significant portion of its assets in bonds or fixed income securities, will vary in response to changes in interest rates. There is the possibility that the value of an ETF’s investment in bonds or fixed income securities may fall because bonds or fixed income securities generally fall in value when interest rates rise. The longer the term of a bond or fixed income instrument, the more sensitive it will be to fluctuations in value from interest rate changes. Changes in interest rates may have a more pronounced effect if the ETF holds a significant portion of its assets in fixed income securities with long-term maturities. In the case of mortgage-backed securities, rising interest rates tend to extend the term to maturity of the securities, making them even more susceptible to interest rate changes. When interest rates drop, not only can the value of fixed income securities drop, but also the yield can drop, particularly where the yield is tied to changes in interest rates, such as adjustable mortgages. Also when interest rates drop, the holdings of mortgage-backed securities by an ETF can reduce returns if the owners of the underlying mortgages pay off their mortgages sooner than expected since the funds prepaid must be reinvested at lower prevailing interest rates. This is known as

prepayment risk. When interest rates rise, the holdings of mortgage-backed securities by an ETF can reduce returns if the owners of the underlying mortgages pay off their mortgages later than anticipated. This is known as extension risk. Maturity Risk. Maturity risk is another factor that can affect the value of an ETF’s fixed income holdings. Certain ETFs may not have a limitation policy regarding the length of maturity for their fixed income holdings. In general, fixed income obligations with longer maturities have higher yields and a greater sensitivity to changes in interest rates. Conversely, fixed income obligations with shorter maturities generally have lower yields but less sensitivity to changes in interest rates. Exchange Traded Notes. Settian Capital may invest in ETNs. ETNs are a type of unsecured, unsubordinated debt security that have characteristics and risks similar to those of fixed-income securities and trade on a major exchange similar to shares of ETFs and gives exposure to underlying investments (typically market indices), which may themselves be equity or fixed income investments. However, this type of security differs from other types of bonds and notes because ETN returns are based upon the performance of a market index minus applicable fees, no period coupon payments are distributed, and no principal protections exist. The value of an ETN may be influenced by time to maturity, level of supply and demand for the ETN, volatility and lack of liquidity in underlying markets, changes in the applicable interest rates, changes in the issuer’s credit rating and economic, legal, political or geographic events that affect the referenced investment. Settian Capital’s decision to sell its ETN holdings also may be limited by the availability of a secondary market. If a client’s investment account must sell some or all of its ETN holdings and the secondary market is weak, it may have to sell such holdings at a discount. If a client’s investment account holds its investment in an ETN until maturity, the issuer will typically give a client’s investment account a cash amount that would be equal to the principal amount (subject to the day’s index factor). ETNs are also subject to counterparty credit risk (which includes the risk that the issuer may fail). The timing and character of income and gains derived from ETNs is under consideration by the U.S. Treasury and Internal Revenue Service and may also be affected by future legislation. Forward Commitments and “When-Issued” Transactions. Settian Capital may purchase and sell securities or other instruments on a “when-issued” and “delayed delivery” basis. The payment obligation and the interest rate receivable on a forward commitment, delayed delivery or when-issued security are fixed when Settian Capital enters into the commitment, but payment is not made out of a client’s investment account until delivery is received from the counterparty. No income accrues to a client’s investment account on such securities in purchase transactions prior to the date of delivery of the securities. When purchasing a security on a when-issued, delayed delivery, or forward commitment basis, a client’s account is exposed to all the rights and risks of ownership of the security, including the risk of price and yield fluctuations. When Settian Capital sells a security on a when-issued, delayed delivery, or forward commitment basis, a client’s investment account does not participate in future gains or losses with respect to the security. If the other party to a transaction fails to deliver or pay for the securities, a client’s investment account could be denied a favorable price or yield opportunity or could suffer a loss. High Risk Investments. All investments in securities and other financial instruments involve a degree of risk that the entire investment may be lost. No assurance, express or implied, can be given that a client account’s investment strategy will be successful in achieving its investment objective. As a result, there can be no assurance that an investor will not lose money on the investment up to the entire amount of the investment. IPO Risk. Settian Capital may invest in IPOs at the time of the initial offering and in post-IPO trading. The stocks of such companies are unseasoned equities lacking a trading history, a track record of reporting to investors and widely available research coverage. IPOs are thus often subject to extreme price volatility and speculative trading. These stocks may have above-average price appreciation in connection

with the initial public offering prior to inclusion in a client’s investment account. The price of stocks included in a client’s investment account may not continue to appreciate. In addition, IPOs share similar liquidity risks as private equity and venture capital. Such liquidity risks exist when particular investments of a client’s investment account would be difficult to purchase or sell, possibly preventing a client’s investment account from selling such illiquid securities at an advantageous time or price, or possibly requiring a client’s investment account to dispose of other investments at unfavorable times or prices in order to satisfy its obligations. The free float shares held by the public in an IPO are typically a small percentage of the market capitalization. The ownership of many IPOs often includes large holdings by venture capital and private equity investors who seek to sell their shares in the public market in the months following an IPO when shares restricted by lock-up are released, causing greater volatility and possible downward pressure during the time that locked-up shares are released. Issuer Non-Diversification Risk. Settian Capital may concentrate its investments in particular markets, sectors or industries. As a result, a client’s investment account may be subject to greater short-term volatility than the broader market indexes than if they were to make investments diversified by markets, sectors or industries as those indexes do. By concentrating in a specific industry or sector that Settian Capital considers mispriced, a client’s investment account will be subject to the risks of that industry or sector, such as technology rapidly going out of date, sensitivity to regulatory changes, minimal barriers to entry and sensitivity to overall market swings. Settian Capital may invest a significant percentage of its assets in the securities of a small number of issuers. As a result, a client account’s investments may be more susceptible to risks associated with a single economic, political or regulatory circumstance or event than a more diversified portfolio might be. Losses in one or more large positions, or a downturn in a securities or market sector in which a client’s investment account is concentrated, could materially adversely affect a client account’s performance in a particular period and could have a material adverse effect on a client account’s cumulative gains and losses. Issuer Risk. The value of a security may increase or decrease for a number of reasons which directly relate to the issuer, such as management performance, financial leverage, and reduced demand for the issuer’s goods or services, or to the industry in which the issuer operates. Illiquid and Thinly Traded Investments. A portion of a client account’s assets may from time to time be invested in securities and other financial instruments or obligations for which no market exists and/or which are restricted as to their transferability under federal or state securities laws. The sale of any such investments may be subject to delays and additional costs and may be possible only at substantial discounts. Due to the lack of a listing or active market for these investments, they may be particularly difficult to value. This may affect significantly the determination of unrealized gains and losses of a client’s investment account. A portion of a client account’s investments may be in thinly traded issues of companies with a relatively limited number of outstanding shares, and such investments may represent a substantial percentage of a client account’s assets from time to time. As a result, moderate trading activity in these issues could have a substantial effect on the market price. Consequently, it may take Settian Capital a relatively long period of time to accumulate its position in a particular issue to minimize the effect of a client account’s purchases on the price. Similarly, it could be difficult for Settian Capital to quickly dispose of such positions without adversely affecting the price. Thus, Settian Capital believes that it may be necessary to hold investments of a client’s investment account in thinly traded issues, if any, for as long as a period of several years to realize a client’s investment objectives. Conversely, it is possible that a significant block of a thinly traded security, that has been acquired over time, may possibly be disposed of at a premium under certain circumstances due to the limited number of shares outstanding. Interest Rate Risk. As nominal interest rates rise, the value of fixed income securities is likely to decrease. Securities with longer durations tend to be more sensitive to changes in interest rates, usually making them more volatile than securities with shorter durations. A nominal interest rate can be

described as the sum of a real interest rate and an expected inflation rate. Inflation-indexed securities decline in value when real interest rates rise. In certain interest rate environments, such as when real interest rates are rising faster than nominal interest rates, inflation-indexed securities may experience greater losses than other fixed income securities with similar durations. In addition, increases in interest rates typically lower the present value of a company’s future earnings stream. Since the market price of a stock changes continuously based upon investors’ collective perceptions of future earnings, stock prices will generally decline when investors anticipate or experience rising interest rates. Investments in Private Companies. Settian Capital may invest in equity securities of public companies that may become private companies, which will subject a client’s investment account to the risks associated with investments in private companies. These risks may be substantial and will relate to a variety of types of risks, including, without limitation, capital needs risks, business risks, technology risks, competitive risks, economic risks, market risks, management risks, government regulation risks, tax risks, and numerous additional types of risks that operating companies face. Such companies may realize any or all of the risks to which their businesses are subject, regardless of how thoroughly they are described in their offering documents, any of which may result in losses for such companies and, consequently, losses to a client’s investment account. Settian Capital expects that there will be no ready market for any securities issued by such companies, and resale of any such securities will generally be restricted by applicable securities law. There can be no assurance that any investment in a private company will earn a positive return or not lose money. Investments in Small-Cap Companies. Settian Capital may invest a significant portion of client assets in securities of companies with small market capitalizations. Certain small-cap companies may offer greater potential for capital appreciation than larger companies. However, prospective investors should note that this potential for greater capital appreciation is accompanied by a substantial risk of loss and that, by their very nature, investments in small-cap companies tend to be very volatile and speculative. This greater risk is, in part, attributable to the fact that the securities of small-cap companies usually have more limited marketability and, therefore, may be more volatile than securities of larger, more established companies or the market averages in general. Because small-cap companies normally have less trading volume than larger companies, it may be more difficult to buy or sell significant amounts of such shares without an unfavorable impact on prevailing prices (i.e., shares of small-cap companies may be less liquid relative to shares of mid- and large-cap companies). Another risk factor is that small-cap companies often have limited product lines, markets, or financial resources and may lack management depth. Small-cap companies may not be well-known to the investing public, may not be followed by the financial press or industry analysts, and may not have institutional ownership. These factors affect Settian Capital’s access to information about the companies and the stability of the markets for the companies’ securities. Investments in small-cap companies may be less liquid and subject to significant price declines that result in losses for a client’s investment account. Further, small-cap companies may be more vulnerable than larger companies to adverse business or economic developments. Lending of Securities. Settian Capital may lend portfolio securities to broker-dealers and other financial institutions. The advantage of such loans is that a client’s investment account continues to receive the interest or dividends on the loaned securities, while at the same time earning interest on the collateral which is invested in short-term obligations. If the borrower fails to maintain the requisite amount of collateral, the loan automatically terminates, and a client’s investment account could use the collateral to replace the securities while holding the borrower liable for any excess of replacement cost over collateral. As with any extensions of credit, there are risks of delay in recovery and in some cases even loss of rights in the collateral should the borrower of the securities fail financially. On termination of the loan, the borrower is required to return the securities to a client’s investment account; any gains or losses in the market price during the loan would inure to a client’s investment account. Leverage. Settian Capital may utilize leverage. The use of leverage results in a client’s investment account controlling substantially more assets than a client’s investment account has equity. Leverage

increases a client account’s returns if a client’s investment account earns a greater return on investments purchased with borrowed funds than a client account’s cost of borrowing such funds. However, the use of leverage exposes a client’s investment account to additional levels of risk including, but not limited to, (1) greater losses from investments than would otherwise have been the case had a client’s investment account not borrowed to make the investments, (2) margin calls or changes in margin requirements may force premature liquidations of investment positions, and (3) losses on investments where the investment fails to earn a return that equals or exceeds a client account’s cost of leverage related to such investments. In the event of a sudden, precipitous drop in value of a client account’s assets, Settian Capital might not be able to liquidate assets quickly enough to repay the borrowings, further magnifying the losses incurred for a client account. Limitations on Effectiveness of Hedging. Although Settian Capital may employ various hedging techniques, the extent and effectiveness of such hedging strategies may vary substantially. The hedging techniques of Settian Capital may be directed toward general market risks or certain issuer risks. Typically, there are numerous investment risks which will not be hedged or necessarily capable of being hedged as a practical matter. To the extent unhedged, investment positions of a client’s investment account will, in general, be fully exposed to market and investment risks. Hedging techniques have a variety of limitations. Hedging against a decline in the value of a position by selling short, for example, does not eliminate fluctuations in the values of positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the overall portfolio positions’ value. Hedging through market index options may only protect against an overall market downturn, as compared with price declines in specific securities. Hedging transactions generally also limit the opportunity for gain if the value of the position should increase, due to the hedging cost or price decline in the hedging position. For a variety of reasons, Settian Capital may not seek or be able to establish a sufficiently accurate correlation between hedging instruments and the Investments being hedged. Such imperfect correlation may prevent Settian Capital from achieving the intended hedge or may expose a client’s investment account to risk of loss. Such losses can include losses on the hedged position, the attempted hedge position, or both, and could be substantial. There can be no assurance, therefore, that investments will be significantly hedged against investment risks or that such hedging strategies, if any, will in fact prove successful. Market Risk. The price of equity securities and other instruments which a client’s investment account may hold may be affected by factors affecting securities markets generally, such as real or perceived adverse economic conditions, supply and demand for particular instruments, changes in the general outlook for corporate earnings, interest rates or adverse investor sentiment generally. Even nondirectional trading strategies may be exposed to market risk with respect to individual investments or the portfolio as a whole. Failure of a marketplace to function properly for any reason, including outside events affecting the marketplace or market participants, may adversely affect a client’s investment account. Non-Specified Investments. Settian Capital may invest the net proceeds of this offering in any investment that Settian Capital deems suitable for a client’s investment account. Settian Capital, then, may invest all, substantially all, or a significant portion of its assets in any one type of investment, or in a small number of securities within any one type of investment, as determined by Settian Capital. Clients must rely on the judgment and ability of Settian Capital with respect to the investment of a client account’s capital and will not have an opportunity to evaluate for themselves the relevant economic, financial and other information regarding the securities and companies in which a client’s investment account will invest. No assurance can be given that Settian Capital will be successful in identifying investments suitable for investment or that, if such investments are made, the objectives of a client’s investment account will be achieved.

Non-U.S. Debt Securities. The returns on debt securities of non-U.S. issuers reflect interest rates and other market conditions prevailing in those countries. If such non-U.S. debt securities are denominated in currencies other than the U.S. Dollar, the effect of gains and losses in the non-U.S.-Dollar currencies against the U.S. Dollar may have a substantial impact on the value of such non-U.S.-Dollar-denominated debt securities. The relative performance of various countries’ fixed income markets historically has reflected wide variations relating to the unique characteristics of each country’s economy. Year-to-year fluctuations in certain markets have been significant, and negative returns have been experienced in various markets from time to time. The non-U.S. government securities in which Settian Capital may invest include, among other things, obligations issued or backed by national, state or provincial governments or similar political subdivisions or central banks in non-U.S. countries, debt obligations of supranational entities including international organizations designated, or backed, by governmental entities to promote economic reconstruction or development, international banking institutions and related government agencies, debt securities of “quasi-governmental agencies”, and debt securities denominated in multinational currency units of an issuer (including supranational issuers). Debt securities of quasi-governmental agencies are issued by entities owned by either a national, state or equivalent government or are obligations of a political unit that is not backed by the national government’s full faith and credit and general taxing powers. Investment in sovereign debt can involve a high degree of risk. The governmental entity that controls the repayment of sovereign debt may not be able or willing to repay the principal and/or interest when due in accordance with the terms of the debt. A governmental entity’s willingness or ability to repay principal and interest due in a timely manner may be affected by, among other factors, its cash flow situation, the extent of its foreign reserves, the availability of sufficient foreign exchange on the date a payment is due, the relative size of the debt service burden to the economy as a whole, the governmental entity’s policy toward the International Monetary Fund, and the political constraints to which a governmental entity may be subject. Governmental entities may also depend on expected disbursements from foreign governments, multilateral agencies and others to reduce principal and interest arrearages on their debt. The commitment on the part of these governments, agencies and others to make such disbursements may be conditioned on a governmental entity’s implementation of economic reforms and/or economic performance and the timely service of such debtor’s obligations. Failure to implement such reforms, achieve such levels of economic performance or repay principal or interest when due may result in the cancellation of such third parties’ commitments to lend funds to the governmental entity, which may further impair such debtor’s ability or willingness to service its debts in a timely manner. Consequently, governmental entities may default on their sovereign debt. Holders of sovereign debt (including a client’s investment account) may be requested to participate in the rescheduling of such debt and to extend further loans to governmental entities. There is no bankruptcy proceeding by which sovereign debt on which governmental entities have defaulted may be collected in whole or in part. Non-U.S. Securities. Settian Capital may invest in securities of non-U.S. issuers and other non-U.S. instruments. Investments in non-U.S. instruments, whether directly or through depositary receipts such as ADRs and GDRs (which are receipts of foreign issuers traded on U.S. stock exchanges) present certain risks not ordinarily associated with investments in U.S. instruments. These risks include political, economic or legal developments (including war or other instability, expropriation of assets, nationalization and confiscatory taxation), withholding taxes on dividend or interest payments or capital transactions or other restrictions, higher transaction costs (including higher brokerage, custodial and settlement costs) and possible difficulty in enforcing contractual obligations or taking judicial action. Also, non-U.S. instruments may not be as liquid and may be more volatile than comparable domestic securities. Public Disclosures and Government Supervision. Often there is less publicly available information about many non-U.S. issuers, and issuers of non-U.S. instruments are subject to different, often less comprehensive, auditing, accounting, financial reporting and disclosure

requirements than U.S. issuers. There is generally less government regulation of financial markets outside of the United States than in the United States. Additionally, in certain countries, there could be risks of expropriation of assets, confiscatory taxation, or diplomatic developments which could affect investments in those countries. To the extent that there is less supervision and governmental regulation of exchanges, markets and intermediaries in countries other than the United States, a client’s investment account may experience settlement difficulties or delays involving non-U.S. securities, which are not usually encountered in the United States. Trading Risks. Delays in making trades in non-U.S. securities relating to volume constraints, limitations or restrictions, clearance or settlement procedures, or otherwise could adversely affect yields and result in temporary periods when assets of a client’s investment account are not fully invested or a client’s investment account is unable to take advantage of attractive alternative investment opportunities. Furthermore, to the extent that a client’s investment account invests in securities of non-U.S. issuers, a client account’s trading expenses would be expected to be higher than the costs incurred with respect to investments in securities of U.S. issuers. Political Instability. With respect to some non-U.S. countries, there is the possibility of expropriation or confiscatory taxation, limitations on the removal of funds or other assets of a client’s investment account, political or social instability, or domestic developments which could affect U.S. investments in those countries. Currency Risk. Settian Capital may invest in securities denominated in non-U.S. currencies. Investing directly in non-U.S. currencies or securities that trade in, or receive revenues in, nonU.S. currencies will be subject to currency risk. Non-U.S. currency exchange rates may fluctuate significantly over short periods of time. They generally are determined by supply and demand in the foreign exchange markets and the relative merits of investments in different countries, actual or perceived changes in interest rates and other complex factors. Currency exchange rates also can be affected unpredictably by intervention (or the failure to intervene) by U.S. or non-U.S. governments or central banks, or by currency controls or political developments. Interventions are generally intended to manipulate exchange rates. Currencies may also be affected by the imposition of exchange controls and other policies intended to affect relative exchange rates. Currencies other than the U.S. Dollar in which a client account’s assets are denominated may be devalued against the U.S. Dollar, resulting in a loss to a client’s investment account. Options. Options trading involves various risks. Specific market movements of the option and the instruments underlying an option cannot be predicted. No assurance can be given that a liquid offset market will exist for any particular option or at any particular time. If no liquid offset market exists, a client’s investment account might not be able to effect an offsetting transaction in a particular option. To realize any profit in the case of an option, therefore, the option holder would need to exercise the option and comply with margin requirements for the underlying instrument. A writer could not terminate the obligation until the option expired or the writer was assigned an exercise notice. The purchaser of an option is subject to the risk of losing the entire purchase price of the option. The writer of an option is subject to the risk of loss resulting from the difference between the premium received for the option and the price of the contract underlying the option that the writer must purchase or deliver upon exercise of the option. The writer of a naked option may have to purchase the underlying contract in the market for substantially more than the exercise price of the option in order to satisfy his delivery obligations. This could result in a large Net Loss. Stock or index options that may be purchased or sold for a client account may include options not traded on a securities exchange. The risk of nonperformance by the obligor on such an option may be greater and the ease with which a client’s investment account can dispose of or enter into closing transactions with respect to such an option may be less than in the case of an exchange traded option.

Portfolio Turnover. Portfolio turnover is not a limiting factor with respect to a client account’s investment decisions. The rate of a client account’s portfolio turnover may vary significantly from time to time depending on the volatility of economic and market conditions, and it is not possible to predict portfolio turnover. Higher portfolio turnover involves correspondingly greater brokerage commissions, dealer mark-up and other transaction costs, which will be borne either directly or indirectly for a client account. In addition, portfolio turnover can result in the realization of capital gains or losses, which may have to be recognized by investors for tax purposes. Potential Exposure of Assets and Counterparty Risk. The assets of a client’s investment account are generally subject to counterparty risk with respect to the brokers, counterparties, clearing houses and exchanges with which they deal. Any default by one of these parties could result in material losses to a client’s investment account. The assets of the Private Fund held by brokers or counterparties are generally not held in segregated accounts, and accordingly, in the event of any such default a client’s investment account may only have the rights of a general creditor in the event any broker or counterparty dissolves or files for bankruptcy. In addition, the institutions, including brokerage firms and banks, with which a client’s investment account trades or invests may encounter financial difficulties that impair the operational capabilities or the capital position of the Private Fund. Securities pledged for a client account as collateral with a broker may be available to the creditors of such broker in the event of such broker’s insolvency. In certain circumstances, a broker also may have the discretion to liquidate a client account’s assets held by such broker. The issuers of some asset-backed securities permit the servicer to retain possession of the underlying obligations. Thus, the return on those obligations may be subject to risks involving insolvency or malfeasance of the servicer. Real Estate Investment Trusts. Settian Capital may invest in real estate investment trusts (“REITs”), which are publicly traded entities that manage a portfolio of real estate assets and businesses, such as shopping centers, nursing homes, medical facilities, apartment complexes, office buildings, industrial warehouses, and hotels. Some REITs concentrate in one or more particular types of real estate assets, and others invest in a broad range of real estate assets. REITs are subject to risks associated with real estate in general, such as declines in the value of real estate; risks related to general and local economic conditions; possible lack of availability of mortgage funds; overbuilding; extended vacancies of properties; increases in competition, property taxes and operating expenses; changes in zoning laws; costs resulting from the clean-up of and liability to third parties for damages resulting from environmental problems; casualty or condemnation losses; uninsured damages from floods, earthquakes or other natural disasters; limitations on and variations in rents; and changes in interest rates. In addition, REITs are subject to risks of poor investment selection, limited diversification, the uncertainties of development and construction projects, potential defaults by highly leveraged borrowers, and general market risks. REITs are also subject to tax risks and heavy cash flow dependency as they must distribute at least 90% of their net earnings each year to shareholders in order to maintain their tax status under the Code. Repurchase Agreements. Settian Capital may engage in repurchase agreements with banks, brokerdealers or other parties. In a repurchase agreement, a client acquires ownership of a security and the seller agrees to repurchase the obligation at a future time and set price, thereby determining the yield during the holding period. In the event of the bankruptcy or other default of a seller of a repurchase agreement, delays could be experienced in liquidating the underlying securities could result and/or losses may be realized, including: (a) possible decline in the value of the underlying security during the period while it seeks to enforce its rights thereto; (b) possible lack of access to income on the underlying security during this period; and (c) expenses of enforcing its rights.

Reverse Repurchase Agreements. Settian Capital may enter into reverse repurchase agreements with respect to securities which could otherwise be sold for a client account. Reverse repurchase agreements involve sales for a client account of portfolio assets concurrently with an agreement for a client account to repurchase the same assets at a later date at a fixed price. During the reverse repurchase agreement period, a client’s investment account continues to receive principal and interest payments on these securities. Reverse repurchase agreements involve the risk that the market value of the securities retained for a client account may decline below the price of the securities a client’s investment account has sold but is obligated to repurchase under the agreement. In the event the buyer of securities under a reverse repurchase agreement files for bankruptcy or becomes insolvent, a client account’s use of the proceeds of the agreement may be restricted pending a determination by the other party, or its trustee or receiver, whether to enforce a client account’s obligation to repurchase the securities. Sector Risk. Sector risk is the possibility that securities within the same group of industries will decline in price due to sector-specific market or economic developments. If Settian Capital invests more heavily in a particular sector, client account values will be particularly sensitive to declines in that sector. Additionally, some sectors could be subject to greater government regulation or increases in government regulation than other sectors, either of which may have an adverse effect on the value of securities of companies in the sector. Securities Subject to Trading Restrictions. A portion of a client account’s assets may be invested in securities and other financial instruments or obligations which are restricted as to their transferability under federal or state securities laws in the United States and elsewhere. The General Partner may be prevented from selling (and in some cases buying) securities that are otherwise liquid where, as a result of Settian Capital’s shareholder activism or role with the issuer of the security (e.g., if Settian Capital or its principal holds a position on a portfolio company’s board of directors), and Settian Capital has or is deemed to have access to material non-public information about the issuer. In such cases, a client’s investment account may be unable to increase or decrease its position in the issuer despite current market activity in the securities, or positive or negative information that Settian Capital may learn about the issuer or the securities separate from its insider status. Short Sales. Settian Capital may engage in the short sale of securities. Short selling involves selling securities which may or may not be owned and borrowing the same securities for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling allows the investor to profit from declines in market prices to the extent the decline exceeds the transaction costs and the costs of borrowing the securities. Because the borrowed securities must later be replaced by purchases at market prices in order to close out the short position, any appreciation in the price of the borrowed securities would result in a loss. Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. An unanticipated tender offer for an issuer could also cause a sudden increase in the price of the securities sold short. Theoretically, the potential loss on the securities sold short is unlimited as there is no ceiling on how far the price of the security may rise. Also, a short seller may be prematurely forced out of a position due to an inability to maintain a loan of the stock that is borrowed to establish the short sale. Further, short selling has recently been the subject of increasing legislative and regulatory scrutiny. Undervalued Companies. Settian Capital may invest in companies that Settian Capital considers to be “undervalued.” The securities of an undervalued company may be depressed in value due to factors including, but not limited to, disappointments in recent earnings, diminished expectations regarding future

earnings, current or expected adverse economic or industry conditions, simply because they have fallen out of favor or because they are not attracting sufficient investor interest. Settian Capital may be mistaken regarding whether particular securities purchased for a client account are undervalued when purchased, and prices for the purchased securities may fall below the purchase price, resulting in material losses for a client’s investment account. Additionally, the reasons the securities are undervalued may persist, or new problems that further depress their prices may develop after investment. Volatility Risk. Client investment accounts will be exposed to the risk of volatility in the equity markets, which may be significant at times due to economic, political and other factors that cannot be controlled or foreseen by Settian Capital. There is no guarantee that any exposure management or other strategy employed by Settian Capital will successfully mitigate any market volatility impacts experienced by client accounts.

Settian Capital also has two financial industry affiliates: (1) Park Avenue Value Partners LLC, a professional services consulting company; and (2) JAEK Capital Management LP, a professional research and support services company. All of the above entities are under the common control of Kristofer Segerberg. While Settian Capital will take reasonable steps to manage conflicts of interest between its activities and those of the affiliated entities, there can be no assurance that those efforts will be successful. It is possible that one or more of the affiliated entities may have a competing interest in one or more investments that might otherwise be suitable for Settian Capital clients. Additionally, given the nature of some of the investments that Settian Capital may make on behalf of clients, it is possible that conflicts may arise between the interests of Settian Capital or its control persons and those of clients managed by Settian Capital. For example, other business opportunities may arise from such investments which may benefit Settian Capital and/or its control persons. Settian Capital has adopted procedures to manage these conflicts which include, where applicable, notification and consent processes. There can be no assurance, however, that any procedure adopted to address this type of conflict will fully or partially mitigate the influence that such conflicts may exert over the investment decision-making process. Settian Capital may also manage proprietary accounts on behalf of certain members of the organization. These proprietary accounts may invest in certain securities also purchased and sold for client accounts. The trading of proprietary accounts by Settian Capital could create incentives for Settian Capital to

allocate trades, choose the timing of trades and divert limited investment opportunities in favor of these accounts. Settian Capital has adopted policies and procedures designed to mitigate potential investment allocation and trading preferences. However, there can be no assurance that these policies and procedures will always prevent the proprietary accounts from receiving more favorable treatment than one or more other accounts managed by Settian Capital.

Settian Capital’s Code applies to all employees of Settian Capital and any account in which an employee has control or a beneficial interest as well as the accounts of family members of each employee’s immediate household, as further described in the Code. The Code also requires employees to report all accounts and securities holdings covered by the Code at the commencement of their employment and annually thereafter. In addition, on a quarterly basis, all employees are required to report all securities transactions executed during the quarter. The Code also requires, among other things, that all employees pre-clear transactions in initial public offerings and private placements. Certain securities are exempt from the requirements of the Code including open-end mutual funds which are neither managed nor affiliated with Settian Capital, money market funds, money market instruments, unit investment trusts that are invested in open-end mutual funds and U.S. Government securities. The Code imposes specific prohibitions on employee trades including (i) trades based on material nonpublic information, (ii) trades intended to manipulate the market, (iii) trades in securities on Settian Capital’s restricted list, (iv) trades in securities subject to an open order or during the blackout period, subject to certain de minimis exceptions relating to large cap securities; and (v) trades in initial public offerings. Settian Capital’s Insider Trading Policy includes specific requirements regarding the possession of material non-public information (“MNI”) in order to avoid situations that may violate applicable statutes or regulations or create an appearance of impropriety. Settian Capital’s Insider Trading Policy strictly forbids any employee from (i) conducting trades, either personally or on behalf of others, including clients of Settian Capital, while in possession of MNI and from (ii) communicating MNI to others. All employees of Settian Capital must acknowledge that they understand the Code and agree to comply with it both upon initial employment and through annual certifications. Conflicts of interest that can impact Settian Capital and a client’s investment accounts, such as those arising from the giving and receipt of gifts to and from business partners, and the making of political contributions, are also addressed. A copy of Settian Capital’s Code of Ethics will be provided to any client, investor or prospective client or investor upon request. Settian Capital’s affiliates and certain employees of Settian Capital are members of one or more of the entities serving as general partner of the Private Fund. Employees of Settian Capital may maintain (either

directly or indirectly) investments in the Private Fund, and the general partner or a member of the general partner of the Private Fund makes a capital commitment to the Private Fund. The general partner of the Private Fund receives performance-based compensation. Furthermore, Settian Capital’s officers, directors and employees may from time-to-time purchase, sell, or hold positions for their personal accounts in securities that may also be, or have been or will be, purchased or sold for the accounts of Settian Capital’s clients. As noted in Item 10 above, Settian Capital may manage proprietary accounts on behalf of certain members of the organization. These proprietary accounts may invest in certain securities also purchased and sold for client accounts and may also purchase securities that are not acquired for client accounts. It is important to note that these accounts are not subject to the trading restrictions noted above with respect to personal securities accounts. Please see Item 12 below for more information regarding trading allocations, including those applicable to the proprietary accounts. Please also refer to Item 10 above for information regarding potential conflicts of interest.

In choosing a broker-dealer platform through which to effect trades, Settian Capital seeks to select the broker-dealer on the basis of its capabilities, expertise in executing transactions for client accounts and its overall execution abilities. Given the use of a single platform, however, Settian Capital is limited in its ability to negotiate best price and execution on a per trade basis. Additionally, Settian Capital may pay brokerage commissions in excess of those which other brokers might have charged for effecting the same transactions. Other factors considered by Settian Capital in choosing a broker-dealer platform include the brokerdealer’s research products and services and the success of prior research recommendations (collectively, “Research”), and its ability to execute difficult trades (possible market impact, size of the order and market liquidity), commitment of capital, access to new issues, nature and frequency of sales coverage, depth of services provided, including economic or political coverage, back office and processing capabilities, financial stability and responsibility, reputation, access to markets, confidentiality, commission rate, and responsiveness to Settian Capital. As noted above, in return for effecting securities transactions through its broker-dealer platform, Settian Capital may receive Research which assists Settian Capital in its investment decision-making processes. Research may include, among other things, proprietary research from broker-dealers, which may be written or oral; software and related support services for use in research and trading and/or computer databases; market, economic and financial data and statistical information; data on pricing and the availability of securities; publications; access to conferences; electronic market quotations; performance measurement services; analyses and/or due diligence concerning specific securities, companies or sectors, including due diligence on specific aspects of a company's operations or finances; analyses on issues

raised in proxy statements; and market, economic and financial studies and forecasts. Research may be in written, oral or online format and may be produced by broker-dealers or third parties such as attorneys, accountants or consultants. When Settian Capital uses client commissions to buy Research, it receives an economic benefit because it does not have to furnish or pay for the Research itself. Because clients pay somewhat higher commissions to generate soft dollars, Settian Capital faces a conflict of interest between its need to access the Research and a client’s investment accounts’ interest in paying the lowest possible commission rates available. It is also possible that some clients who generate little to no soft dollar commissions may benefit from the Research obtained from commissions generated from other client accounts. Although the Research obtained by Settian Capital may be used to service some or all of Settian Capital’s clients, a brokerage commission paid by a specific client may be used to pay for Research that is not used in managing that specific client’s account. Settian Capital does not consider client referrals in selecting broker-dealers.

Aggregation and Allocation Practices Settian Capital will generally execute transactions for clients on an aggregated basis where possible and when Settian Capital believes that to do so would be in the best overall economic interests of the clients. In accordance with its fiduciary duty, it is Settian Capital’s policy that all clients be treated fairly, subject to client-imposed and other constraints. A number of factors are taken into consideration when allocating investment opportunities among Settian Capital’s clients, including investment objectives and strategies, risk tolerances, tax status, size of client accounts, size of available positions, current market conditions, total portfolio invested positions and the nature of the security to be allocated. From time to time, Settian Capital may be allocated the opportunity to purchase securities in initial public offerings expected to be heavily over-subscribed. These allocations may be offered to Settian Capital in part as a result of its usage of one or more brokerage platforms or firms. Settian Capital may allocate securities purchased in these offerings to client accounts based on a number of factors including the client’s investment objectives and strategies. Settian Capital may aggregate orders in which Settian Capital, its affiliates and/or employees have a financial interest, including but not limited to proprietary trading accounts managed on behalf of employees of Settian Capital. In such circumstances, no client will be favored over any other client. All orders in the same instrument that were aggregated and executed with a particular broker-dealer during a day will generally receive an average share price, pay the same commission rates, and share any brokerage costs or other expenses of the order on a pro rata basis, based on order size. All aggregated orders will generally be allocated according to the designations made by the portfolio manager of such client accounts. Client orders partially filled will, as a general matter, be allocated pro rata in proportion to each client's original order. Where it is not meaningful to allocate a small number of securities among the accounts participating in the transaction on a pro-rata basis, Settian Capital may allocate such securities to less than all of the participating accounts in a manner determined in good faith to be a fair and equitable allocation over time. Notwithstanding the above, due to differing tax ramifications, as well as dissimilar risk constraints and tolerances, accounts with similar investment mandates may trade the same securities at differing points in time or may not participate in trades in which other accounts may participate. Additionally, for the reasons noted above, certain accounts, including proprietary accounts as well as the Private Fund in which Settian Capital, its affiliates and/or employees (“Settian Capital Funds”) have a financial interest, may trade separately from other accounts and participate in transactions which are deemed to be inappropriate for other accounts with similar investment mandates.

From time-to-time Settian may, but is not obligated to, issue other communications to investors in the Private Fund regarding the fund’s portfolio and/or performance. Settian does not routinely issue portfolio and/or performance reporting to clients with separately managed accounts. Under normal circumstances clients should be able to access such information through their account custodians. Settian encourages any client which requires specialized portfolio and/or performance reporting to retain the services of a third-party account administrator.

As disclosed to the client or investor, the Agent's compensation may or may not increase the referred client’s or investor's fees beyond that which Settian Capital would otherwise charge the client or investor for its investment management services. Settian Capital will benefit from arrangements whereby clients are referred directly to it and investors are referred directly to the Private Fund, since Settian Capital’s management fees are generally based upon a percentage of such client's or such investor’s assets under management. Thus, the more assets Settian Capital has under management, the higher its fee income.

independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and (ii) the Private Fund distributes its audited financial statements to all investors within 120 days of the end of its fiscal year.

investment management agreement. Settian Capital’s authority may be limited by client-imposed investment objectives and strategies. Settian Capital assumes any discretionary authority through the signed investment management agreement. From time to time, Settian Capital may, but is not obligated to, execute specific client transaction requests submitted for tax management purposes. Nonetheless, Settian Capital reserves the right to refuse any or all such specific requests. Settian Capital also may, in its sole discretion, limit any such transactions by account size, transaction size, operational complexity, or any other criterion as determined solely by Settian Capital.

Settian Capital believes that, in most instances, supporting the management of companies in which it invests serves the best financial interests of its clients. Nonetheless, Settian Capital maintains the right to vote in contravention of a recommendation made by management when Settian Capital believes that doing so is in the best interest of Settian Capital’s clients. Settian Capital has adopted specific procedures that address proxy voting responsibilities, material conflicts of interest, if any, record keeping, due diligence activities with respect to certain voting activities undertaken by the proxy voting service and disclosure requirements. Furthermore, as part of Settian Capital’s policy, the firm may abstain from voting a proxy when it is determined that the cost of voting the proxy exceeds the expected benefit to the client or, in the sole discretion of Settian Capital, when it believes that it is acting in the best interest of its clients. There may be occasions where the voting of proxies may present an actual or perceived conflict of interest between Settian Capital and its clients. Settian Capital will not vote proxies contrary to the best interest of its clients due to business or personal relationships with an issuer’s management, participants in proxy contests, corporate directors or candidates for corporate directorships, or where Settian Capital or an employee may have a personal interest in the outcome of a particular matter before shareholders. When there exists an actual or potential conflict of interest, Settian Capital will engage a third party to vote the proxies on behalf of clients. Settian Capital generally does not accept client directed proxy voting requests, but may do so, in its sole discretion, on a case-by-case basis. Any client who wishes to discuss a particular proxy vote may contact Kristofer Segerberg at the number on the front of this Brochure or by email at segerberg@pavpcapital.com. Clients may also contact Settian Capital to obtain information on how proxies were voted for a client and to request a copy of Settian Capital’s proxy voting policies and procedures. Settian Capital may, but is not obligated to, participate in and file class action lawsuit claims on behalf of all of its clients. Settian Capital may determine not to file a claim on behalf of a client account for reasons including but not limited to the following: (i) in cases where a client account has closed prior to a class action lawsuit being filed, Settian Capital may not file a claim on such client’s behalf due to

administrative burdens outweighing anticipated benefits to the client; (ii) after conducting a cost-benefit analysis, Settian Capital may choose not to file a claim on a client’s behalf where the cost of filing would exceed any anticipated benefits to the client; and/or (iii) circumstances in which Settian Capital believes that participation in the class action suit could otherwise be harmful to existing clients’ interests. Additionally, Settian Capital cannot guarantee that it will be notified of any particular class action suit in a timely manner.