Ashoka Whiteoak Capital Pte. Ltd.: investment adviser

The Adviser also provides investment supervisory services to separately managed accounts and sub-advisory services to an investment company registered under the Investment Company Act. The Adviser makes investments generally in transferable securities and derivative products thereof for the Private Funds and separately managed accounts. The Adviser’s advisory services consist of investigating, identifying and evaluating investment opportunities, structuring, negotiating and making investments on behalf of the Clients, managing and monitoring the performance of such investments, and disposing of such investments. The Adviser provides investment management and supervisory services to its Clients in accordance with the terms of the respective governing documents, including subscription agreements for its advised Private Funds, or investment advisory agreements for separately managed accounts and the registered investment company (each, an “Advisory Agreement”). Investment advice is provided directly to the Private Funds or to other advisors managing the Private Funds, and not individually to the investors in the Private Funds. Services are provided to the Private Funds in accordance with the Investment Management Agreements with the Private Funds and/or organizational documents of the applicable Private Fund. Investment restrictions for the Private Funds, if any, are generally established in the organizational or offering documents of the applicable Private Fund, Advisory Agreements and/or side letter agreements negotiated with investors in the applicable Private Fund (such documents collectively, a Private Fund’s “Organizational Documents”). The Adviser does not participate in wrap fee programs. As of 31 March 2026 the Adviser’s regulatory assets under management consisted of the following:  

Discretionary: $ 5,378,766,539.21 Non-Discretionary: $ 0

Management Fees As compensation for investment management and supervisory services rendered to the Private Funds, the Adviser receives from each such Private Fund a Management Fee typically at an agreed fixed rate, calculated by the Private Fund’s NAV. Management Fees paid by a Private Fund may also be reduced by other fees or compensation received by the Adviser or its affiliates that relate to such Private Fund’s activities and investments, or by certain organizational or other expenses borne by such Private Fund, as described in more detail below. Management Fees paid by a Private Fund are indirectly borne by investors in such Private Fund. The precise amount and calculation of the Management Fees for each Private Fund are set forth in such Private Fund’s Agreements. Management Fee structures can differ from one Private Fund to another. As compensation for investment management services rendered to separately managed accounts, the Adviser receives a Management Fee and/or Performance Based fees, at an agreed fixed rate, calculated based on the account’s assets under management and/or performance of the account. As compensation for sub-advisory services rendered to the registered investment company, the Adviser receives a Management Fee calculated based on the company’s assets under management.

Expenses Adviser Expenses To the extent provided in the Agreements of the Private Funds, the Adviser will pay out of Management Fees all expenses and costs incurred by the Adviser in the course of providing services to the Private Funds, including compensation of its investment professionals, rent, utilities, office expenses, those travel costs which are not related to Private Funds’ expenses under the Organizational Documents, audit costs, staff recruitment costs, insurance costs, information technology costs, marketing costs, legal expenses, software costs, database costs and printing costs. Management Fees and sub-advisory fees received also contributes to these Adviser expenses.

Private Fund Expenses Each Private Fund is responsible for paying its own organizational, operating and related expenses as described below and in the applicable Organizational Documents. In cases where multiple Private Funds, properties or entities incur or benefit from a specific expenditure, Adviser will allocate the expense by estimating the relative usage and benefit that each such Private Fund, property or entity obtains from the expense, as more fully described below. The Private Funds are responsible for travel expenses related to their respective businesses. Such expenses include the Private Fund’s Directors’ coach or economy class airfare for most domestic travel and, for transcontinental, international destinations or other longer duration flights, business or first class airfare.

Allocation of Expenses From time to time the Adviser will be required to decide whether certain fees, costs and expenses should be allocated between or among Private Funds and/or other parties. Certain expenses may be the obligation of one particular Private Fund and may be borne by such Private Fund or, expenses may be allocated among multiple Private Funds and entities. The Adviser will allocate fees and expenses incurred in connection with the operations and management of a Private Fund between the Adviser and such Private Fund in accordance with the Organizational Documents of such Private Fund or Private Funds. However, while the Adviser intends to use good faith and its best judgment in connection with any such allocation, such

allocations may require inherently subjective determinations and give rise to conflicts of interest due to the inherent biases in the process. The appropriate allocation among the Private Funds of expenses and fees generated in the course of evaluating and making investments often may not always be clear, especially where more than one Private Fund participates. For instance, if multiple Private Funds are considering making an investment that is not consummated, allocation of the expenses generated for the account of such Private Funds (such as expenses of common counsel and other professionals) will be made in good faith. In general, the Adviser intends to resolve all such matters on a pro-rata basis, using its best judgment, considering all factors it deems relevant. With respect to allocating other expenses among Private Fund(s), Adviser, Investors and/or Third Parties, as appropriate, to the extent not addressed in the Organizational Documents of a Private Fund, the Adviser will make any such allocation determination in a fair and reasonable manner using its good faith judgment, notwithstanding its interest (if any) in the allocation. The Adviser will make any corrective allocations and take any mitigating steps if it determines such corrections are necessary or advisable. Notwithstanding the foregoing, the portion of an expense allocated to a Private Fund for a particular service may not reflect the relative benefit derived by such Private Fund from that service in any particular instance.

Compensation and Fee Schedules All investors should review the Governing Documents for each Private Fund in conjunction with this brochure for more complete information on the fees and compensation payable with respect to a particular Private Fund. Investors and prospective investors in the Private Funds should note that similar advisory services may (or may not) be available from other investment advisers for similar or lower fees. Deduction of Fees White Oak is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Private Funds and any separately managed account, at the times and in the amounts described above. Other Fees and Expenses In addition to the fees payable to White Oak, the Private Funds will incur certain charges imposed by third parties, including (but not limited to) any sales or other taxes, fees or government charges that may be assessed against The Private Funds; placement agent fees; the costs and expenses (including travel-related expenses) of holding meetings or conferences with the Private Funds’ investors; all expenses relating to litigation and threatened litigation involving the Private Funds; indemnification obligations and expenses; expenses attributable to normal and extraordinary investment banking, commercial banking, accounting, auditing, appraisal, tax advisory, tax preparation, legal, external consulting, custodial and registration services provided to the Private Funds; and the costs and expenses for tax and audit services to the Private Funds. Timing of Payments Management Fee payments are generally due monthly in arrears. Please refer to the Private Fund’s Governing Documents for more complete information on the timing of management fee payments.

fees are separate and distinct from the advisory management fees charged by White Oak under the Advisory Agreement. Performance-Based Fees may create an incentive for White Oak to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Please refer to the Organizational Documents of each White Oak Private Fund for more complete information on the “performance-based fee” arrangements of each White Oak Private Fund. Side-by-Side Management White Oak may provide concurrent advisory services to clients that are not charged a performance-based fee by the Adviser. As a result, the potential for the Adviser to receive greater fees or allocations from performance-based accounts creates a conflict of interest with respect to the allocation of investment opportunities, as White Oak may have an incentive to direct the best investment ideas to, or to allocate investments in favor of, the account that pays a performance fee or allocation. To alleviate potential conflicts of interest, the allocation of commitments and investment decisions with respect to each White Oak Private Fund, subadvised and separately managed accounts are made by the Adviser in accordance with White Oak’s investment allocation policy, which takes into account multiple criteria for the Private Funds, sub-advised and separately managed accounts, including: specific objectives of each Private Fund, sub-advised and separately managed accounts, the size and capital available for investment, diversification needs, the size of the investment opportunity, current and anticipated market conditions, specific investment restrictions or guidelines applicable to each White Oak Private Fund, sub-advised and separately managed accounts, and relevant tax or regulatory considerations. In the event investment opportunities are suitable for more than one White Oak Private Fund, sub-advised and separately managed accounts, the Adviser will allocate such investment opportunities in a manner that is fair and equitable to each Private Fund, sub-advised and separately managed account relative to the other Private Funds, sub-advised and separately managed accounts over time, taking into account all relevant facts and circumstances.

Minimum Investment Requirements White Oak ensures that US investors in each of the Private Funds are “accredited investor” as defined in Regulation D under the Securities Act. In addition, White Oak requires that US investor in each of the Private Funds be a “qualified purchaser” as defined in the Investment Company Act.

In addition, there can be no assurance that any investor in any Private Fund advised by the Adviser will receive any distribution from a White Oak . Investing in the Private Fund involves a risk of loss that investors should be prepared to bear. Investors in the Private Funds should carefully consider, among other factors, the following material risks involved with White Oak’s investment strategies. Investors in the Private Funds are requested to refer to the Governing Documents of the applicable White Oak Private Fund for more complete information on investment strategies employed by the White Oak and the corresponding risks associated with such investment strategies. In the following risk disclosures, “the Private Fund” may refer to any Private Fund advised by White Oak. INVESTMENT RISKS Asset Class Risk The equity market and the prices of various stocks and derivative underlyings may fluctuate widely based on a variety of factors including global, jurisdiction-specific macro-economic conditions, and stock specific factors. The performance of futures could be substantially different from the performance of underlying securities. Counterparty Risk The institutions, including brokerage firms and banks, with which the Adviser does business, or to which securities have been entrusted for custodial purposes, may encounter

financial difficulties that impair the operational capabilities or the capital position of client accounts. There is a risk that any of such counterparties could become insolvent. The insolvency of the Adviser’s counterparties is likely to impair the operational capabilities of the Adviser. No Control Over Portfolio Companies Accounts may acquire significant positions in the securities of particular companies. Nevertheless, the Adviser is unlikely to be represented on the board of directors or share any control over the management of any such company. Opposition of management or existing investors of portfolio companies, especially in the absence of an effective legal framework to protect minority shareholder/ creditor’s rights, could jeopardize Adviser’s strategy. The success of each investment depends on the ability and success of the management of that company in addition to economic and market factors. Smaller Company Risk Adviser may invest in the securities of small or medium-size companies that may be more susceptible to market downturns, and the prices of which may be more volatile than those of larger companies. Smaller companies generally pose greater investment risks because such companies have narrower markets and more limited managerial and financial resources than larger, established companies. Availability and Accuracy of Information The Adviser will select investments on the basis of information and data derived from firsthand research by the Adviser. Although the Adviser intends to evaluate all such information and data and to seek independent corroboration when the Adviser consider it appropriate and when it is reasonably available, the Adviser will not in many cases be in a position to confirm the completeness, genuineness or accuracy of such information and data. Reliance on Service Providers/ Intermediaries The Adviser may engage a variety of service providers, including but not limited to those in the areas of legal, tax, accounting, valuations, custodial services, bankers etc. In the event any such persons have any adverse development which affects their performance of duties with their clients or they breach any of the terms of engagement, the Adviser might be posed with a risk, which might be significant. Systems Risk High volume trading will frequently occur at the market opening and before market close. Such high volumes may also occur at any point in the day. These may cause delays in order execution or confirmation. During periods of volatility, on account of market participants continuously modifying their order quantity or prices or placing fresh orders, there may be

delays in execution of order and its confirmation. Therefore, under certain market conditions, it may be difficult or impossible to liquidate a position in the market at a reasonable price or at all, when there are no outstanding orders either on the buy side or the sell side, or if trading is halted due to any action on account of unusual trading activity or price hitting circuit filters or for any other reason. System/ Network Congestion Trading on the exchange is in electronic mode, based on satellite/ leased line communications, combination of technologies and computer systems to place and route orders. Thus, there exists a possibility of communication failure or system problems or slow or delayed response from system or trading halt, or any such other problem/glitch whereby not being able to establish access to the trading system/network, which may be beyond the control of and may result in delay in processing or not processing buy or sell orders either in part or in full. Performance Risks Client accounts may be invested directly or indirectly in companies in highly competitive markets or product segments dominated by firms with substantially greater financial and technical resources. Companies in which client accounts invests may operate in product segments that face technological changes and/or may be dominated by other firms or organizations. These and other inherent business risks could affect the performance of these companies and affect the value of investments, thereby affecting client accounts as a whole, due to their involvement in these companies. Illiquidity of Portfolio Investments Client accounts may be invested in markets which are smaller and potentially more volatile than securities markets in more developed economies, and these securities markets could experience problems that could affect the market price and liquidity of the securities of portfolio companies. Material Information Regarding Portfolio Companies The Adviser may enter into discussions with professionals and agents to in the process of shortlisting of portfolio companies, and the Adviser often will be required to make decisions without complete information or in reliance upon information provided by third parties that is impossible or impracticable to verify. The marketability and value of each investment will depend upon many factors beyond the control of the Adviser. On the other hand, if the Adviser, its employees or Affiliates come in contact with non-public price sensitive information regarding any portfolio company, such persons may be restricted from initiating transactions in the securities of such portfolio companies. RISKS SPECIFIC TO THE FUNDS Concentration of Investments

Although it will be the policy of the Private Fund to diversify its investment portfolio, the Private Fund may at certain times hold relatively few investments. The Private Fund could be subject to significant losses if it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including default of the issuer. Availability and Ability to Acquire Suitable Investments The Adviser will be competing with other investors having similar investment objectives including many of the larger investment banking firms, financial companies and other venture capital or private equity funds which have substantially greater financial resources than the Adviser, and have substantially greater numbers of research staff and more analysts than the Adviser has. There can be no assurance that the Adviser will succeed in finding investments on similar or more favourable terms in comparison to its competitors. Such competition may have an adverse effect on the ability of the Private Fund to successfully utilize the total commitments as well as on the length of time required for the same. Moreover, these investments are not free from risk and may be subject to the liquidation risk of the issuing entities. Exit Strategy The feasibility and terms of any proposed exit strategy for investments will depend in part on factors that are not within the control of the Adviser, at the time of the proposed disposition, such as the effect of applicable legislation and political and economic conditions. Consequently, the precise timing of the disposition of an investment and the manner of disposition are impossible to predict, and no assurance can be given that such disposition will be achieved on terms favorable to client accounts. Portfolio Risk Client accounts will have investments spread by asset type with varying exit horizons. Poor performance by even a few of these investments could lead to adverse effects on overall returns. Client accounts could be subject to significant losses if it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including default of the issuer. Portfolio Turnover While the Adviser generally intends to employ long-only, opportunistically the investment strategy may result in a short holding period before investments are rolled over into new investments or sold. This will cause the recognition of any investment gains. Some of these gains may not qualify for the holding period needed for long capital gains tax treatment. Therefore, taxable Investors in the Private Fund could have a greater need to pay regular taxes (out of their own resources or by requesting redemptions) than compared to other investment strategies that hold investments longer. The turnover of the Private Fund’s portfolio also may

generate substantial transaction costs, which will be borne by the Private Fund, and indirectly by the Investors, regardless of its profitability. Restrictions on Redemptions and Transfer Terms of redemptions and transfers are set out in the relevant Organizational Documents. No Assurance of Returns The investors are not being offered assured returns or redemption, and there will be no recourse to the Adviser. Accordingly, the ability of the Private Fund to pay returns on/redeem the Shares will depend on the realizations from the Private Fund investments. The funds available for distributions on the Shares, as well as upon termination/liquidation of the Private Fund, will be limited to the monies recovered on the Private Fund’s investments and to the balance funds after meeting all liabilities and obligations. The Private Fund will have no assets other than its monies contributed by the Investors and any distributions on the Shares shall be made only out of such funds. Deployment Risk Owing to the market conditions, the Private Fund may not be able to identify the assets to deploy the contributions received and therefore the same may be a deterrent factor for the Private Fund to achieve the targets laid down by the Adviser. Diverse Investor Group The Investors may have conflicting investment, tax and other interests with respect to their investments in the Private Fund. The conflicting interests of individual investors may relate to or arise from, among other things, the nature of investments made by the Private Fund, the structuring or the acquisition of investments and the timing of disposition of investments. As a consequence, conflicts of interest may arise in connection with decisions made by the Adviser, including with respect to the nature or structuring of investments that may be more beneficial for one investor than for another investor, in particular with respect to investors’ individual tax situations. In selecting and structuring investments appropriate for the Private Fund, the Adviser will consider the investment and tax objectives of the Private Fund and its investors as a whole, not the investment, tax or other objectives of any Investor individually. Foreign Currency Exposure As the portfolio of the Private Fund(s) may consist of securities denominated in non-US dollars (“US$”), the NAV of the Private Fund, when measured in US$, will, to the extent this has not been hedged against, be affected by changes in the value of the securities’ currency relative to US$. The Adviser may, but is not obligated to, hedge the portfolio’s exposure to the non-US$ back to US$. The use of hedges involves special risks, including the possible default by the other party to the transaction, illiquidity and, to the extent the Adviser’s assessment of certain market movements is incorrect; the risk that the use of hedges could result in diminished returns or losses greater than if the hedging had not been used. Hedging arrangements may have the effect

of limiting or reducing the total returns to the Private Fund if the Adviser’s expectations concerning future events or market conditions prove to be incorrect. In addition, the costs associated with a hedging program may outweigh the benefits of the arrangements in such circumstances. Borrowings/ Leverage The Private Fund may undertake short-term borrowings to meet its temporary liquidity requirements, including for the purposes of effecting investments and redemptions. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. To the extent the Private Fund purchases securities with borrowed funds, its net assets will tend to increase or decrease at a greater rate than if borrowed funds are not used. The level of interest rates generally, and the rates at which such funds may be borrowed in particular, could affect the operating results of the Private Fund. If the interest expense on borrowings were to exceed the net return on the investments made with borrowed funds, the Private Fund’s use of leverage would result in a lower rate of return than if the Private Fund were not leveraged. Dependence on Key Personnel The Private Funds will be largely dependent upon the experience and judgment of the Adviser, its key management team or the Investment Committee for selection of suitable portfolio companies. Neither the key management team of the Adviser nor the Investment Committee is under any contractual obligation to remain with the Adviser for all or any portion of the Term. The key management team of the Adviser/ the Investment Committee will commit a suitable amount of its business efforts as may be necessary to the Private Fund, though it is not required to devote all of its time to the affairs of the Private Fund. They may manage other funds as well. The inability of the Adviser to attract and retain required talent pool may also adversely affect the performance of the Private Fund. Supervision of Trading Operations The Adviser intends to supervise and monitor trading activity in the Private Fund’s account to ensure compliance with the Private Fund’s objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in the Private Fund account. Management Fees As a result of payment of Management Fee, the returns realized by client accounts might be less than the returns the investors may have realized from engaging in the same activities directly if they had made such investments directly. Foreign Investment and Ownership Restrictions The governments of foreign securities issuers often restricts foreign investment in certain sectors. These restrictions have been progressively eased to permit foreign investments.

There is no guarantee, however, that this policy of liberation will continue. Any reversal could have a retroactive effect and affect existing investments and could also impact the Private Fund’s ability to enforce negotiated rights. Governmental Agreements in Respect of Anti-Corruption/ Ethical Practices The Adviser may enter into one or more agreements that have, as their principal purpose, the prevention, minimization, disclosure, monitoring or remedy of corruption or other unethical or inappropriate behavior in connection with any investment in, or other dealings with, the Private Fund by a governmental or quasigovernmental agency (such as a retirement plan for governmental or quasi-governmental employees). No prevailing market standard for such agreements exists, and it is possible that any such agreement may provide a governmental or quasi-governmental investor with rights or preferences (e.g., withdrawal rights) that are not available to other Investors and may, under certain circumstances, be contrary to the best interests of the Private Fund. Such agreements will be disclosed only to those actual or potential Investors that have separately negotiated with the Adviser for the right to review such agreements. Freedom of Information/ Sunshine Laws Under "freedom of information," "sunshine", "public records" and similar laws, certain governmental or other regulated entities such as state universities and pension funds may be required to publicly disclose confidential information regarding the Private Fund or its portfolio companies, notwithstanding contractual obligations (such as those contained in the Private Fund's Constitution) to the contrary. Any such disclosure could have a material adverse effect upon the Private Fund or its portfolio companies, and could even expose the Private Fund to claims for damages brought by portfolio companies or other persons related thereto. Nevertheless, the Private Fund's Constitution will not prohibit such entities from being admitted to the Private Fund. Risks Related to Pandemics and Related Diseases. Occurrence of pandemic and related diseases could potentially disrupt the firm’s operations and affect the ability of White Oak to operate effectively. Pandemics are impossible to predict, and the circumstances surrounding it will continue to evolve.

Inflation Risk. Inflation is a sustained rise in overall price levels. Moderate inflation is associated with economic growth, while high inflation can signal an overheated economy. Inflation risk is the risk that the value of assets or income from investments will be less in the future as inflation decreases the value of money (i.e., as inflation increases, the values of The Private Funds’ assets can decline). Inflation poses a “stealth” threat to Limited Partners because it reduces savings and investment returns. Central banks, such as the U.S. Federal Reserve, generally attempt to control inflation by regulating the pace of economic activity. They typically attempt to affect economic activity by raising and lowering short-term interest rates. At times, governments may attempt to manage inflation through fiscal policy, such as by raising taxes or reducing spending, thereby reducing economic activity; conversely, governments can attempt to combat deflation with tax cuts and increased spending designed to stimulate economic activity. Inflation rates may change frequently and significantly as a result of various factors, including unexpected shifts in the domestic or global economy and changes in economic policies, and The Private Funds’ investments may not keep pace with inflation, which may result in losses to Limited Partners. Geopolitical tensions. Geopolitical risks pose risks to global trade and could result in sanctions which in turn could lead to inflation and volatility in asset prices.

RISKS SPECIFIC TO NON-US JURISDICTIONS In general, the Adviser notes that the Organizational Documents of each Private Fund will include additional risk disclosures which define risks specific to the jurisdictions in which those Private Funds operate. There are regulatory, market, tax, accounting, and asset-specific risks associated with participation in each Private Fund. Investors should carefully consider these risks, in addition to the more generally applicable risks in this Item. POTENTIAL CONFLICTS OF INTEREST The following inherent or potential conflicts of interest should be considered by prospective investors in the Private Fund. In the event that a conflict of interest arises, the Adviser will endeavor to ensure that such conflict is resolved fairly. The Adviser, the Custodians and the Administrator and any of their Affiliates, respective officers, directors, employees and any person connected with them (“Interested Parties”) may from time to time act as director, Adviser, manager, custodian, registrar, broker, administrator, investment advisor, distributor or dealer in relation to, or be otherwise involved in, other funds established by parties other than the Private Fund, as the case may be, which have similar or different objectives to those of the Private Fund. It is, therefore, possible that any of them may, in the course of business, have potential conflicts of interest with the Private Fund. In addition, subject to applicable law, any of the foregoing and their Affiliates may deal, as principal or agent, with the Private Fund, provided that such dealings are carried out as if effected on normal commercial terms negotiated on an arm’s length basis. The Interested Parties may invest in, directly or indirectly, or manage or advise other investment funds or accounts which invest in assets which may also be purchased or sold by the Private Fund. None of the Interested Parties is under any obligation to offer investment opportunities of which any of them becomes aware to the Private Fund or to account to the Private Fund in respect of (or share with the Private Fund or inform the Private Fund of) any such transaction or any benefit received by any of them from any such transaction, nor be obliged to account to the Private Fund for any profits or benefits made or derived therefrom, nor shall they have any obligation to disclose or refer to the Private Fund any of the investment or service opportunities obtained through such activities, but will allocate such opportunities on an equitable basis between the Private Fund and other clients. In addition, subject to applicable law, any of the foregoing may deal, as principal or agent, provided that such dealings are carried out as if effected on normal commercial terms negotiated on an arm’s length basis. Interested Parties may own Shares in the Private Fund, deal as principals with the Private Fund in the sale or purchase of investments of the Private Fund or act as brokers, whether to the Private Fund or to third parties, in the purchase or sale of the Private Fund’s investments and shall be entitled to retain profits or customary commissions resulting from such dealings. Generally The Adviser may cause the Private Fund to invest in instruments in which one or more parties or affiliated entities own an interest and accordingly may derive additional fees or other benefits from such other investments. The Interested Parties may from time to time

conduct business with persons or entities which invest, or whose clients invest, in the Private Fund, may deal with the Private Fund in multiple capacities, may have dealings with others doing business with the Private Fund or engaged in competitive activities and may earn fees from or receive or provide other consideration from or to any of the foregoing. Other Activities by the Adviser/ Interested Parties The Adviser and each of its directors presently and will in the future, directly or indirectly, direct, sponsor or manage multiple accounts. The Adviser and each of its directors may have financial or other incentives to favor some such accounts over the Private Fund. However, some conflicts may arise due to some of the officers of the Adviser having duties in connection with other investment funds/matters. Such officers may have conflicts of interest in allocation of responsibilities, services and functions among the Private Fund and other similar entities to the Private Fund. Placement Agents Subject to applicable laws and regulations, certain placement agents engaged by the Advisor may be paid ongoing compensation while investors introduced to the Private Fund by them are Shareholders thereof. Accordingly, such placement agents will have a conflict of interest in advising investors whether to purchase or redeem Shares.

Relationships with Related Persons As discussed in the section titled “Participation or Interest in Client Transactions; Personal Trading,” the Adviser and its related persons are, directly or indirectly, the directors and/or managing members of each of the Private Funds. White Oak and its related persons may spend substantially all of their business time on one or more of the Private Funds as required pursuant to the terms of each advised Private Fund’s Governing Document.

Additionally, White Oak is a related party to the following investment advisers: Acorn Asset Management Ltd; White Oak Capital Management (Spain), Sociedad Limitada; White Oak Capital Management Consultants LLP; Ashoka Whiteoak Capital Management (GIFT) LLP, and WhiteOak Capital Asset Management Limited. The above advisers are under common control with White Oak, and certain executives of the Adviser serve as executives to these related parties. All investment advisers listed provide non-binding advisory services. Besides the Adviser, none of the investment advisers are registered with the SEC as Registered Investment Advisers. Selection or Recommendation of Other Advisers White Oak does not recommend or select other investment advisers for its clients and receive compensation from such advisers in a manner that would create a material conflict of interest.

All supervised personnel must acknowledge the terms of the Code of Ethics annually, or as amended. It is the expressed policy of White Oak that no person employed by White Oak shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with its Code of Ethics, White Oak requires that anyone associated with its advisory practices with access to advisory recommendations provide securities holdings reports and quarterly transaction reports to the firm’s Compliance department . White Oak requires such “access persons” to also receive approval from the Compliance department prior to investing in any initial public offerings or private placements. In an effort to prevent inappropriate securities transactions by White Oak’s personnel, the Compliance department will maintain and make available a list of restricted securities. The restricted securities list will be updated periodically and will include securities: (i) held by a White Oak Private Fund with respect to a portfolio investment; (ii) under active investment consideration by White Oak; (iii) held by a White Oak Private Fund as a result of a distribution from a portfolio investment or which White Oak knows or believes will be so distributed to a White Oak Private Fund; (iv) being issued in an IPO or private placement; and (v) about which any access person is in possession of, or knows, material nonpublic information. Access persons are strictly prohibited from trading on their own behalf in restricted securities without obtaining the prior written approval of the Compliance department. White Oak requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. White Oak’s Code of Ethics also includes the firm’s policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline or termination.

White Oak will provide a complete copy of its Code of Ethics to any person upon request.

Securities transactions will be executed through brokers selected by White Oak in its sole discretion and without the consent of investors. In placing portfolio transactions, White Oak will seek to obtain the best execution for the clients, taking into account the following factors: the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the broker; the broker’s risk in positioning a block of securities; the quality, comprehensiveness and frequency of available research services considered to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying White Oak's other selection criteria. White Oak is authorized to pay higher commissions to such firms if White Oak determines such prices or commissions are reasonable in relation to the overall services provided. White Oak is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services required to be performed by White Oak and White Oak's allocations and fees are not reduced as a consequence of the receipt of such supplemental research information. Research services provided by broker-dealers used by the clients and the Private Funds may be utilized by White Oak or its affiliates (including other investment funds managed by such persons) in connection with their other investment activities. Since commission rates are negotiable, White Oak's selection of brokers on the basis of considerations which are not limited to applicable commission rates may at times result in Clients being charged higher transaction costs than it could otherwise obtain. Soft Dollar Arrangements. The term “soft dollars” refers to a means of paying brokerage firms for products and services through commission revenue, based on the volume of brokerage commission revenues generated from securities transactions executed through brokers by an Adviser on behalf of advisory clients. Section 28(e) of the Securities 22 Exchange Act of 1934, as amended allows White Oak to pay broker-dealers more than the lowest commission available in order to obtain research and brokerage services without breaching its fiduciary duties to clients or imposing a duty upon White Oak to obtain the lowest commission if certain conditions are met and White Oak makes a good faith determination that the commissions paid are reasonable in relation to the value of the brokerage or research services on behalf of its advisory clients. The determination may be

viewed in terms of either the particular transaction involved or the overall responsibilities of White Oak with respect to the accounts over which it exercises investment discretion. In determining if something is research, thus falling within the safe harbor provisions, the controlling principle is whether it provides lawful and appropriate assistance to the money manager in the performance of its investment decision-making responsibilities. Certain brokerage and research products and services utilized by White Oak are categorized as mixed-use items that are partially paid for with soft dollars. Pursuant to the guidance set forth in the July 18th, 2006 SEC Interpretive Release regarding permissible client commission practices, White Oak partially pays for mixed-use items with soft dollars after reasonably allocating between eligible and ineligible uses and making a good faith determination that the commissions being paid are reasonable in light of each of the brokerage and research services that are provided. Information so received is in addition to and not in lieu of services required to be performed by White Oak and the Management Allocation and Performance Fee are not reduced as a consequence of the receipt of such supplemental research information. Because commission rates in the are negotiable, White Oak's selection of broker-dealers on the basis of considerations which are not limited to applicable commission rates may at times result in a client and the Private Funds being charged higher transaction costs than it would otherwise obtain. Nonetheless, White Oak's decision on which broker-dealer to utilize will be fully driven by a concerted effort to seek best execution. Research services received from brokerdealers are supplemental to White Oak’s own research effort and, when utilized, are subject to internal analysis before being incorporated by White Oak into its investment process. As a practical matter, it would not be possible for White Oak to generate all of the information presently provided by broker-dealers. White Oak pays cash for certain research services received from external sources. White Oak also allocates brokerage for research services, which are available for cash. While the receipt of research services from brokerage firms has not reduced White Oak’s normal research activities, the expenses of White Oak could be materially increased if it attempted to generate such additional information through its own staff. To the extent that broker-dealers provide research services of value, White Oak is relieved of expenses, which it may otherwise bear. In addition, White Oak has an incentive to select a broker dealer based on its interest in receiving research or other products or services, rather than client’s interests in receiving lower transaction costs. Certain broker-dealers who provide quality brokerage and execution services also furnish research services to White Oak. In selecting a broker-dealer, White Oak may consider, among other things, the broker-dealer’s best execution capabilities, reputation, and access to the markets for the securities being traded. White Oak will generally seek competitive commissions for transactions for advisory client’s accounts. Consistent with obtaining best execution, transactions for advisory clients may be directed to brokers in return for research services furnished by them to White Oak. Such research generally will be used to service all of White Oak's advisory clients, but brokerage commissions paid may be used to pay for research that is not used in managing a specific account. Therefore, research may not necessarily benefit all accounts paying commissions to such brokers. Accordingly, White Oak cannot readily determine the extent to which commission rates charged by broker-dealers reflect the value of their research services. White Oak generally assesses the reasonableness of commissions in light of the total brokerage and research services provided by each

particular broker-dealer. We use client brokerage commissions to obtain research or other products or services and receive a benefit because we do not have to pay for the research, products, or services. We have a conflict of interest in that regard because of our incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products and services, rather than on our clients’ interest in trading at the most favorable prices. White Oak receives a wide range of services from broker-dealers. These services include: information on the economy, industries, groups of securities, individual companies, statistical analysis, performance analysis, and analysis of corporate responsibility issues. These services provide both domestic and international perspective. Research services are received primarily in the form of written reports, computer generated services, telephone contacts, and personal meetings with security analysts. In addition, such services may be provided in the form of meetings arranged with corporate and industry spokespersons, economists, academics and government representatives. In some cases, research services are generated by third parties but are provided to White Oak by or through broker-dealers. Cross Trades. White Oak may engage in cross-trading in limited circumstances. “Crosstrading” involves the purchase and sale of securities between accounts managed by the Company. White Oak does not intend to engage in cross-trading on a regular basis. However, White Oak may effect cross-trades in the future when it believes it is in the best interest of its clients to do so. Cross trades in which White Oak has engaged, and any cross trades in which White Oak engages in the future, have been and will be effected in accordance with procedures designed to ensure that any cross trades between accounts managed by White Oak are consistent with its obligation to achieve “best execution” for its Private Funds and that no Private Fund is disfavored by cross-trading. White Oak will not receive any fees or compensation in connection with cross-trading. White Oak will not effect cross trades involving any account subject to ERISA unless the cross trade complies with an ERISA exemption.

Nevertheless, the receipt of compensation by the placement agents creates a potential conflict of interest, and may affect the judgment of placement agents and broker-dealers when making referrals to White Oak and The Private Funds.

In situations where there is a conflict of interest or appearance of a conflict of interest, the Adviser will cast the proxy votes in a manner consistent with the best interest of the clients and shall place those interests ahead of its own. The Adviser will take necessary steps to ensure that a decision to vote the proxy was based on the Adviser’s determination of the client’s best interest and was not the product of the conflict. Investors may contact the Adviser for a copy of the policy or information with respect to a specific client proxy vote, at no cost. Class Action In addition, if any “Class Action” documents are received by the Adviser on behalf of any advised pooled investment vehicle, the Adviser will ensure that the pooled investment vehicle either participates in, or opts out of, any class action settlements received. Adviser will determine if it is in the best interest of the partnerships to recover monies from a class action. The portfolio manager/analyst covering the company will determine the action to be taken when receiving class action notices. In the event the Adviser opts out of a class action settlement, the Adviser will maintain documentation of any cost/benefit analysis to support its decision.