Trium Capital LLP: investment adviser

TCL provides discretionary investment management services to private investment vehicles that are classified as hedge funds (the "Funds") and consist of: • Private pooled investment vehicles open to US qualified purchasers (Cayman domiciled hedge funds, typically with a Delaware feeder). • Private pooled investment vehicle open to US qualified purchasers (US domiciled) that serves as an investment vehicle for a state pension investment trust. • Private pooled investment vehicles that are not open to US investors (Irish-domiciled UCITS funds), including a multi-strategy UCITS Fund (“the Trium Multi-Strategy UCITS Fund” or “TMSU”) comprising sleeves managed by various PMs within TCL, some of which also manage a standalone Fund. • Private pooled investment vehicles that constitutes ERISA plan assets. TCL also provides sub-advisory services to other private funds pursuant to investment management agreements between TCL and such private funds’ investment adviser (the “Mandates”). TCL provides its services in accordance with the relevant offering documents of the respective Funds (i.e., private placement memorandums, prospectuses, etc.) and investment management agreements for the respective Mandates. Certain of the private investment vehicles managed by the Firm may hold assets that constitute “plan assets” of employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and/or Section 4975 of the Internal Revenue Code (together, “ERISA Plans”). To the extent that the assets of any such ERISA Plan are invested in a Fund for which the Firm provides investment management services, the Firm will be deemed to be a fiduciary under ERISA with respect to the management of the ERISA Plan’s assets invested in that Fund. As an ERISA fiduciary, the Firm is required to manage such assets in accordance with the fiduciary standards set forth in ERISA, including the duties of prudence and loyalty, and to act solely in the interest of plan participants and beneficiaries. The management of ERISA Plan assets is subject to certain restrictions, including prohibited transaction rules, which may limit the types of investments and transactions that may be entered into by a Fund or affect the manner in which certain transactions are structured or executed. Compliance with ERISA requirements may impose additional constraints on the Firm’s investment activities and may result in additional costs or administrative burdens for affected Funds. Prospective investors that are ERISA Plans or investing plan assets are encouraged to consult with their own legal and tax advisers to determine whether an investment in a Fund is appropriate in light of ERISA and other applicable considerations.

1* Such registration does not imply that the SEC has endorsed the qualifications of Trium to provide the services described

herein.

As of December 31, 2025, the Firm had under its discretion regulatory assets under management totaling USD $5,790,815,400.

TCL has established the RPA from which it may pay for research (as defined in the FCA Rules) (“Research”) that it receives from third parties in connection with the provision of services to the relevant Funds and certain other investment funds, vehicles or accounts managed by TCL that would benefit from the same research (“Similar Clients”). The RPA will be funded by research charges (“Research Charges”) paid by the Master Fund and any Similar Clients which will be determined by TCL in accordance with TCL’s research policy and the FCA Rules. The research purchased through the RPA is expected to be of a type that would be permitted under Section 28(e) of the United States Securities Exchange Act of 1934, as amended (“Section 28(e)”). Collection of Research Charges The Master Fund will be charged according to the “accounting method” whereby the Master Fund will be debited the quarterly value of the annual Research Budget at the beginning of each quarter, but the Master Fund will amortise the expense pro-rata over each accounting period within that calendar year. The Master Fund has authorised the Investment Manager to instruct payment of the Research Charge (or portion thereof) from the Master Fund’s account to the RPA. Other Fees, Charges and Expenses TCL may expense the following charges in accordance with the relevant Fund offering documents or the specific Mandate investment management agreement. Such charges include but are not limited to: costs and expenses of the administration of the Fund or Mandate, transaction costs, broker commissions (including blockchain-based settlement charges such as gas fees), borrowing charges on securities sold short and any issue or transfer taxes chargeable in connection with any investment transactions, interest on borrowings, including borrowings from the Prime Brokers, any taxes and any regulatory or corporate fees payable to governments or agencies, any litigation and indemnification expenses and extraordinary expenses not incurred in the ordinary course of business, the charges and expenses of legal advisers, accountants and auditors, communication expenses with respect to investor services and all expenses of meetings of Fund Directors and Shareholders and of preparing and distributing financial and other reports, proxy forms, prospectuses and similar documents, the cost of insurance, the cost of preparing and providing information to Shareholders for tax reporting purposes, expenses incurred by TCL in soliciting subscriptions for Shares (including, without limitation legal fees and the costs of any registrations and notifications and of any regulatory reporting required as a result or condition of such solicitation), the costs of reporting information to regulators, tax authorities or other governmental agencies, the cost of obtaining and maintaining the listing of the Shares on any stock exchange,

ERISA bonding costs, if required, software and services related to investment operations, accounting, treasury management and risk management, including third party middle and back office; market data and due diligence fees and expenses (including any travel to perform research or initial and ongoing due diligence on investments, online news and quotation services, computer hardware and software used for research, Bloomberg service, risk software etc.), fees and expenses of Digital Asset exchanges, expenses related to the exchange of Digital Assets to fiat, all fees and charges of custodians (including with respect to Digital Asset Wallets) and all other organisational and operating expenses. These costs and expenses are generally incurred at normal commercial rates. The relevant Fund bears its proportionate share of any fees, charges and expenses incurred by the Master Fund through its investment in the Master Fund. investment funds, vehicles or accounts managed by the Investment Manager or its affiliates will be allocated in an equitable manner among the Fund and/or the Master Fund and those other investment funds, vehicles or accounts (which may mean that the cost or expense is allocated equally, in approximate proportion to their net asset values, in approximate proportion to the size of a relevant investment, or otherwise).

Performancebased fees and side-by-side management create conflicts of interest, which TCL has identified and described in the following paragraphs. Performance-based fees create an incentive for the Firm to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. In order to address this potential conflict of interest, the Firm periodically reviews client accounts to ensure that the account is being managed according to the client's investment objectives and risk tolerance. Performance-based fees create an incentive for the Firm to overvalue investments which lack a market quotation. In order to address such conflict, the Firm has adopted policies and procedures that require the Firm to utilize a specified hierarchy of price sources, methodologies, and tolerance tests for instruments in the scope of the vehicles’ trading strategy. These policies and procedures also provide a tiered escalation-review mechanism for price deviations that exceed specified thresholds. Side-by-side management might provide an incentive for the Firm to favour accounts for which it receives a performance-based fee. For example, TCL has an incentive to allocate limited investment opportunities, such as initial public offerings, to clients who are charged performance-based fees over clients who are charged asset-based (i.e. management) fees only. To address this conflict of interest, TCL has instituted policies and procedures that require the Firm to fairly allocate investment opportunities (if they are suitable), and monitor that allocation, in an effort to avoid favouritism among clients, regardless of whether the client is charged performance fees.

Where a TCL Portfolio Manager (“PM”) manages multiple funds, managed accounts, and/or a sleeve in a Fund with similar or identical investment objectives, i.e., managed pari passu, a conflict of interest may arise where a PM has stronger incentives to favour one fund or account over another. Where PMs, officers of TCL, or other Trium staff have investments in a Trium Fund, they may have an incentive to favour one Fund over another. Another potential side-by-side management conflict is presented by the Trium Multi Strategy UCITS Fund (“TMSU”). TMSU is a multi-strategy UCITS fund managed by TCL that is not marketed to and is not open to US investors. TMSU is structured as a multi-strategy vehicle comprised of strategy sleeves that are managed by different portfolio managers within TCL. TMSU has an investment committee (the “Trium Multi Strategy Committee” or “TMSC”) that is comprised of senior officers of TCL, including the Chair, the Head of Multi-Strategy/Co-CEO, Chief Risk Officer, and the Head of Trading. The TMSC makes decisions as to which of the strategy sleeves to allocate to on a monthly basis. Some of the senior officers on the TMSC are also members of the Firm’s Executive Committee (the “Trium Executive Committee”, or “TEC”). TCL may have potential conflicts of interest by virtue of these senior officers serving on both the TEC and the TMSC. These individuals may be presented with competing duties and incentives, including with respect to portfolio construction, asset allocation, risk management, liquidity management, and the prioritisation of investment opportunities across TMSU, its individual strategy sleeves, and other client accounts. TCL has adopted policies and procedures reasonably designed to identify, manage, and mitigate these potential conflicts of interest, including allocation policies, investment committee governance procedures, information barriers, and oversight and compliance monitoring. However, there can be no assurance that such measures will be fully effective in every circumstance, and these conflicts of interest may adversely affect TMSU, the Funds and their respective investors. The Firm has the following controls in place to mitigate such conflict of side-by-side management and managing multiple funds/accounts:

Documented TCL Trade Aggregation & Allocation Policy which sets out that all allocations and aggregated orders must, on every occasion, be made to clients fairly. Compliance, Risk Monitoring, and Operational functions report directly to the TEC and their incentives are not linked to investment performance. Best Execution Policy. Compliance monitoring. Where two clients have similar mandates or invest in the same strategies through different Funds or accounts, the conflict risk is assessed and monitored. Depending on the level of the risk and the situation and mandate, accounts are traded on a pari passu and/or systematic basis with automated allocations between accounts. Where the Funds/Accounts have different liquidity terms, and a large redemption is made, liquidity is monitored, and an orderly redemption process is in place.

TCL maintains a deferred compensation program under which a portion of certain employees’ variable remuneration is invested in one or more Funds managed by TCL. Employees are also encouraged to invest directly in Funds managed by TCL, particularly in those Funds where the employee is involved in the investment management of such Fund. Because the value of these investments and deferred awards is tied to the performance of the Funds managed by TCL, employees may have a financial incentive to favour investment strategies, products, or decisions that could enhance the value of their deferred compensation. These investments and arrangements create an alignment of interest with investors, but they also create a conflict of interest where an employee is able to influence the performance of one Fund or mandate over the other. TCL addresses any such potential conflicts through firm wide policies and supervisory controls designed to ensure that investment

decisions are based solely on the interests of clients, and by providing full and fair disclosure of these incentives as required under the Investment Advisers Act.

Certain clients may include employee benefit plans subject to ERISA. Please see Item 4 (Advisory Business) for a discussion of ERISA-related fiduciary considerations. TCL also provides investment advisory services to other private funds for which is has been appointed the sub-advisor.

The keys risks associated with the Strategies are set forth below. Market risk - The success of client portfolio activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty, changes in laws, trade barrier, currency fluctuations and controls, and national and international political circumstances. These factors may affect the level of volatility of securities prices and the liquidity of investments in client portfolios. Such volatility or illiquidity could impair profitability or result in losses. Liquidity risk - The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment. The Firm will invest for clients in securities that are not traded in any market or exchange. Moreover, many of these investments may be held by relatively few investors or have low trading volume. Under adverse market or economic

conditions or in the event of adverse changes in the financial condition of the issuer, the Firm may find it difficult to sell such instruments. Consequently, the Firm may be forced to sell at prices lower than if the instruments were widely held or more actively traded. In addition, the Firm may not be able to sell the investment at all, resulting in a total loss. Finally, dispositions of investments that are subject to limitations on transfer tend to adversely affect the terms obtainable upon a disposition. Operational risk - A client depends on the Firm to develop and implement appropriate systems with regard to its activities. A Firm relies on data processing systems to enter into transactions and to evaluate certain investments, to monitor its portfolios and capital, and to generate risk management and other reports that are critical to the oversight of client accounts. In addition, the Firm relies on information systems to store sensitive information about its operations and its clients/investors. Certain of the Firm’s activities will be dependent upon systems operated by third parties, including a Fund’s administrator, counterparties and other service providers, and the Firm may not be in a position to verify the risks or reliability of such third-party systems. Failures in the systems employed by the Firm, a Fund’s administrator, counterparties, exchanges, third-party wallet providers and other parties could result in mistakes made in effecting transactions, or in transactions not being properly booked, evaluated or accounted for. Disruptions in the Firm’s operations may cause clients to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on a client and its investments. Counterparty risk - The Firm will engage in transactions for clients in securities and financial instruments that involve counterparties. Under certain conditions, clients could suffer losses if a counterparty to a transaction were to default or if the market for certain securities or financial instruments were to fail. In addition, clients could suffer losses in the event of a default or bankruptcy by certain other third parties, including brokerage firms and banks with which the client does business. Currency risk /Exchange risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Strategy

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Global political event risk - non-U.S. securities and other assets (through ADRs and otherwise) may give rise to risks relating to political, social, and economic developments abroad and risks resulting from the differences between the regulations of US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets.

Fixed Income Securities - Investments in fixed income securities are subject to credit, liquidity, prepayment, and interest rate risks, any of which may adversely impact the price of the security and result in a loss. The municipal market can be significantly affected by adverse tax, legislative or political changes and the financial condition of the issuers of municipal securities. Emerging Markets risks - Investments in emerging markets will be impacted by economic conditions in the countries in which those companies operate. Many developing countries have a history of economic instability, and an investment’s success may depend on the overall level of economic activity and political and social stability in these emerging markets. Investments in foreign companies may be adversely affected by declining economic conditions in the host country. Emerging markets may be less liquid than more developed economies and markets. Moreover, certain emerging markets may impose restrictions that specifically impact liquidity, such as restrictions on buying and selling within the same trading day, which could impact the ability to sell securities at a given time and, therefore, impact the investment strategy. The legal infrastructure and accounting, auditing, and reporting standards in emerging markets may not provide the same degree of shareholder protection or information to investors as would generally apply in more developed markets. In particular, valuation of assets, depreciation, exchange differences, deferred taxation, contingent liabilities and consolidation may be treated differently from accounting standards in more developed economies and markets. Likewise, a client account may experience tax risks around a lack of clarity or definition in respect of the payment of tax on dividends and/or capital gains income realized as a result of holding investments in an emerging market. Further, a client account's ownership rights, including the right to bring claims against an issuer, may be uncertain or otherwise limited. Cybersecurity – The Firm and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage or interruption from computer viruses, network failures, computer and telecommunications failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. A cybersecurity breach could expose both the Firm and its clients/investors to substantial costs (including, without limitation, those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, adverse investor reaction, the dissemination of confidential and proprietary information and reputational damage), civil liability as well as regulatory inquiry and/or action. While the Firm has established a business continuity plan in the event of, and risk management strategies, systems, policies and procedures to seek to prevent, cybersecurity breaches, there are inherent limitations in such plans, strategies, systems, policies and procedures including the possibility that certain risks have not been identified. Furthermore, the Firm and its clients/investors cannot control the cybersecurity plans, strategies, systems, policies and procedures put in place by other service providers to the clients/investors and/or the issuers in which the clients/investors invest. Short-Sales risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting 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. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. TCL does not represent or guarantee that its services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. TCL cannot offer any guarantees or promises that financial goals and objectives will be met. Past performance is not a reliable indicator of future returns. The respective Fund offering documents contain certain additional information about the respective investment strategies including methods of analysis and risks. Fund investors should carefully review the respective Fund’s offering documents for full details of all the potential risks.

The Trium UCITS Funds are not open to US investors. TCM Wealth Limited (“TCM”) is under common control with the Firm but operates in a separate geographic location. TCM is a trading platform with 13 traders-each making a deposit of their own capital, which is held in escrow, and managing a trading portfolio within specified risk limits. TCM does not have any external clients. The core investment universe is UK small and micro-cap stocks. However, traders may take positions in global equities and related securities. The relationship between TCM and the Firm presents a potential conflict of interest pertaining to disclosure of confidential trading-related information between the entities. Multiple controls mitigate this potential conflict. TCM is located in a separate office location from the Firm. The Firm and TCM have separate order-management and portfolio-management systems, and consequently neither has access to the trade or position information of the other. The two entities maintain separate compliance frameworks, which are administered by shared compliance personnelthe only shared personnel between the firms-to help ensure established barriers remain effective and information is not exchanged among the entities. Both firms trade at a volume that is relatively small compared to market capitalization, limiting any potential impact on securities’ market price. Further, while there is limited scope for overlapping trades between TCM and the Firm, due to different core investment universes, the shared compliance personnel monitor, among other things, (1) overlapping trades between the entities to detect improper sharing of trading information and (2) electronic communications between the firms. Personnel of both entities also receive initial and ongoing compliance training that addresses these issues. Credere Capital LLP (“Credere”) is an independent, asset-management firm which manages a relative value convertible bond arbitrage strategy. Credere is unrelated to Trium Capital LLP in terms of strategic (versus operational) management control and ownership. However, Trium Capital LLP has a services agreement and seeding/profit-sharing arrangements with Credere Capital LLP. The services provided include Chief Operating Officer, Chief Compliance Officer, Chief Risk Officer, operations staff, and related IT infrastructure.

Additionally, the Firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about clients or their account holdings by persons associated with the Firm. The Code of Ethics sets out the procedures in place governing personal trading, and includes the following provisions:

All permanent staff (and temporary staff at the Firm for longer than 3 months) are deemed to be Access Persons. All personal brokerage accounts under the discretion of staff, including where the member of staff has discretion over the accounts of their spouses and dependent children must be notified to the Firm. Prior Compliance approval is required for ‘pre-approvable securities’ in accordance with the Firm’s Personal Account Dealing Policy. Initial and annual self-certification and holdings reports are submitted to the Firm by all Access Persons of the Firm.

The Firm prohibits its front office staff (including Portfolio Managers, analysts and execution traders) from personal account trading in securities owned by the Firm’s Funds or its Mandates.

All TCL staff making a subscription or a redemption from a Trium Fund must seek prior approval from the Head of Compliance before instructing the trade. Rationale for the trade must be provided. Temporary staff (such as interns, consultants, and contractors) working at TCL for a period of less than 3 months, shall be prohibited from personal account dealing during their tenure at the Firm. (Please refer to Item 10 for discussion of conflicts of interest and corresponding controls regarding the trading activities of TCM.) The Code of Ethics is available to clients or prospective clients upon request by contacting the Firm at the telephone number listed on the cover page of this Brochure.

Should the Firm wish to charge research costs to these funds this must be performed in accordance with the UK FCA research rules by way of an RPA which is funded by way of a specific research charge to its clients. (Charges included in an RPA would also qualify for the safe harbor in section 28(e) of the Securities Exchange Act of 1934). The Firm’s investment approach is to use qualitative techniques when deciding upon securities to be traded for the Mandates it manages. The Firm maintains a list of brokers with whom it may deal with. This list is reviewed at least on an annual basis, and brokers are added or deleted according to the Firm’s view of the quality and cost of the service provided, as explained in the “Best Execution” subsection immediately below. Brokers are used by the Firm at its own discretion. Best Execution Brokerage costs are not paid by the Firm. Brokers build in a spread in respect of execution services provided only. Brokers with whom the Firm trades are therefore selected on the basis of the certain criteria and execution factors, which include, but are not limited to the following, with particular emphasis being given to the price:

Price (overall costs of a trade including commissions, mark-ups, markdowns or spreads) Speed Likelihood of execution and settlement, including accurate and timely execution, settlement, clearance and error/dispute resolution processes Size of the trade and ability to fill trades in staged orders Nature of the security and the available market makers Reputation, financial strength and stability Conflicts of interest between the Firm and the broker Other considerations relevant to the execution of an order (e.g. history of trade errors caused by broker)

The Firm is not incentivised to select a more expensive broker over another when executing trades. The Firm has an Allocation Policy that governs the allocation of trades. Where different strategies are similar and managed by the same portfolio manager, trades will be aggregated for execution and average pricing will be utilized to ensure that pricing across clients is as fair as possible. In instances where the Firm has aggregated client orders, the trades shall be allocated fairly across Funds or Mandates. This would generally be achieved by allocating pro rata based on the gross exposure of the accounts. However, each pro rata allocation shall be adjusted based on the following exceptions:

Investment objectives, liquidity and risk profiles Regulatory restrictions Where there are minimum trade lot sizes Prime brokerage capability

It may be the case that some investments may be suitable for one investment vehicle and not the other. In such instances, it will not be possible to allocate pro rata across the Funds and/or Mandates. Trade Errors The Firm will treat any trade error in accordance with its Trade Error Policy. Trade Errors will be documented and actions taken, where possible, to prevent such errors in the future.

Cross Trades In rare instances, the Firm may engage in cross trades. Cross trades shall only be permitted if the Firm can demonstrate that they are in the best interest of the participating funds or accounts. All cross trades will be carried out in accordance with the Firm’s Cross Trade Policy.

In relation to the private pooled investment vehicles open to US qualified purchasers, statements are sent to all investors on a monthly basis by the respective Fund administrator. These reports contain a detailed analysis of the holdings as at the reporting date and transactions effected during the period. In addition, the Firm sends a report on either a monthly or quarterly basis which analyses the portfolios’ risk and return characteristics along with a commentary on the market and the portfolio itself.

If you have any questions regarding the financial statements of the Delaware Funds or regarding the receipt of such statements, they should be directed to TCL directly at the telephone number on the cover page of this Brochure. Delaware Fund investors should also carefully review the statements they receive from the Delaware Fund’s administrator.

For systematic strategies, which typically have highly diversified portfolios and short holding periods, it is not practical to engage in proxy voting. The Firm’s policy is therefore to abstain from proxy voting in these instances. For securities held via a contract for differences (CFD), while there is typically no voting right attached, where Trium views a vote to be important, Trium will work with the Prime Brokers to seek to ensure that a vote is cast. If needed Trium can move the position to a cash position to ensure that the Firm has the right to vote. In order to ensure that the Firm votes proxies in the best interests of its clients, the guidelines and procedures set out in the Firm’s proxy-voting policy have been implemented to address a material conflict of interest. The Firm will first assess a proxy issue to see if there is any possible conflict of interest involving itself or its affiliates. If a conflict is identified, independent personnel will be utilized to develop the Firm’s voting position. Trium Silver Blaze Strategy A separate proxy-voting methodology applies to the Trium Silver Blaze Strategy. This global equity arbitrage Strategy has only limited proxy-voting opportunities due to (1) typical short-holding periods of positions--less than 40 days, which limits voting scope and relevance, and (2) holdings that involve large-cap and mid-cap stocks which, in most cases, are held via CFD or Swap, and so are not entitled to a proxy vote. Further, the investment process integrally involves constructive and open discussions with management. Therefore, the Firm would typically abstain to remain neutral, rather than vote against management. In the rare instance that the portfolio held a cash equity position over a vote, the specific proxy voting policy for this Strategy shall be to abstain from voting, in order to maintain a neutral position. As part of its proxy voting policy, the Firm has adopted procedures as to how to handle class actions. The Firm will evaluate each class action to determine whether it will (a) participate in the class action or (b) opt out of the class action and separately pursue its own remedy. The Firm may use an outside third-party vendor to track and submit documentation to recover class action awards. The Firm generally does not serve as the lead plaintiff in class actions because the costs of such participation typically exceed any extra benefits that accrue to lead plaintiffs. For information regarding how Trium voted proxies and/or a copy of the Firm’s Proxy Voting Policy, this can be obtained by contacting the Firm at the telephone number listed on the cover page of this Brochure.