59 North Capital Management, LP: investment adviser

The Domestic and Offshore Feeder Funds invest their assets in the Master Fund. Additionally, 59 North Capital manages one separately managed account on a discretionary basis (the “SMA” and together with the Funds the “Clients” or “Client Accounts”). The Clients are managed in accordance with their own investment objectives as set forth in the relevant governing and offering documents (each, a “Governing Document” and, collectively, the “Governing Documents”). Investment objectives are not tailored to any particular private investor (each, an "Investor"). 59 North Capital does not participate in wrap fee programs. As of December 31, 2025, 59 North Capital had approximately $7,503,173,537 in regulatory assets under management on a discretionary basis on behalf of its Clients.

For example, investors in the Funds who are associated with 59 North Capital, such as its officers or employees, generally do not pay management fees though they do pay their pro-rata share of private fund operating costs. The management fee may vary by Client Account. The Governing Documents specify the fees applicable to each Client Account. The SMA is also charged a management fee each quarter as described in the relevant Governing Documents.

Other Expenses The Master Fund will bear all expenses relating to its ongoing structure and operation, including: (i) the management fee; (ii) all investment-related costs and expenses, i.e., expenses that, in the Adviser’s sole discretion, are related to the investment of the Funds’ assets; (iii) fees and expenses related to portfolio exposure and performance, management systems, risk management services and software related to trade reconciliation, treasury, margin, financial and counterparty management; (iv) the Funds’ legal, accounting, tax preparation and other tax-related expenses, auditing, consulting and other professional expenses; (v) third-party administration costs, fees and expenses; (vi) all fees and charges of custodians, clearing agencies and banks; (vii) compliance and reporting expenses and expenses attributable to regulatory filings; (viii) the Adviser’s pro rata share of related insurance costs; (ix) any taxes; (x) all costs and expenses incurred in attempting to protect and enhance the value of the Funds; (xi) fees and expenses related to any activist-related activities; (xii) any fees and expenses related to the Adviser’s liquidation, if applicable; (xiii) fees paid to proxy and securities class action advisory firms; (xiv) expenses relating to the offer and sale of Interests and withdrawals and transfers thereof; and (xv) other reasonable expenses related to the purchase, sale, preservation or transmittal of the Fund’s assets. Generally: To the extent that any of the foregoing expenses relate to the operations of one or more other funds or accounts managed by the Adviser or any of their respective affiliates, 59 North Capital will attempt to allocate such expenses based on a good faith determination of the relative benefits of such expenses to all such funds and accounts benefiting from such expenses. Any expense common to any other private fund clients or accounts managed by the Adviser or its affiliates generally will be paid pro rata by such entities based on the approximate size of the relevant investment relating to such expense or otherwise on assets under management, as appropriate (or in any other manner deemed fair and equitable by 59 North Capital, in its sole discretion). The Adviser remains responsible for its overhead expenses of an ordinary and recurring nature, such as rent, supplies, secretarial expenses, its direct compliance expenses, stationery, charges for furniture and fixtures, salaries and bonuses of its employees, employee insurance, employee benefits and payroll taxes. The Adviser has adopted policies and procedures intended to address trade errors to ensure that the Clients are treated fairly. Subject to any contractual limitations set forth in the relevant Clients’ governing documents, the Adviser has discretion to resolve a particular error in a manner that it deems appropriate and consistent with the Adviser’s policies and procedures. For information on the Adviser’s brokerage and transaction costs, please see “Item 12 – Brokerage Practices.”

its officers or employees, generally do not incur any performance fees. The performance fees may vary by Client Account. The Governing Documents will specify the fees applicable to each Client Account. Generally: The Adviser has adopted policies and procedures intended to address conflicts of interest that may arise relating to the management of multiple Client accounts, including accounts with different fee arrangements and the allocation of investment opportunities. The Adviser reviews investment decisions for the purpose of ensuring that all accounts with substantially similar investment objectives are treated equitably. It is the Adviser’s general policy to trade the portfolios of all Clients on a pari passu basis based on relative capital. However, allocations may be made on a basis other than pro rata for a number of reasons, including, but not limited to: a Client’s investment guidelines and restrictions; available cash; liquidity requirements; tax or legal reasons; to avoid odd lots; or in cases in which such an allocation would result in a de minimis allocation to a Client. Each Investor should review the appropriate Governing Documents for more information on the applicable Incentive Allocation.

The approach embraces position‐level concentration in high‐conviction ideas, which are derived from a deep, independent, and disciplined research process. Risk of Loss The following explanation of certain risks is not exhaustive, but rather highlights some of the more significant risks associated with the investment strategies that the Adviser seeks to implement. Nature of Investments The Adviser has broad discretion in making investments for the Clients. Investments generally consist of long or short positions in equities and options and other assets that may be affected by business, financial market, or legal uncertainties. There can be no assurance that the Adviser correctly evaluates the nature and magnitude of the various factors that could affect the value of and return on investments. Prices of investments may be volatile, and a variety of factors that are

inherently difficult to predict, such as domestic or international economic and political developments, may significantly affect the results of the Clients’ activities and the value of its investments. In addition, the value of the Clients’ portfolios may fluctuate as the general level of interest rates fluctuates. No guarantee or representation is made that the Clients’ investment objectives will be achieved. Equity-Related Instruments in General The Clients invest in equity securities and equity-related instruments. Equity securities represent ownership interests in their respective issuers and generally carry the most risk associated with a specific issuer’s capital structure. The price of equity securities and their related financial instruments vary for a variety of reasons, including but not limited to supply and demand of the equity securities, the actual or perceived business opportunities associated with the issuer, the current and potential future cash flow of the issuer, the issuer’s management, their ability to execute on a specific business plan, the general economic environment, and the outlook for the overall economy. To the extent the Clients own an equity security or otherwise have exposure to an equity security or an equity-related financial instrument, this investment carries the risks associated with owning equities and may also carry risks associated with the form of financial instrument (e.g., options, derivative or securities-based futures contract). Any investment in equities or equity-related instruments entails a significant risk of loss. Short Sales Short sales create certain potential risks that are not otherwise associated with a long only portfolio. For example, a short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase, which might prevent or limit the Clients’ ability to exit the short position. There is also the risk that the securities borrowed by the Clients in connection with a short sale must be returned to the securities lender on short notice. If a request for return of borrowed securities occurs at a time when other short sellers of the security are receiving similar requests, a “short squeeze” can occur, and the Clients may be compelled to replace borrowed securities previously sold short with purchases on the open market at the most disadvantageous time, possibly at prices significantly in excess of the proceeds received in originally selling the securities short. The Clients’ inability to continue to borrow securities previously sold short may also force the Clients to unwind other elements of an investment position, possibly at a loss. From time to time, various regulatory authorities have imposed “short-selling bans” in selected securities (often, however, a wide population of securities), making it difficult if not impossible to continue to implement certain long/short (as well as other) equity strategies. For example, the SEC adopted an “uptick rule” in 2010 and securities exchanges have also reinstated “uptick rules” — generally prohibiting short sales unless the last recorded sale price of a stock was higher than the previous transaction. Over time, rules similar to the “uptick rule” could materially increase the Clients’ transaction costs by requiring the Adviser to delay executing certain short sales (as well as to execute them at higher prices than would otherwise be the case), and in certain circumstances could prevent the Clients from acquiring a short position which the Adviser would otherwise have acquired for it. Purchase of Options

Trading options is highly speculative and may entail risks that are greater than investing in other financial instruments. Prices of options are generally more volatile than prices of other financial instruments. In trading options, the Adviser speculates on market fluctuations of the underlying financial instrument (e.g., a security, an index, a commodity, exchange rate or other instrument), while only investing a small percentage of value relative to the Clients’ potential exposure. The price of any option is a function of direction (e.g., whether the option is a “put”—the right to sell—or a “call”—the right to buy), the time to expiry and the implied volatility of the underlying instrument. The Clients may “buy” an option, which means it pays a premium to receive exposure to a larger notional amount. A “buyer” of options risks losing all of its investment if the option expires “out of the money” (i.e., the trade goes against that option buyer). Purchasing put and call options, as well as writing these options, are highly specialized activities and entail greater than ordinary investment risks. Because option premiums paid or received by an investor will be small in relation to the market value of the investments underlying the options, buying and selling put and call options can result in large amounts of leverage. As a result, the leverage offered by trading in options could cause an investor's asset value to be subject to more frequent and wider fluctuations than would be the case if the investor did not invest in options. Use of Leverage The Client Accounts may utilize moderate leverage. This utilization results in the Clients controlling more assets than the Clients have equity. Leverage increases the Clients’ returns if the Clients earn a greater return on investments purchased with borrowed Clients than the Clients’ cost of borrowing such funds. However, the use of leverage exposes the Clients to additional levels of risk, including (i) greater losses from investments than would otherwise have been the case had the Client Accounts not borrowed to make the investments, (ii) margin calls or interim margin requirements which may force premature liquidations of investment positions and (iii) losses on investments where the investment fails to earn a return that equals or exceeds the Clients’ cost of borrowing such funds. In the event of a sudden, precipitous drop in value of the Clients’ assets, the Clients might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying its losses. Hedging Transactions The Clients’ portfolios may utilize a variety of financial instruments such as derivatives, options, swaps, caps and floors, forward contracts for both risk management and general investment and speculation purposes. With respect to the risk management and hedging transactions, there can be no assurances that a particular hedge is appropriate, or that a certain risk is measured properly. Further, while the Client Accounts may enter into hedging transactions to seek to reduce risk, such transactions may result in poorer overall performance and increased (rather than reduced) risk for the Client Accounts than if it did not engage in any such hedging transactions. In addition, the Adviser may choose not to enter into hedging transactions with respect to some or all of its positions. Non-Diversification While the Clients’ portfolios generally contain a number of both long and short positions, the Clients will be invested primarily in a relatively concentrated portfolio of equity securities. While the Adviser intends to avoid excessive concentration of net exposure in individual industries or geographies on behalf of the Clients, the Clients’ portfolios can become relatively concentrated in any one issuer, market capitalization, industry, type of security and geographic area, and such concentration may increase the losses suffered by the Clients as the investment portfolios of the Clients may be subject to more rapid change in value than would be the case if the Clients were required to maintain a wider diversification among issuers, market capitalizations, industries, types

of securities and geographic areas. In addition, the Clients may from time to time hold a few, relatively large (in relation to its capital) securities positions, with the result that a loss in any such position could have a material adverse impact on the Clients’ capital. Derivatives Derivatives allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark, or index at no cost or at a fraction of the cost of investing in the underlying asset. The value of this type of instrument depends largely upon price movements in the underlying asset. Therefore, many of the risks applicable to trading the underlying asset are also applicable to trading derivatives related to this asset. Use of derivative instruments presents various risks which include the following: • Tracking - When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative instrument and the underlying investment sought to be hedged may prevent the Clients from achieving the intended hedging effect or expose the Clients to the risk of loss. • Liquidity - Derivative instruments, especially when traded in large amounts, may not be liquid in all circumstances, so that in volatile markets the Clients may not be able to close out a position without incurring a loss. In addition, daily limits on price fluctuations and speculative position limits on exchanges on which the Clients may conduct transactions in derivative instruments may prevent prompt liquidation of positions, subjecting the Clients to the potential of greater losses. • Leverage - Trading in derivative instruments can result in large amounts of leverage. Thus, the leverage offered by trading in derivative instruments magnifies the gains and losses experienced by the Clients and could cause the Clients’ net asset value to be subject to wider fluctuations than would be the case if the Clients did not use the leverage inherent in derivative instruments. • Over-the-Counter Trading - Derivative instruments that may be purchased or sold by the Clients may include instruments that are not traded on an exchange. The risk of non-performance by the obligor on these instruments may be greater and the ease with which the Clients can dispose of or enter into closing transactions with respect to these instruments may be less than in the case of an exchange-traded instrument. In addition, significant disparities may exist between “bid” and “ask” prices for derivative instruments that are not traded on an exchange. Derivative instruments not traded on exchanges are also not subject to the same type of government regulation as exchange traded instruments, and many of the protections afforded to participants in a regulated environment may not be available in connection with these transactions. • Regulation of Over-the-Counter Transactions - The Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) includes provisions that comprehensively regulate the over-the-counter (“OTC”) derivative market. Although the effects of Dodd Frank on the OTC market have yet to be determined, dealers and other market participants are subject to additional clearing and margin requirements, as well as registration obligations and other regulatory requirements, such as business conduct standards, disclosure requirements, reporting and recordkeeping requirements and disclosures of conflicts of interest and other regulatory burdens. It is likely that these new and ongoing requirements increase the overall cost for OTC derivative dealers and other market participants, which may be passed along, at least partially, to market participants, such as the Clients, in the form of higher fees, decreased liquidity, less advantageous dealer marks and increased margin costs.

Incentive Allocation Michael Bilger, managing member of the general partner, has invested substantially all of his liquid net worth in the Funds to align his interests with the Investors. Notwithstanding the foregoing, the allocation of a percentage of the Clients’ net profits to the general partner may create an incentive for the Adviser to cause the Clients to make investments that are riskier or more speculative than would be the case if this allocation were not made. Since the allocation is calculated on a basis that includes unrealized appreciation of assets, such allocation may be greater than if it were based solely on realized gains. In addition, in the event that an Investor makes a complete or partial withdrawal from their capital account, or is required to retire at any time other than at the end of a fiscal year, the Incentive Allocation will be computed and charged to such Investor with respect to the withdrawn amount as though the date of such Investor’s withdrawal of capital or retirement was the last day of a fiscal year. This may result in the Investor being charged an Incentive Allocation during the year even though the Investor does not have net profits based on the entire year’s performance (i.e., due to losses that occur after the withdrawal). Initial Public Offerings The Clients may invest in initial public offerings. Investments in initial public offerings (or shortly thereafter) may involve higher risks than investments issued in secondary public offerings or purchases on a secondary market due to a variety of factors, including, without limitation, the limited number of shares available for trading, unseasoned trading, lack of investor knowledge of the issuer and limited operating history of the issuer. In addition, some companies in initial public offerings are involved in relatively new industries or lines of business, which may not be widely understood by investors. Some of these companies may be undercapitalized or regarded as developmental stage companies, without revenues or operating income, or the near-term prospects of achieving them. These factors may contribute to substantial price volatility for these securities and, thus, for the value of the Clients’ interests. Warrants and Rights The Clients may invest in or hold warrants and rights. Warrants are securities giving the holder the right, but not the obligation, to buy the stock of an issuer at a given price (generally higher than the value of the stock at the time of issuance), on a specified date, during a specified period, or perpetually. Rights are similar to warrants, but normally have a shorter duration. Warrants and rights may be acquired separately or in connection with the acquisition of securities. Warrants and rights do not carry with them the right to dividends or voting rights with respect to the securities that they entitle their holder to purchase, and they do not represent any rights in the assets of the issuer. As a result, warrants and rights may be considered more speculative than certain other types of investments. In addition, the value of a warrant or right does not necessarily change with the value of the underlying securities, and a warrant or right ceases to have value if it is not exercised prior to its expiration date. Brokerage and Custodial Risk There are risks involved in dealing with the custodians or prime brokers who settle the Clients’ trades. The Clients maintain a custody account with Goldman Sachs, Morgan Stanley, and Fidelity (collectively referred to herein as, the “Prime Broker”). Although the general partner monitors the Prime Broker and believes that it is an appropriate custodian, there is no guarantee that the Prime Broker, or any other custodian that the Clients may use from time to time, will not become bankrupt or insolvent. While both the U.S. Bankruptcy Code and the Securities Investor Protection Act of 1970 seek to protect customer property in the event of a bankruptcy, insolvency, failure, or liquidation of a broker-dealer, there is no certainty that, in the event of a failure of a brokerdealer that has custody of the Clients’ assets, the Clients would not incur losses due to its assets

being unavailable for a period of time, the ultimate receipt of less than full recovery of its assets, or both. The Clients and/or the Prime Broker may appoint sub-custodians in certain non-U.S. jurisdictions to hold the assets of the Clients. The Prime Broker may not be responsible for cash or assets which are held by sub-custodians in certain non-U.S. jurisdictions, nor for any losses suffered by the Clients as a result of the bankruptcy or insolvency of any such sub-custodian. The Clients may therefore have a potential exposure on the default of any sub-custodian and, as a result, many of the protections that would normally be provided to a fund by a custodian may not be available to the Clients. Under certain circumstances, including certain transactions where the Clients’ assets are pledged as collateral for leverage from a non-broker-dealer custodian or a non-broker-dealer affiliate of the Prime Broker, or where the Clients’ assets are held at a non-U.S. custodian, the securities and other assets deposited with the custodian or broker may not be clearly identified as being assets of the Clients and the Clients could be exposed to a credit risk with regard to such parties. Custody services in certain non-U.S. jurisdictions remain undeveloped and, accordingly, there is a transaction and custody risk of dealing in certain non-U.S. jurisdictions. Given the undeveloped state of regulations on custodial activities and bankruptcy, insolvency, or mismanagement in certain non-U.S. jurisdictions, the ability of the Clients to recover assets held by a sub-custodian in the event of the sub-custodian's bankruptcy or insolvency could be in doubt, as the Clients may be subject to significantly less favorable laws than many of the protections that would be available under U.S. laws. In addition, there may be practical or timing problems associated with enforcing the Clients’ rights to its assets in the case of a bankruptcy or insolvency of any such party. Cybersecurity Risk The Clients, the Adviser, and their service providers, including banks, broker-dealers, custodians and their affiliates, may be subject to operational and information security risks resulting from cyberattacks. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, unauthorized asset transfers, and various other forms of cybersecurity breaches. Cyber-attacks affecting the Clients, the Adviser, or their service providers may adversely impact the Clients. For instance, cyber-attacks may interfere with the processing or execution of the Clients’ transactions, cause the release of confidential information, including private information about Investors, subject the Clients, the Adviser or their affiliates to regulatory fines or financial losses, or cause reputational damage. Additionally, cyber-attacks or security breaches (e.g., hacking or the unlawful withdrawal or transfer of funds), affecting any of the Clients’ key service providers, such as the Adviser, banks, broker-dealers, custodians, or other counterparties holding assets of the Clients, may cause significant harm to the Clients, including the loss of capital. Similar types of cybersecurity risks are also present for issuers of securities in which the Clients may invest. These risks could result in material adverse consequences for such issuers and may cause the Clients’ investments in such issuers to lose value. While the Adviser has instituted specific policies and has engaged specialized vendors to manage cybersecurity risk and disaster recovery, there are no assurances that these policies and vendors will mitigate risks associated with cybersecurity. Artificial Intelligence Risks The Adviser uses generative artificial intelligence technologies and large language models and chatbots (“Generative AI”), in certain business and investment research processes. The Adviser is also exposed to risks associated with the use of Generative AI by third parties, including service providers, counterparties, data vendors, and other market participants, and the Adviser may not always be aware of such use or able to control how third-party systems are developed, maintained, or operated. Generative AI tools rely on large datasets that may be incomplete or unreliable, and their outputs may be inaccurate, biased, misleading, or otherwise unreliable. The use of Generative

AI may also present cybersecurity, confidentiality, data privacy, intellectual property, and other operational or legal risks. Because Generative AI technologies are rapidly evolving, the Adviser’s related policies and procedures may continue to develop, and it may be difficult to predict the full scope of risks associated with current or future uses of such technologies. Non-Disclosure of Positions In an effort to protect the confidentiality of its positions, the Clients generally do not disclose its positions to Investors on an ongoing basis except as detailed in the monthly risk reports, although the general partner, in its sole discretion, may permit such disclosure on a select basis to certain Investors.

Effects of Health Crises and Other Catastrophic Events Health crises, such as pandemic and epidemic diseases, as well as other catastrophes that interrupt the expected course of events, such as natural disasters, war, or civil disturbances, acts of terrorism, power outages and other unforeseeable and external events, and the public response to or fear of such diseases or events, have and may in the future have an adverse effect on the Funds’ investments and the Firm’s operations and employees. For example, any preventative or protective actions that governments may take in respect to such diseases or events may result in periods of business disruption, inability to obtain raw materials, supplies and component parts, and reduced or disrupted operations for certain Fund investments. In addition, under such circumstances the operations, including functions such as trading and valuation, of the Firm and other service providers could be reduced, delayed, suspended, or otherwise disrupted. Further, the occurrence and pendency of such diseases or events could adversely affect the economies and financial markets either in specific countries or worldwide. Bank Deposits Risk Deposits maintained at a Federal Deposit Insurance Corporation (“FDIC”) insured bank are insured up to $250,000 per depositor, per insured bank, for each account ownership category, in the event of a bank failure. Any deposits over $250,000 in cash per account at a single bank may be unrecoverable in the event the bank fails. Diversifying banking relationships could serve to mitigate the potential loss of assets and available liquidity.

In this regard, the Adviser has developed policies and procedures in the Code of Ethics that are premised on the fundamental principles of openness, integrity, honesty and trust. Employees are provided with a copy of the Code of Ethics and are annually required to sign and acknowledge that they will comply with its provisions. The Adviser will provide a copy of the Code of Ethics to any Investor or prospective Investor upon request. Personal Trading In general, employees (and members of their immediate households) must obtain pre-clearance before making certain securities transactions, including transactions in a private placement or initial public offering. The spirit of the Code of Ethics is to discourage frequent trading in employee personal accounts. Employees must also obtain pre-approval from the CCO before engaging in any outside business activities. All employees must provide duplicate copies of brokerage statements to the CCO. These records are used to monitor compliance with the foregoing policies. Participation and Interest in Client Transactions Subject to applicable law, the Adviser may affect transactions between Client accounts whereby one Client account will purchase securities from or sell securities to another account. If it plans on effecting such transactions in the future, the Adviser will follow documented procedures for doing so, including requiring pre-approval from the CCO. Aside from investments in the Funds, related persons generally may not invest in the same securities (or related securities) that are recommended to Clients. Such practices could present a conflict, where a related person is in a position to trade in a manner that could adversely affect a Client’s account (e.g., by placing its own trades before or after Client’s trades are executed in order to benefit from any price movements). The Adviser has adopted the personal trading policy summarized above in an effort to minimize such conflicts.

Although the Adviser will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. The receipt of such products or services and the determination of the appropriate allocation in the case of "mixed use" products or services create a potential conflict of interest between the Adviser and its Clients. In selecting brokers and negotiating commission rates, the Adviser may take into account the financial stability and reputation of brokerage firms, creditworthiness, efficiency of execution and error resolution, the actual executed price and the commission, custodial and other services provided for the enhancement of the Adviser’s portfolio management capabilities, the size and type of the transaction, the difficulty of execution and the ability to handle difficult trades, and the operational facilities of the brokers and/or dealers involved (including back office efficiency) and the research, brokerage or other services provided by such brokers. Soft Dollars The Adviser has entered into soft dollar arrangements with brokers. Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”), is a "safe harbor" that permits an investment manager to use commissions or "soft dollars" to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. Except for services that would be Client expenses or as otherwise described below, the Adviser will limit the use of "soft dollars" to obtain research and brokerage services to services which constitute research and brokerage within the meaning of Section 28(e). Research services within Section 28(e) may include: research reports (including market research), certain financial newsletters and trade journals, software providing analysis of securities portfolios, corporate governance research and rating services, attendance at certain seminars and conferences, discussions with research analysts, meetings with corporate executives, consultants' advice on portfolio strategy, data services (including services providing market data, company financial data and economic data), advice from brokers on order execution and certain proxy services. Brokerage services within Section 28(e) may include: services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment manager and a broker-dealer and other relevant parties such as custodians), trading software operated by a brokerdealer to route orders, software that provides trade analytics and trading strategies, software used to transmit orders, clearance and settlement in connection with a trade, electronic communication of allocation instructions, routing settlement instructions, post trade matching of trade information and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. The use of commissions arising from the Clients’ investment transactions for services other than research and brokerage will be limited to services that would otherwise be a Client expense. The use of commissions to obtain such other services would be outside the parameters of Section 28(e). In some instances, the Adviser receives a product or service that is used, in part, by the Adviser for Section 28(e) eligible purposes and, in part, for other purposes (e.g., an order management system, trade analytical software or proxy services). In such instances, the Adviser makes a good faith effort to determine the relative proportion of the product or service used to assist the Adviser in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting the Adviser in carrying out its investment decision-making responsibilities is paid through brokerage commissions generated by Client transactions and the proportion attributable to

administrative or other purposes outside Section 28(e) are paid for by the Adviser from its own resources unless otherwise a Client expense. Aggregation When appropriate, the Adviser aggregates Client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades are allocated securities based on the average price achieved for such trades.

If the Adviser determines that a conflict of interest exists as to a particular issuer, the CCO will determine whether the conflict is material to the vote. If it is determined not to be material, the Adviser will vote without further procedures. If it is determined to be material, the Adviser will resolve the conflict in one of several possible ways, such as by engaging a third party to recommend a vote. Current and prospective Clients and Investors may request a copy of the Adviser’s proxy voting policies, as well as relevant proxy voting records, by contacting the CCO.