Peakline Partners, LLC: investment adviser

Except where otherwise noted herein, all references to the “Adviser,” “us,” “we,” or “our” are intended to collectively encompass Peakline Partners and its affiliates (including the Fund Managers). A. Advisory Services Offered We provide discretionary investment management services solely to private investment funds, that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”) (each, a “Fund,” and collectively, the “Funds”). Such discretionary investment management services primarily consist of sourcing, structuring, and negotiating investments and dispositions, monitoring the performance of investments and performing certain administrative services. The Funds to which the Adviser provides portfolio and investment management services include: (i) private equity, private credit, and venture capital funds (“PC Funds”) and (ii) real estate funds (“RE Funds”). These services are detailed in the offering documents for each Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Adviser manages each Fund based on the investment objectives, policies and guidelines as set forth in the respective Fund’s Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Adviser or certain Fund Managers have entered into, and could in the future, enter into, side letter or other written agreements with one or more investors which have the effect of establishing rights under, or altering, modifying, or changing the terms of interest held by investors. Certain types of side letters create a conflict of interest among the Adviser and investors, and/or between investors themselves. For more detailed information on investment objectives, policies, and guidelines, please refer to the respective Fund’s Offering Documents.

Wrap Fee Programs The Adviser does not participate in wrap fee programs. B. Assets Under Management The Adviser managed $2,805,468,495 in client assets on a discretionary basis based on the fund valuations reported at the time of this annual filing which are primarily as of December 31, 2025. Such amount includes capital that can be called by certain Funds from investors. The Adviser does not manage client assets on a non-discretionary basis. Clients may request more current information at any time by contacting the Adviser.

RE Funds As compensation for the investment management services rendered to each RE Fund, the Adviser typically receives an annual management fee at an annual rate of up to 1.50%, calculated and payable quarterly in advance. Certain real estate investments may also have an asset oversight and accounting fee which is a fixed fee that is paid to the Adviser and is typically less than $100,000 annually. Fund Expenses In general, each Fund will also bear all costs and expenses related to their organization, management and operation, including, but not limited to:

expenses incurred in connection with the formation of the Fund, the Fund’s investment management entity (i.e., the general partner) and other vehicles or entities, as applicable;

expenses incurred in the offering of the Fund’s interests;

the costs related to acquiring, holding and disposing of investments;

third-party legal, accounting, tax and other consulting fees;

fees paid to the administrator;

costs associated with preparing and distributing tax documents and reports;

In certain circumstances, costs and expenses paid to third-party broker-dealers connection with raising capital;

premiums for insurance; and

certain taxes.

Other Fees The Adviser receives and, in the future, expects to receive, certain acquisition, disposition, capital structuring, consulting, advisory, directors’, investment banking, monitoring, transaction, closing, break-up, real estate brokerage, asset management, construction management, guaranty, development or other transactional fees or fees for services rendered in relation to the investments held by the Funds (“Other Fees”); provided that any such Other Fees are within a reasonable range of market-standard fees and compensation that would be paid to third-party providers pursuant to an arm’s length agreement. The Adviser does not buy or sell securities, other than the recommendation of interests in the Funds, and does not receive any compensation for securities transactions in any client account, other than the management fees noted above and performance-based fees noted below. For more detailed information on the fees and compensation received by the Adviser and its affiliates, please refer to the respective Fund’s Offering Documents.

Investors should understand that the receipt of performance-based fees creates a conflict of interest as the Adviser has the potential to receive higher compensation. Performance-based fees create an incentive for the Adviser to make investments that are riskier or more speculative than might otherwise be the case in the absence of such arrangement. Additionally, the Adviser is incentivized to favor and devote more time and effort to managing investments when there is a potential for receipt of carried interest. In allocating investments, the Adviser has an incentive to favor Funds with higher potential for carried interest distributions over Funds with lower potential for carried interest. As explained in Item 11 below, the Adviser seeks to mitigate these conflicts through disclosures in this Brochure; additional disclosures in the applicable Offering Documents, as well as through the Adviser’s Code of Ethics and policies and procedures contained in its Compliance Manual.

Generally, the investors in the Funds meet the definition of “accredited investor” as defined in Regulation D, “qualified purchaser” as defined in Section 2(a)(51) of the 1940 Act, and “qualified client” as defined in Rule 205-3 under the Advisers Act, and/or (iv) “knowledgeable employee” under Rule 3c-5 of the 1940 Act. Such investors include individuals, entities, trusts, estates, other corporations or business entities, or family offices. In addition, owners, principals and other related persons of the Adviser can and have invested in one or more of the Funds. Investors who wish for more information about the Funds, or to subscribe for an interest therein will be required to demonstrate their investment qualifications prior to accessing any information about Peakline Partners’ Funds. The various requirements for investing in a Fund, including the minimum investment size, are set forth in each Fund’s Offering Documents. The Adviser has the ability, in its sole discretion, to permit commitments below the minimum amounts set forth in the Offering Documents.

Private Equity – targets investments that the Adviser believes offer potential long-term risk-adjusted returns, with a focus on market sectors with favorable macro-growth fundamentals and relatively low cyclicality, including healthcare, food and beverage, financial services, and specialty manufacturing.

Private Credit – focused on direct lending and leasing, which includes any debt or assets held by or extended to privately held companies and most commonly involves non-bank institutions making loans or leasing equipment to private companies.

Venture Capital – generally seeks investments in early stage, growth equity, and buyout opportunities.

Investment structures generally include direct investments, co-investments, secondary investments, joint venture arrangements, and investments in third-party funds. The Adviser generally sources investment opportunities consistent with these strategies by leveraging Peakline Partners’ ecosystem of entrepreneurs, business owners, family offices, experts and referral partners. Opportunities are typically screened or evaluated using both qualitative and quantitative analyses. After an opportunity has gone through an analysis, then the opportunity is either rejected or taken to the Investment Committee for that particular Fund. The applicable Investment Committee will hold a vote on whether to pursue the opportunity. The Adviser provides advice and direction to each Fund during the entirety of the investment process, from sourcing to realization in an effort to create value. B. Risk Factors General Investment and Strategy Risks Risk of Loss; No Assurance of Investment Return – An investment in the Funds requires a long-term commitment with no certainty of return. The Funds normally invest in securities, companies or sectors that are not publicly traded. These investments are generally illiquid and can be volatile; therefore, they are not suitable for investors who may need the proceeds of such investments for frequent or unknown cash needs. There is normally no public market for the types of investments in which the Funds invest. If investors need to sell their Fund interests, they would likely do so at a substantial discount. Further, depending on the terms of the investment, the investor may not be able to transfer or sell his/her Fund interests. The risk of investing in alternative investments is the majority or complete loss of invested monies, depending on the underlying assets. In addition, investors may not see any return on investment for some time depending on the type of investment; these investments should be seen as a long-term investment subject to high risk of loss. The risk factors discussed below do not purport to be an exhaustive list of all such risks. For a more detailed discussion of the specific risks associated with each Fund and its underlying investments, please refer to each Fund’s respective Offering Documents, which should be read fully in order to understand all applicable risks. Lack of Liquidity of Investments – The Funds are generally illiquid. Although the Funds’ investments could generate current income, the return of capital and the realization of gains, if any, from such investments is expected to occur upon their disposition. In addition, it is expected that investments will not be sold until a number of years after they are made. The types of investments held by the Funds may be such that they require a substantial length of time to liquidate. Given the nature of these investments, a Fund may be unable to realize its investment objectives by sale or other disposition at attractive prices within any given period of time or may otherwise be unable to complete any exit strategy for its investments. In some cases, the Funds may be prohibited by contract from selling investments for a period of time, or there may be contractual rights or obligations that may otherwise significantly affect price and/or liquidity. In the event a loan repayment or other funding obligation arises at a time in which a Fund does not have sufficient cash assets to cover such payment, such Fund may have to liquidate certain

investments at less than their expected returns to satisfy the obligations thereby, resulting in lower realized proceeds to a Fund than might otherwise be the case. Underlying Investments – The Funds are subject to risks incident to the ownership of the underlying investments, including: changes in general economic or local conditions; changes in investment preferences that reduce the attractiveness of a Fund’s underlying investments to investors; increases in maintenance, insurance and other operating costs; changes in tax laws and rates; and changes in the laws and regulations applicable to any one or more underlying investments. Concentration Risk – Because each Fund generally invests in a limited number of investments (sometimes, only a single investment), its overall returns could be adversely affected by the negative performance of a single investment. Such a risk will be considerably greater than if the Fund were not permitted to concentrate their investments to such an extent. To the extent a Fund concentrates investments in a particular geographic region, security, sector, industry or stage of investment, it will be more susceptible to fluctuations in value resulting from adverse economic or business conditions relating thereto. In addition, the Funds may make investments in some transactions with the intent of refinancing or selling a portion thereof, and in such cases, there will be the risk that a Fund will be unable to complete the refinancing or sale, which could lead to increased risk as a result of a Fund having an unintended long-term investment and reduced diversification. Risks Upon Dispositions of Investments – In connection with the disposition of a Fund investment, a Fund will generally need to make representations about the business and financial affairs of such asset typical of those made in connection with the sale of such a business or asset. It could also be required to indemnify the purchasers of such investment if any such representation turns out to be inaccurate. These arrangements create contingent liabilities for a Fund, which might ultimately have to be funded by the Fund investors if such contingent liabilities exceed the reserves and other assets of the Fund and such investors have received prior distributions from the Fund. Furthermore, under the Delaware Revised Uniform Limited Partnership Act and Revised Uniform Limited Liability Company Act, as applicable, each investor that receives a distribution in violation of such act must, in some cases, return such distribution to the Fund. Early Termination of a Fund and/or Distributions in Kind – Pursuant to the respective Fund’s governing documents, it can be dissolved and terminated prematurely and therefore could be unable to accomplish its objectives or required to dispose of its investments at a disadvantageous time or make an in-kind distribution (causing investors not having their capital invested or deployed in the manner originally contemplated, or causing the investments to be liquidated at a time when values are relatively low). Risk of Uninsured Losses – While the Funds tend to carry customary comprehensive liability and casualty insurance, certain insurance policies may not be available or may be available only at prohibitive cost. In addition, losses may exceed insurance policy limits, and policies may contain exclusions with respect to various types of losses or other matters. Consequently, all or a portion of a Fund’s investments may not be covered by insurance, and insurance may not cover all losses. Recourse to a Fund’s Assets – A Fund’s assets, including any investments made by such Fund, are available to satisfy all liabilities and other obligations of the Fund. If a Fund itself becomes subject to a liability, parties seeking to have the liability satisfied could have recourse to the Fund’s

assets generally and not be limited to any particular asset, such as the investment leading to the liability. Highly Competitive Market for Investment Opportunities – The activity of identifying, completing, and realizing attractive Fund investments is long and complex and involves a high degree of uncertainty, especially with respect to timing. In addition, searching for appropriate investments is highly competitive. Even if investment opportunities are identified, there can be no assurance that a Fund’s bids to acquire interests in such investments will succeed; and, upon a successful bid, legal or contractual transfer restrictions, including rights-of-first-refusal, changeof-control, and similar provisions applicable to such investment could prevent a Fund from acquiring all or a portion of such investment. In addition, the Adviser could be unable to obtain as favorable terms as it would otherwise in a less competitive investment environment. The availability of investment opportunities generally will be subject to market conditions as well as the prevailing regulatory or political climate. In addition, the current private investment environment has become even more competitive as other market participants, including hedge funds and special purpose acquisition companies, have been competing for investment opportunities that have traditionally been targeted by private investment funds. The Funds will be competing with other investors, private equity and real estate funds, financial institutions and corporate or strategic buyers, some of which will have greater resources than the Funds, for the investments that the Funds would like to make. Furthermore, additional pooled investment vehicles with similar investment objectives are expected to be formed in the future by other unrelated parties. As a result, there can be no assurance that the Funds will be able to identify and complete Fund investments that satisfy their investment objectives or realize the value of those Fund investments, or that they will be able to fully invest their commitments. The Funds could incur significant expenses investigating potential investments that are ultimately not consummated, including expenses relating to due diligence, transportation, legal expenses and the fees of other third-party advisors. Borrowing and Leverage – Sometimes, the Funds are permitted to borrow or obtain leverage on a secured or unsecured basis and to borrow funds or otherwise obtain leverage for the purpose of making investments as well as for other purposes, including to make distributions to its investors, which will be in addition to indebtedness that is incurred, directly or indirectly, by the Fund’s underlying investments. Accordingly, a Fund could effectively be highly leveraged at any given time, however such instances are expected to be infrequent and temporary due to limitations on subscription line borrowings. The interest expense and other costs incurred in connection with such borrowings may not be recovered by appreciation of or cash flow from such Fund’s investments. If the investments’ performance fails to cover the cost of borrowings, a Fund’s assets (including uncalled capital commitments) could decrease faster than if there had been no borrowings. Additionally, if a Fund’s investments fail to perform to expectation or suffer losses, the value of the Fund’s investments, and therefore the underlying investors’ investment, will decrease more than if the Fund had not incurred borrowings or other leverage, so that borrowings or other leverage will magnify any such adverse consequences. Repayment of borrowings and other leverage incurred by a Fund is an obligation senior to the equity investments of its investors, and the agreements for such obligations may prohibit distributions to its investors in certain circumstances. Further, to the extent income received from investments is used to make interest and principal payments, the investors in such Fund could nonetheless be allocated income, and therefore have tax liability in excess of cash received by them in distributions. Where a Fund is permitted to engage in portfolio financing where several investments are cross-collateralized, multiple investments may be subject to the risk of loss. As a result, such Fund could lose its interests in performing investments in the event such investments are cross-collateralized with 10 | P a g e

poorly performing or nonperforming investments. The incurrence of a significant amount of indebtedness, directly or indirectly, by the Fund or an investment may, among other things, (i) give rise to an obligation to make mandatory prepayments of debt, which will reduce distributions to the investors in such Fund, (ii) limit the ability of the Fund or its investments to adjust to changing market conditions, placing it at a disadvantage compared to its competitors who have relatively less debt, and (iii) limit the ability of the Fund or its investment to obtain additional financing or increase the cost of obtaining such financing. Economic Conditions – A significant market downturn could cause significant uncertainty in the valuation and/or stability of a Fund’s investments and otherwise impact a Fund’s activities and investment returns. Interest rates, general levels of economic activity, fluctuations in the market price of securities, inflation, trade policy, war, and participation by other investors in the financial markets are expected to affect the value and number of investments made by a Fund. In addition, if marketplace events continue (or worsen), this could harm the availability of credit to businesses generally and could lead to an overall weakening of the U.S. and global economies. Any resulting economic downturn could adversely affect the financial resources of a Fund’s portfolio company or other investment, and its ability to refinance or make principal and interest payments on outstanding debt when due. In the event of such defaults, a Fund could lose both invested capital in and anticipated profits from those Fund investments. In addition, current global economic conditions could materially and adversely affect (i) the ability of a Fund or its underlying investments to access credit markets on favorable terms or at all in connection with the financing or refinancing of investments, (ii) the ability or willingness of certain counterparties to do business with a Fund or its affiliates, (iii) a Fund’s exposure to the credit risk of others in its dealings with various counterparties (for example, in connection with joint ventures or the maintenance with financial institutions of reserves in cash or cash equivalents), (iv) consumer spending and demand for the products and services offered by a Fund’s portfolio companies, (v) growth opportunity for a Fund’s investments, (vi) a Fund’s ability to exit its investments at desired times, on favorable terms, or at all, (vii) availability of reliable insurance on favorable terms or at all, and (viii) the ability of a Fund’s investors to meet their obligations to a Fund promptly or at all. As a result, there can be no assurance that a Fund will be able to make investments that will generate the returns that are being targeted. The Funds may also be required to hold illiquid investments for several years before any disposition can be affected. Prospective investors are urged to take a potential downturn and general market disrpuptions into account in deciding whether or not to make an investment in a Fund. Prior Investment Performance Not Indicative of Future Results – The performance of any Fund is dependent on future events and is, therefore, inherently uncertain. The respective prior investment experience of the Adviser and its affiliates cannot be relied upon to predict future events due to a variety of factors, including, without limitation, varying business strategies, different local and national economic circumstances, different supply and demand characteristics, varying degrees of competition, and varying circumstances pertaining to the private investment sector. A Fund is a newly formed entity and has no prior operating history on which an investor can base its prediction of future success or failure. Although the Adviser has experience in making investments in various assets, the past performance of these investments is not indicative of the future results of any Fund’s investments. Dependence on Key Personnel; Reliance on Certain Principals – The success of a Fund depends in substantial part upon the skill and expertise of the members of the Adviser’s leadership team and other individuals employed to assist them. The loss of the services of one or more of 11 | P a g e

these individuals, and the inability to recruit and hire replacements or additional key personnel as needed, could have a material adverse effect on a Fund’s operations. Furthermore, although investment professionals employed by the Adviser will commit a significant amount of their business efforts to certain Funds, they will not be required to devote all of their business time to any particular Fund’s affairs. Due Diligence and Analytic Risks – Before making the investment, the Adviser will conduct due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to the investment. Outside consultants, legal advisors, accountants, investment bankers and other third parties may be involved in the due diligence process to varying degrees. Such involvement of third-party advisors or consultants may present a number of risks primarily relating to the Adviser’s reduced control of the functions that are outsourced. In addition, if the Adviser is unable to timely engage third-party providers, its ability to evaluate and effectuate its investment strategy could be adversely affected. When conducting due diligence and making an assessment regarding an investment, the Adviser will generally rely on the resources available to it, including information provided by the investment and, in some circumstances, third-party investigations. The Adviser’s due diligence investigation may not reveal or highlight all relevant facts that may be necessary or helpful in evaluating the investment and such investigation will not necessarily result in the investment being successful. There is generally limited publicly available information about certain types of underlying investments pursued by the Funds. Moreover, there can be no assurance that attempts to identify risks associated with an investment will achieve their desired effect. Potential investors should regard an investment in a Fund as speculative and having a high degree of risk. Should the Adviser, and/or such third parties’: (i) pre-acquisition evaluation of the real and financial condition of each new investment fail to detect certain issues; (ii) estimates of the costs of acquiring, repositioning or developing an acquisition prove too low; or (iii) estimates of the time required to achieve the desired return prove too optimistic, the profitability of the investment may be adversely affected. Failure to Make Capital Contributions – The interests of a Fund could be materially and adversely affected by the failure of an investor to meet its contribution or other payment obligations to the Fund (whether arising through an investor’s default, its excuse or exclusion from one or more investments, or a permitted withdrawal or removal from the Fund). If an investor makes no contribution or payment to a Fund for any reason, the other investors could be needed to fund the shortfall, with the consequence that the non-defaulting investors have greater exposure to a Fund’s investments or liabilities than they otherwise would. An investor’s failure to make any contribution or payment to a Fund for any reason could also cause the Fund to be unable to meet the Fund’s obligations when due, which could materially and adversely impair the Fund’s ability to execute on its investment strategy or to otherwise continue operations. In such events, a Fund could face significant liabilities or penalties that could materially reduce the returns to the participating investors (including non-defaulting investors). A substantial default by (or discontinued participation of) one or more investors would leave a Fund with less available capital commitments and would limit opportunities for investment diversification and likely reduce returns to the Fund. Mandatory Withdrawal – Fund Managers have the authority to require an investor to withdraw from a Fund prior to the termination and liquidation of the Fund if the Fund Manager determines that the continued participation in the Fund of such investor could materially adversely affect the Fund or in certain other circumstances as further described in the respective Fund’s governing documents (for example, by causing the Fund to be registered as an investment company under the 1940 Act or causing the Fund’s assets to be treated as “plan assets” under ERISA). An 12 | P a g e

investor required to withdraw early from a Fund could suffer a material loss on its investment. Fixed and Variable Cost Risks – Many costs associated with a Fund’s underlying investment are not reduced at any time. These fixed costs intensify the risk to a Fund, and some costs associated with certain investments may be subject to cost increases beyond the control of the Fund. Variable rate debt in a time of rising interest rates could also result in unanticipated costs increases. Refinancing Risks – Loans to underlying investments may be subject to relatively short maturities, which may require refinancing. There is no assurance that replacement financing can be obtained by an underlying investment or, if it is obtained, that interest rates and other terms would be as favorable as for the original loans made to such underlying investments. Inability to refinance a loan on favorable terms may compel a Fund to attempt to dispose of an investment or the investments on terms less favorable than might be obtained at a later date. Effect of Fees and Expenses on Returns – A Fund will pay certain fees and will bear all expenses related to its operations. Such fees are expected to reduce the actual returns to investors. Most of the fees and expenses will be paid regardless of whether a Fund produces positive investment returns. If a Fund does not produce significant positive investment returns, these fees and expenses could reduce the amount of the investment recovered by an investor to an amount less than the amount invested in the Fund by such investor. Unspecified Investments; Availability of Suitable Investments – There can be no assurance that the Adviser will be able to find a sufficient number of attractive opportunities to meet a Fund’s investment objectives, that there will be a sufficient number of investments that meet the investment criteria of the Funds or that the Funds will be presented with an adequate number of new investment opportunities. Changes in various factors (including, among others, economic conditions, political conditions, securities markets conditions and tax burdens) may also adversely affect the availability of suitable and attractive investment opportunities for the Funds. No assurance can be given that investment opportunities can be sourced, acquired, financed or disposed of at favorable prices or terms or that perceived trends in the market for the types of investments suitable for the Funds will continue. Accordingly, no assurance can be given that any Fund will be able to fully deploy all of its capital. Investors will not have an opportunity to evaluate for themselves the relevant economic, financial and other information regarding the investments to be made by a Fund and, accordingly, will be dependent upon the judgment and ability of the Fund Manager to make investments in the Funds, and for the Funds to identify, structure and implement investments consistent with their investment objectives and policies. Need for Follow-On Investments – Following a Fund’s initial investment in an asset, the Fund could be called upon to provide additional funds or otherwise increase its existing investment therein. An economic recession or adverse business prospects and might have a negative impact on the ability of a portfolio company or other Fund investment to access additional capital necessary to sustain growth or conduct operations. The Fund may not be able or willing to make one or more follow-on investments, which could have a substantial negative impact on such company or investment, as applicable, which in turn may negatively impact the Fund’s investment therein, reduce or eliminate returns and result in a complete loss of the Fund’s investment. Risks Related to Investments in Real Estate Real Estate Risks – Funds investing in real estate will be subject to the risks inherent in the 13 | P a g e

ownership, development, and operation of real estate and real estate-related businesses and assets. Deterioration of real estate fundamentals generally, and in the U.S. in particular, would negatively impact the performance of one or more of a Fund’s investments (and thus the underlying investors). These risks include, but are not limited to, those associated with the burdens of ownership of real property, general and local economic conditions, changes in environmental and zoning laws, casualty or condemnation losses, regulatory limitations on rents, decreases in asset values, changes in the appeal of assets to tenants, changes in supply of and demand for competing assets in an area (as a result, for instance, of overbuilding), the financial resources of tenants, changes in availability of debt financing which could render the sale or refinancing of investments difficult or impracticable, changes in building, environmental and other laws, energy and supply shortages, various uninsured or uninsurable risks, natural disasters, political events, changes in government regulations (such as rent control), changes in real property tax rates and operating expenses, changes in interest rates, and the availability of mortgage funds, which could render the sale or refinancing of investments difficult or impracticable, increased mortgage defaults, increases in borrowing rates, negative developments in the economy or political climate that depress travel activity, environmental liabilities, contingent liabilities on disposition of assets, acts of God, terrorist attacks, war and other factors that are beyond the control of the RE Funds. In addition, there can be no assurance that there will be a ready market for the resale of a Fund investment. Illiquidity could result from the absence of an established market for Fund investments or a disruption in the market. Co-Investments; Joint Ventures – As noted above, certain Funds will from time to time participate in co-investments and joint venture arrangements with unaffiliated third parties, including sellers and/or co-owners of investment property, affiliates of a seller, investors in the Fund or other third parties (including other investment funds, accounts and clients managed or advised by Peakline Partners). Such investments will involve risks not present in investments where a third party is not involved, including the possibility that: (i) the Fund and such co-venturer will reach an impasse on a major decision that requires the approval of both parties; (ii) a coventurer or partner of the Fund will at any time have economic or business interests or goals that are inconsistent with those of the Fund; (iii) the co-venturer or partner will encounter liquidity or insolvency issues or become bankrupt; (iv) the co-venturer or partner will be in a position to take action contrary to the Fund’s investment objective; (v) the co-venturer or partner will take actions that subject the property to liabilities in excess of, or other than, those contemplated; or (vi) in certain circumstances the Fund will be liable for actions of its co-venturers or partners. The coventurer or partner could be a joint venture partner or interest holder in another joint venture or other vehicle in which Peakline Partners has an interest or otherwise controls. It could also be more difficult for the Fund to sell its interest in any joint venture, partnership or entity with other owners than to sell its interest in other types of investments (and any such investment could be subject to a buy-sell right). The Fund is permitted to grant co-venturers or partners approval rights with respect to major decisions concerning the management and disposition of the investment, which would increase the risk of deadlocks or unanticipated exits from an investment. A deadlock could delay the execution of the business plan for the investment or require the Fund to engage in a buy-sell of the venture with the co-venturer or partner or conduct the forced sale of such investment or require alternative dispute resolution in order to resolve such deadlock. As a result of these risks, the Fund could be unable to fully realize its expected return on any such investment. Further, to the extent that the Fund offers any co-investment opportunity to any investors or third parties, some or all of the risks described above will also apply to such co-investments. Non-Renewal of Leases – A Fund’s investment in real estate is subject to the risks that, upon expiration, leases for space may not be renewed, the space may not be re-leased, or the terms 14 | P a g e

of renewal or re-lease, including the cost of required renovations or concessions, may be less favorable than current lease terms. In the event of any of these circumstances, cash flow from a Fund’s real estate investments and, therefore, the value of an investment in a Fund, could be adversely affected. These risks may be particularly acute for single-tenant properties. Tenant Default and Bankruptcy – A tenant’s default in performing its lease obligations, or the tenant’s bankruptcy, could adversely affect cash flow from a real estate investment and cause a Fund to incur legal costs and other costs that would not likely be recouped. An early termination of a lease by a bankrupt tenant would result in unanticipated expenses to re-let the premises. In addition, a Fund may encounter additional risks and uncertainties with respect to the treatment of tenants under the laws of the various jurisdictions in which a Fund may invest, including, without limitation, in circumstances involving a tenant’s bankruptcy. Risks of Development Projects; Construction Risks – Real estate development and redevelopment projects generally have a higher degree of risk when compared to existing income generating properties. The successful development of new, or expansion of existing, real estate development projects entails a variety of risks (some of which could be unforeseeable at the time a project is commenced) and could require or result in the involvement of a broad and diverse group of stakeholders who will either directly influence or potentially be capable of influencing the nature and outcome of the project. In connection with the development of a new development project, the acquisition of a late-stage development project, and/or expansion of an existing development project, a Fund could encounter construction risks typical for infrastructure businesses, including:

labor disputes, shortages of material and skilled labor, or work stoppages,

subsurface conditions,

slower than projected construction progress and the unavailability or late delivery of necessary equipment,

less than optimal coordination with public utilities in the relocation of their facilities,

political or local opposition,

adverse weather conditions and unexpected construction conditions,

accidents or the breakdown or failure of construction equipment or processes, receipt of regulatory approvals or permits, site or land procurement,

environmentally related issues,

counterparty non-performance,

project feasibility assessment and dealings with and reliance on third-party consultants, and

catastrophic events such as explosions, fires and terrorist activities and other similar events beyond a Fund Manager’s control.

These risks could result in substantial unanticipated delays or expenses and, under certain circumstances, could prevent completion of construction activities once undertaken, any of which could have an adverse effect on a Fund and on the amount of capital available for distribution to investors. Construction costs could exceed estimates for various reasons, including inaccurate 15 | P a g e

engineering and planning, labor and building material costs in excess of expectations and unanticipated problems with project startup. Such unexpected increases could result in increased debt service costs and funds being insufficient to complete construction, which in turn could result in the inability of project owners to meet the higher interest and principal repayments arising from the additional debt required. Delays in project completion can result in an increase in total project construction costs through higher capitalized interest charges and additional labor and material expenses and, consequently, an increase in debt service costs. Delays could also affect the scheduled flow of project revenues necessary to cover the scheduled operations phase debt service costs, operations and maintenance expenses and damage payments for late delivery. In addition, risks inherent in construction work could give rise to claims or demands against a portfolio company from time to time. Moreover, market conditions could change during construction that make such development less attractive than at the time it was commenced. Risks of Investments in Qualified Opportunity Zones – Certain RE Fund investments will include real estate development and re-development projects located in “qualified opportunity zones” (“QOZs”), as designated in accordance with 2017 H.R. 1, known as the Tax Cuts and Jobs Act, as extended and amended pursuant to P.L. 119-21, known as the One Big Beautiful Bill Act. These investments generally carry the risks associated with the concentration of the Fund’s investments in economically depressed areas. As a result, a Fund’s investments will be exclusively concentrated in QOZs, and a Fund could experience losses as a result of such concentration. Worsening economic conditions in QOZs in which a Fund’s investments will be concentrated could have an adverse effect on the Fund’s assets, including reducing the demand for new financings, limiting the ability of a Fund’s investments to pay financed amounts and impairing the value of a Fund’s assets. Capital Intensive – Real estate investing is capital intensive. A Fund could acquire assets that have defects, and normal wear and tear on such Fund’s assets could necessitate repairs. A Fund could acquire an asset with a capital expenditure plan, but the conditions of the asset could cause the capital requirements to exceed expectations. Furthermore, a Fund could be required to expend funds to correct defects or to make improvements before an investment that it made in an asset can be sold. In all these cases, such Fund could be required to expend capital on the asset in excess of its business plan. No assurance can be given that such Fund will have the necessary funds available to meet the capital requirements of any particular asset, that any such efforts or expenditures will be successful, or that such funds, once expended, will yield a sufficient incremental return. Risks Relating to Private Company Investments Business and Credit Risks and Risks Associated with Portfolio Companies – A fundamental risk associated with a private equity investment strategy is that the companies in which private equity funds invest will not perform as expected. Portfolio companies could deteriorate as a result of, among other factors, an adverse development in their business, a change in the competitive environment, an economic downturn, or legal, tax or regulatory changes. Portfolio companies that a Fund Manager expects to remain stable could in fact operate at a loss or have significant variations in operating results, could require substantial additional capital to support their operations or to maintain their competitive position, or could otherwise have a weak financial condition or be experiencing financial distress. Business risks could be more significant in smaller portfolio companies or those that are embarking on a build-up or operating turnaround strategy. Some or all of such risks could be present in connection with a Fund’s investment therein. 16 | P a g e

Less Established Companies – Certain investments made by the Funds could be in less established companies or early-stage companies. Such Fund investments could involve greater risks than are generally associated with investments in more established companies. Such companies could have shorter operating histories on which to judge future performance and might not have significant or any operating revenues. Such companies also could have a lower capitalization and fewer resources (including cash) and be more vulnerable to failure, resulting in the loss of such Fund’s investment therein. In addition, less mature companies could be more susceptible to irregular accounting or other fraudulent practices. Lack of Information for Investments in Private Companies – The investment strategy for one or more Funds could involve investments in private companies for which no market exists. Little public information exists about many of these companies, and such Funds will be required to rely on the Fund Manager’s diligence efforts to obtain adequate information to evaluate the potential risks and returns involved in investing in these companies. Incomplete or inaccurate information could impact both initial and ultimate valuations of such investments, as well as such Fund’s operating plan for such investments. Therefore, the risk that such Fund could invest on the basis of incomplete or inaccurate information could adversely affect its investment performance. The uncertainty regarding information about its prospective investments subjects the Funds to greater risk than investments in publicly traded companies. There is no assurance that any Fund’s diligence efforts will result in it obtaining fully complete and accurate information about prospective investments or that any investment will be successful. Minority Equity Interests – Certain Funds may make minority, non-controlling, equity investments in companies over which a Fund will have no or limited ability to exert influence. In such cases, the Adviser expects that the existing managers of the portfolio company will retain autonomy over the day-to-day operations of the company and will generally retain a majority stake in it. Accordingly, such Funds will rely on the existing management and board of directors or similar body of the portfolio company, which could include representation of other investors with whom the Fund or its affiliates is not affiliated and whose interests could conflict with the interests of the Fund. In holding non-controlling interests, the Fund will have a limited ability to create additional value in the portfolio company by effecting changes in the strategy and operations of the portfolio company or to protect its position or to create or take advantage of exit opportunities. The Fund’s inability to control the timing of the making, restructuring, refinancing and exiting of its investment could adversely affect performance. The management of the portfolio company could make business, financial or management decisions with which the Fund Manager does not agree, or such management could take risks or otherwise act in a manner that does not serve the Fund’s interests. Reliance on Portfolio Company Management. The Funds seek to monitor the performance of investments in operating companies either through interaction with the board of directors of the applicable company and/or by maintaining an ongoing dialogue with the company’s management team. However, a Fund is generally not in a position to control a company investing in its debt securities and a company’s management will be primarily responsible for the operations of the company on a day-to-day basis. Although the Fund Managers seek to invest in companies with strong management teams, there can be no assurance that existing management teams, or any new ones, will be able to operate companies successfully. In addition, with respect to debt or minority equity investments, funds are subject to the risk that a company in which it invests could make business decisions with which the Fund Manager disagrees and the management of such company, as representatives of the majority common equity holders, could take risks or otherwise act in ways that do not serve the interests of such portfolio company. 17 | P a g e

Leverage and Distressed Securities – The capital structure of a Fund’s portfolio company could be highly leveraged and/or have securities that are distressed, or such conditions could develop in the future. If such conditions were to materialize, this would likely increase the exposure of the Fund investment to adverse economic factors such as significantly rising interest rates, severe downturns in the economy or deterioration in the conditions of the portfolio company or its industry. Under such circumstances, the returns generated from such investment could not compensate the Fund adequately for the risks assumed. Control Positions and Non-Controlling Interests –The Funds may be permitted to assume control positions in its portfolio companies. The exercise of control over a company imposes additional risks of liability for environmental damage, product defects, failure to supervise management, violation of governmental regulations and other types of liability in which the limited liability generally characteristic of business operations could be ignored. A Fund could hold a noncontrolling interest in certain companies and, therefore, could have a limited ability to protect its position in such companies. Equipment Leasing – The Funds may participate in equipment leasing arrangements in which they acquire or finance equipment that is leased to businesses and other end users. The Funds generally receive revenue through lease payments. The risks associated with this strategy include lessee default or delayed payments, equipment depreciation, technological obsolescence, and challenges in repossessing or disposing of leased equipment. Additionally, market demand for certain types of equipment may fluctuate, which could adversely affect lease terms and revenue. There is no assurance that the Funds will achieve their expected returns from equipment leasing, and losses could materially and adversely affect the performance of the Funds. Regulatory and Other Risks Legal, tax and regulatory changes could occur during the term of an investment that could adversely affect the Fund, its underlying investments and/or the investor. Investment Company Act of 1940 – The Funds will not be subject to the provisions of the 1940 Act in reliance upon Section 3(c)(1), 3(c)(5) or Section 3(c)(7) thereof. Section 3(c)(7) excludes from the definition of “investment company” any issuer whose outstanding securities are owned exclusively by “qualified purchasers” (as defined in Section 2(a)(51) under the 1940 Act). Section 3(c)(1) of the 1940 Act excludes from the definition of “investment company” any issuer whose outstanding securities are beneficially owned not more than one hundred persons, and in each case that meet the other conditions contained therein. A “qualified purchaser” generally includes (among others): (i) a natural person who owns not less than $5 million in investments, (ii) a company acting for its own account or the accounts of other qualified purchasers that owns and invests on a discretionary basis not less than $25 million in investments and (iii) certain trusts. [Add description of 3(c)(5)] As a result of the foregoing, the Funds will not be subject to the substantive and disclosure provisions of the 1940 Act and, accordingly, Fund investors will not be afforded the protections of the 1940 Act. Investors will also be asked to make representations and agree to comply with restrictions on transfer designed to assure that the respective Fund remains excluded from “investment company” status under the 1940 Act. Investment Advisers Act of 1940 – The Adviser is registered as an investment adviser under the Advisers Act and, as such, is subject to the Advisers Act. Failure to comply with the 18 | P a g e

requirements imposed on us could have a material adverse effect on the Adviser’s ability to perform its duties to the Funds. The Adviser’s ability to source and execute transactions for the Funds could also be adversely affected by negative publicity arising from any regulatory compliance failures or other inappropriate behavior attributed to or any other publicity related to the Adviser, any affiliate of the Adviser or any of their respective investment professionals. Business Continuity Plans – In the event of unforeseen catastrophic events, such as cyber attacks, natural disasters, terrorist attacks and epidemics, the Adviser will initiate its business continuity plan to safeguard that its employees have the resources and technology necessary to continue their responsibilities and meet the needs of its Funds, investors and underlying Fund investments. The business continuity plan is tested to ensure that appropriate measures are put in place to manage any such catastrophic events. Despite such measures, the Adviser cannot predict the level of disruption that such catastrophic events could have on its operations or the ability of the plan to succeed in a time of crisis. Thus, its business continuity plan may be insufficient to continue operating the Adviser’s business as usual. The failure of the business continuity plan for any reason could cause significant interruptions in the operations of the Adviser, the Funds, and/or their underlying investments. While the Adviser has limited ability to control these risks, the Advisers will work with each Fund Manager and its underlying portfolio companies or other investments, as applicable, with respect to the ongoing implementation of its own business continuity plan. Future Changes in Applicable Law; Overall Regulatory Environment – The Funds’ ability to implement their investment programs, as well as the ability of the Funds to conduct their operations and objectives, is based on laws and regulations that are subject to change through legislative, judicial or administrative action. Future legislative, judicial or administrative action could adversely affect the Funds’ ability to implement their investment programs, as well as the ability of the Funds to conduct their operations and achieve their objectives. Recent economic events have given rise to a political climate that may result in the Advisers and Funds becoming subject to increased regulatory scrutiny and/or entirely new legal, tax or regulatory regimes. The Funds and/or their investments may be adversely affected as a result of new or revised legislation, or regulations imposed by U.S. or non-U.S. tax or governmental regulatory authorities or selfregulatory organizations that supervise the financial markets. The Funds and/or some or all of their investors also may be adversely affected by changes in the interpretation or enforcement of existing laws and rules by these governmental authorities and self-regulatory organizations. It is not possible to determine the extent of the impact of any new or revised laws, regulations or initiatives that may be proposed, or whether any of the proposals will become law. Compliance with any new laws or regulations could be more difficult and expensive and may have a material adverse effect on the Funds and some or all of their respective investors. SEC Regulation; Impact of Rule Reforms – Changes in law or regulations could adversely affect the value of investments held (directly or indirectly) by a Fund, affect the ability of a Fund to pursue its investment strategy, restrict the Adviser’s and Fund Managers’ ability to operate as they have in the past, and increase the amount of fees or expenses borne by a Fund and the investors therein indirectly. The time and attention as well as the financial costs associated with compliance with any regulatory rulemaking could divert the Adviser’s resources away from managing the investment programs of the Funds, which could adversely affect both the Funds and their underlying investments. Similarly, any cost of new compliance obligations attributable to the Funds have the potential to increase the financial burden on the Funds to the extent the 19 | P a g e

Funds themselves are required to bear such costs and expenses and could reduce investors’ distributions. Further, the impact of SEC rulemaking is uncertain and legal or regulatory uncertainty with respect to any such rulemaking is likely to result in a diversion of the Adviser’s time and resources as well as expose the Adviser to regulatory risk, all of which in turn could negatively impact the Funds and their underlying investments. Inflation – Certain countries have experienced and could in the future experience substantial, and in some periods extremely high, rates of inflation. Inflation and rapid fluctuations in inflation rates have harmed and could continue to harm the economies and securities markets (both public and private) of certain countries in which the Funds invest. There can be no assurance that high rates of inflation will not have a material adverse effect on the investments of the Funds. For example, if a company or asset were unable to increase its revenue while business expenses were increasing, the company’s profitability would likely suffer. Likewise, to the extent a company or asset has revenue streams that are slow or unable to adjust to changes in inflation, including by contractual arrangements or otherwise, the company or asset could increase revenue by less than its expenses increase. Conversely, as inflation declines, a company or asset could see its competitors’ costs stabilize sooner or more rapidly than its own. Moreover, as inflation increases, the real value of the interests in the Funds and distributions therefrom can decline and increase the likelihood that the Fund will surpass its hurdle rate. Disease and Epidemics – The effect of disease and epidemics, such as the Coronavirus pandemic, can adversely impact the operations, performance and financial position and business of the Adviser, the Funds and their investments. Coronavirus, renewed outbreaks of other epidemics or the outbreak of new epidemics could lead to health or governmental authorities requiring the closure of offices or other businesses and could also lead to a general economic decline. For example, such events could adversely impact economic activity through disruption in supply and delivery chains. Moreover, the Adviser’s operations and those of the Adviser’s Funds or investments could be harmed if personnel are quarantined as the result of, or to avoid, exposure to a contagious illness. Similarly, travel restrictions or operational issues resulting from the rapid spread of contagious illnesses could have a material adverse effect on business and results of operations. A resulting negative effect on economic fundamentals and consumer confidence could weaken market value, increase market volatility and reduce liquidity, all of which could harm the Adviser’s business, the Funds and underlying Fund investments. Cybersecurity – The Adviser, each Fund Manager, Fund and their underlying portfolio companies, and each of their respective service providers, rely on the internet, computer networks and various software and hardware (collectively, “information technology” or “IT” systems) for both internal and external-facing operations. The Adviser manages certain IT systems but also relies on third-party service providers and vendors that manage other IT systems and provide products and services critical to the Adviser’s business. The Adviser and its affiliates collect and hold personally identifiable information of its investors, and Fund Managers engage third party service providers that may have access to such personally identifiable information in connection with providing necessary information technology and security and other business services to the Funds. Although such persons make efforts to maintain the security and integrity of such information technology networks and related systems, and they have implemented various measures to manage the risk of a security breach or disruption, there can be no assurance that their security efforts and measures will be effective or that attempted security breaches or disruptions will not be successful or damaging. The Adviser and its affiliates face risks associated with security breaches, whether through cyberPeakline Partners, LLC – Form ADV Part 2A 20 | P a g e

attacks or cyber intrusions over the internet, malware, computer viruses, attachments to emails, phishing attempts or other scams, persons inside its organization or persons/vendors with access to their systems and other significant disruptions of their information technology networks and related systems. Such persons’ information technology networks and related systems are essential to the operation of their respective businesses and their ability to perform their respective day-to-day operations. Even the most well-protected information, networks, systems and facilities remain potentially vulnerable because the techniques used in such attempted security breaches evolve and generally are not recognized until launched against a target, and in some cases, are designed not to be detected and, in fact, may not be detected. Accordingly, the Adviser or any of its affiliates may be unable to anticipate these techniques or to implement adequate security barriers or other preventative measures, and thus it is impossible for such persons to entirely mitigate this risk. A breach or significant and extended disruption in the function of the Adviser or its affiliates’ systems could damage their reputation, generate third party claims, result in the unintended and/or unauthorized public disclosure or the misappropriation of proprietary, personally identifiable and confidential information and require the Adviser and/or its affiliates to incur significant expenses to address and remediate or otherwise resolve these kinds of issues. The Adviser or its affiliates may not be able to recover these expenses from their service providers, its insurers or any other responsible parties. As a result, there can be no assurance that the Adviser or its affiliates would not be adversely impacted. Artificial Intelligence – Advancements and changes to artificial intelligence (“AI”) technology may disrupt the business models of the Funds’ investments through various means. This may include increasing competition, lowering barriers to entry, accelerating innovation cycles, and reducing demand for existing products or services. These changes may result in loss of market share, declining revenues, or obsolescence of core business operations. Firms and business models that fail to adopt or respond effectively to AI developments may be particularly adversely affected. In addition, the costs associated with integrating AI or otherwise remaining competitive in business’ respective market may impair financial performance. These factors could materially and adversely affect the value and performance of the Funds’ investments. Material Non-Public Information – Despite the Adviser’s maintenance of restricted lists and other internal controls, the internal controls relating to the management of material non-public information could fail and lead to the Adviser, or one of its investment professionals, buying or selling a security while, at least constructively, in possession of material non-public information. Inadvertent trading on material non-public information could harm the Adviser’s reputation, lead to the imposition of regulatory or financial sanctions, and harm the Adviser’s ability to perform its investment management services on behalf of a Fund. Disclosure of Portfolio and Other Information – On occasion, we expect to provide portfolio holdings information to entities that have been retained by clients to evaluate portfolio risk. We provide this information in our sole discretion and reserve the right to cease providing information at any time. We make reasonable efforts to preserve the confidentiality of the information we provide, such as by entering into non-disclosure agreements, but we cannot ensure that the entities we provide information to will fulfill their confidentiality obligations. Reliance on Other Third Parties – The Funds rely on third parties to provide certain services, which reliance may ultimately not be justified. Any default or failure to perform by such service provider could have an adverse effect on a Fund, its assets, and the interests of the investors. Also, 21 | P a g e

the Fund may be liable for the actions of its service providers. While each Fund Manager will attempt to limit the liability of the Fund by reviewing qualifications and previous experience of all service providers, such action may be insufficient to protect a Fund from liability or loss. *** Past performance is not a guarantee of future returns. Investing in the Funds involves a risk of loss that each existing and prospective investor should understand and be willing to bear. Existing and prospective investors are reminded to read fully and carefully understand these risks as outlined in Offering Documents and to discuss these risks with the Adviser. Conflicts of Interest The Adviser and its affiliates engage in a broad range of advisory and non-advisory activities, including investment activities for their own account and for the account of its Funds, and providing transaction-related, legal, management and other services to the Funds and their Fund investments. The Adviser will devote such time, personnel and internal resources as are necessary to conduct the business affairs of each Fund in an appropriate manner, as required by the relevant Fund’s governing documents, although the Funds and their respective investments will place varying levels of demand on these over time. In the ordinary course of the Adviser conducting its activities, the interests of a Fund likely will conflict with the interests of the Adviser, another Fund or Fund investment, or their respective affiliates in certain circumstances. Certain conflicts of interest are discussed herein. As a general matter, the Adviser will determine all matters relating to its management of the Funds using its best judgment considering all factors it deems relevant, but in its sole discretion, subject in certain cases to the required approvals by the investors in or the advisory boards of the participating Funds. Affiliated Person Ownership in the Adviser and its Affiliates - Some Peakline Partners employees and affiliated persons (collectively, “Peakline EAPs”) are owners of Peakline Partners and/or its affiliates. These ownership interests give rise to certain conflicts of interest, as the proceeds of any such investment offerings are expected to ultimately accrue, at least in part, to the benefit of their owners, which include the Peakline EAPs. Accordingly, the Peakline EAPs have an incentive to present these investment opportunities to our Fund investors and/or to recommend or facilitate investments by our Fund investors in any such offering. To mitigate these conflicts of interest, Peakline Partners discloses the nature of this conflict of interest, and will not place the interests of Peakline Partners above those of any Fund investor. Relationship Among Funds – The Adviser and its affiliates currently manage, and expect in the future to manage, several Funds that pursue investment strategies similar to, overlapping with, or related to the investment strategy of each other, which creates conflicts of interest for allocation of time, resources and investment opportunities. In addition, to accommodate the participation by one or more investors (or related group of investors), the Adviser generally has a right to establish one or more new Funds. In addition, some Funds will involve different terms and fee structures that incentivize the Adviser to make more (or less) of a particular investment opportunity available to a Fund and therefore present conflicts of interest in respect of the managing and monitoring of such investments and evaluating and executing on disposition opportunities. Accordingly, the Adviser cannot assure equal treatment with respect to allocation of time, resources and investment opportunities. In addition, investments and other activities undertaken by the Adviser could affect the existing investments and/or investment opportunities of a Fund. For example, any such investment in a particular industry could limit the ability of a Fund to pursue other opportunities within 22 | P a g e

the same or related industries. Additionally, portfolio companies in which the Funds invest are expected to, from time to time, be in the same industry as, and compete with, one or more Funds’ portfolio company investments. In such instances, the Adviser will be free, in its discretion, to make recommendations and decisions with respect to the origination or disposition of such investments, independent of the recommendations and decisions made by the Adviser for the Fund. All such recommendations and decisions will be made for a Fund in a manner that the Adviser finds, based on its fiduciary duties and contractual obligations, appropriate given the investment objective, liquidity, diversification and other limitations of a Fund. The principals and senior executives of any given Fund Manager are generally permitted to provide services to other Funds. A Fund’s Fund Manager and its affiliates and principals often reserve the right to also manage separate accounts, which accounts may invest in the types of investments pursued by such Fund. Outside Activities of Principals and Other Personnel and their Related Parties – Certain personnel of the Adviser and its various affiliates may be subject to a variety of conflicts of interest relating to their responsibilities to the Funds and their respective portfolio companies. For example, such individuals’ outside business activities as members of investment or advisory committees or boards of directors of or as advisors to other investment funds, corporations, foundations or other organizations could create a conflict if such other entities have interests that are adverse to those of the Adviser or any particular Fund, including if such other entities compete with a Fund for certain resources. Such personnel may have a greater financial interest in the performance of the other entities than the performance of the Funds. This involvement may create conflicts of interest in making investment(s) on behalf of the Fund and such other funds, accounts and other entities. Although the Adviser will generally seek to minimize the impact of any such conflicts, there can be no assurance they will be resolved favorably for the Funds. Also, personnel are generally permitted to invest in alternative investment funds, private equity funds, real estate funds, hedge funds and other investment vehicles, as well as securities of other companies, some of which will be competitors of the Funds. Investors will not receive any benefit from any such investments, and the financial incentives of advisory personnel in such other investments could be greater than their financial incentives in relation to the Funds. Shared Leadership Structure – The Adviser is governed by a Board of Directors, whose directors overlap with the Board of Directors of Cresset Capital Management, LLC, which owns and controls Cresset Asset Management, LLC, an SEC-registered wealth management affiliate, as discussed in Item 10.A below. Because the overlapping directors will govern both the Adviser and Cresset Asset Management, LLC, such overlapping directors could have an incentive to favor one such investment adviser over the other. These overlapping directors could also face competing obligations among each investment adviser from a time-commitment and cost allocation perspective. To address these conflicts, the Adviser will monitor such competing interests and take any steps it deems appropriate to ensure that clients are ultimately treated fairly and equitably over time. Diverse Investor Base; Conflicts Amongst Fund Investors – The investors in any given Fund may be subject to different legal, tax, and regulatory regimes. For example, investors may include taxable and tax-exempt entities and will be organized in various jurisdictions. The nature and diversification of the Funds’ investments, as well as the manner in which such Funds make, structure, hold, and exit such investments could therefore lead to a more favorable legal, tax or regulatory outcome for some investors, while disadvantaging others. In selecting investments appropriate for a Fund, a Fund Manager will consider the investment objectives of the investing Fund as a whole, not the investment objectives of any of the underlying Fund investors individually. To the extent that the Fund Manager is able to structure certain investments based in part on 23 | P a g e

investors’ respective legal, tax and regulatory constraints, such Fund Manager will not take into account such considerations as they relate to each individual investor. Side Letters – The Adviser and/or its affiliates enter into side letters or similar agreements with certain investors in connection with their investments without the approval of any other investor. Side letters subject the Adviser to conflicts of interest. This will generally have the effect of establishing rights under or supplementing the terms of the relevant governing document with respect to such investor in a manner beneficial to such investor and more favorable to such investor than those applicable to other investors. Such rights or terms in any such side letter or other similar agreement can include, without limitation, (i) rights to designate a member of a board of directors (or other governing body) of an investment; (ii) excuse or exclusion rights applicable to particular investments (which would increase the percentage interest of other investors in, and contribution obligations of other investors with respect to, such investments); (iii) reporting obligations of the Adviser; (iv) waiver of certain confidentiality obligations; (v) consent of the Adviser to certain transfers by such investor; (vi) rights or terms necessary given particular legal, regulatory, or public policy characteristics of an investor; (vii) adjustments to fees or other economics (including, without limitation, the management fee, carried interest, or distributions); (viii) access to certain information; (ix) consent rights of the investor; (x) co-investment rights; (xi) tax and structuring matters; and (xii) other representations, warranties or diligence confirmations. The Adviser and/or its affiliates will enter into such side letters with any party as the Adviser determines, in their sole and absolute discretion, at any time. Unless required by the relevant Fund agreement, the Adviser will generally not be required to disclose to or otherwise notify the other investors of any such side letters or of any of the rights or terms or provisions, and some or all of the other investors will generally not be entitled to receive such additional benefits or other rights. In addition, the Adviser will not have to offer such additional or different rights or terms to any or all of the other investors, and investors will not necessarily have so-called “most-favored-nation” rights in respect of all or any of the more favorable terms provided to others. Investors will have no recourse against the Fund or the Adviser or any of its affiliates if certain investors receive additional benefits or other rights under side letters more favorable than the terms received by other investors. As a result of certain side letters, investors holding the same Fund interests may have different returns, or receive different information, depending on any arrangements applicable to a given investor’s interest in the Fund. In addition, if the Adviser enters into a side letter entitling an investor to be excused or excluded from a particular investment or withdraw from the Fund, (a) any election to be excused or excluded or to withdraw by such investor will increase the percentage interest of other investors in, and contribution obligations of other investors with respect to, future investments, and reduce the overall size of the Fund and/or (b) the Fund’s ability to consummate certain investments could be inhibited. Co-investment rights granted to an investor in a side letter or other similar agreement will, at times, lead to fewer co-investment opportunities (or reduced or no allocations) being made available to other investors. It is also expected that the Adviser will from time to time confirm factual matters to incoming investors, make statements of intent or expectation to such investors or acknowledge statements by such incoming investors that relate to the Fund and/or the Adviser’s activities pertaining to it in one or more respects. As a result, side letters or similar agreements could enable such investors to take actions based on information not available to other investors that do not have the benefit of such agreements. Any such statements, confirmations agreements or acknowledgements will not involve the granting of any legal right or benefit, and therefore generally will not be subject to any so-called “most-favored-nations” process or election by the investors, and as a result investors will not typically receive notice of it or copies of the documentation (if any) in which they are contained. 24 | P a g e

There can be no assurance that any such arrangements will not harm the Fund or that such arrangements will not influence the Adviser’s activities or the operation of the Fund. In addition, the Adviser and its affiliates have a right to enter into agreements with investors while considering such investor’s overall relationship with the Adviser and its affiliates, including one or more Funds aside from the present Fund to which such investor is subscribing, with terms applicable solely to such investor and its investment in the Fund and other Funds. Such an agreement will generally involve an investor agreeing to make a capital commitment to multiple Funds or strategies sponsored by the Adviser and/or its affiliates, one or more of which could include the Fund or a separate account under an overall integrated arrangement. Investors will be unable to elect any rights or benefits granted to such multi-strategy investors. Specific examples of such additional rights and benefits could include specialized reporting, more favorable or different economic arrangements, rights to participate in the investment process, as well as priority rights or targeted amounts for co-investments alongside the Fund or other vehicles or strategies sponsored by the Adviser and/or its affiliates. Allocation of Shared Expenses – The Adviser and its affiliates generally incur fees, costs and expenses on behalf of more than one Fund and/or the Adviser or its affiliates. In such instances, the Adviser will determine a fair and equitable method for allocating these costs amongst the relevant parties incurring such expenses, subject to all applicable legal, contractual or similar restrictions. For example, the Adviser reserves the right to choose to allocate based upon the Funds’ capital commitment size, amount of invested capital in underlying deals, and/or usage percentages of the service or product incurring such expense, as well as whether all or a portion of a multiple-purpose expense should be viewed as overhead and absorbed by the Adviser and/ or its affiliates. The allocations of such expenses will not always be proportional, and any such determinations involve inherent matters of discretion. The use of any particular expense allocation methodology will at times lead certain Funds to bear relatively more expenses in some cases and less in others compared to what any particular Fund would have borne if a different methodology had been used. The Adviser, in its discretion, can revise or change previously determined allocation methodologies to ensure that such expenses remain fairly and reasonably allocated among the Funds, the Adviser and its affiliates (as applicable). Allocation of Investment Opportunities – In certain circumstances, multiple Funds will be in competition for limited investment opportunities. The Adviser may have differing fee arrangements with its Funds which, in some circumstances, will create a conflict of interest for the Adviser with regard to the allocation of these opportunities. Investment opportunities will be allocated on a basis that over a period of time is fair and equitable among the Funds, as determined in good faith by the Adviser’s applicable investment committee (as applicable, the “Investment Committee”) in consideration of those factors it deems relevant, with the support and review of the Adviser’s finance department, as described in its Allocation of Investment Opportunities Policy. In certain circumstances, the Adviser is permitted to determine to alter certain investment allocations to take into account the structure of certain transactions or legal, tax, regulatory or other similar considerations (including applicable investment limitations, availability of capital, applicable contractual obligations, the specific nature and type of the investment, portfolio diversification concerns, the anticipated tax treatment of the investment), as determined by the applicable Fund Manager in its discretion, which could result in a Fund not investing in a particular investment. Moreover, based on such considerations, a Fund may invest in different proportions in particular coinvestments, may structure its investment in particular co-investments in a manner that differs from the investment structure used by other such Funds or may exit co-investments at different times, on 25 | P a g e

different terms or in different proportions than other such Funds. As a result, the returns of a Fund could differ materially. Such differentiation (particularly in the structuring and timing of investments) can lead to conflicts of interest. Conflicts could arise in setting the investment allocation where the differing returns among the vehicles could affect the aggregate amount of carried interest that would be earned by the Adviser. Further, there is an inherent conflict in determining whether a Fund should not participate in a particular investment because of the possibility that the investment will incur a significant tax burden, where such tax burden is not borne by the Adviser in calculating the amount of the carried interest. After the Funds receive full and fair allocation as determined by the Adviser’s Allocation of Investment Opportunities Policy, employees and partners are eligible to invest alongside the Funds. If a Peakline Partners’ employee or partner wishes to participate in an investment that has been allocated to the Adviser’s Funds, the employee or partner must adhere to all reporting and preclearance requirements as enumerated in the Adviser’s Code of Ethics. Valuation – The fair value of all Fund investments, or of property received in exchange for any investments, will be determined by the Fund Manager in accordance with such Fund’s respective governing documents. Accordingly, the carrying value of an investment may not reflect the price at which the investment could be sold in the market, and the difference between carrying value and the ultimate sales price could be material. The valuation of such investments will be determined by the Fund Manager in accordance with procedures set forth in the Adviser’s Valuation Policy. The exercise of discretion in valuation by a Fund Manager presents conflicts of interest, including in connection with determining the amount and timing of distributions of carried interest and the calculation of management fees. Notwithstanding the valuation procedures set forth in the Fund Agreement, a Fund Manager may have an incentive to value such investments at a higher level in order to enhance performance reporting and to receive a higher management fee or other fees (if such management or other fees are based on the value of investments). Further, in connection with a Fund Manager's discretion in valuing certain assets, such Fund Manager maintains discretion to determine whether certain assets have experienced an impairment in value. A permanent impairment or write-off of an investment would generally reduce the basis from which the management fee or other fees are calculated. The Fund Manager therefore has an incentive to hold onto assets or other investments that have poor prospects for improvement and/or to avoid or otherwise delay determining that an investment has been subject to permanent write-off or impairment in order to receive ongoing management fees and/or other fees in the interim. Material Non-Public Information – Certain personnel of the Adviser and its affiliates expect, from time to time, to acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Funds will not be free to act on any such information. Thus, in certain cases, the Funds will be unable to initiate transactions that they otherwise might have initiated and will be unable to sell investments that they otherwise might have sold, which could harm a Fund. Despite the foregoing, the Adviser can determine, in its sole discretion at any time, that such information could impair its ability to effect certain transactions on behalf of a Fund, whether for legal, contractual, or other reasons. As a result, the Adviser can elect not to receive such information or to restrict access to such information to certain personnel that are placed behind an “information wall.” Lack of access to any such information could adversely affect a Fund’s investments that in some cases could have been avoided had the Fund or Adviser had such information. Use of Leverage – The Funds may be permitted to maintain leverage with one or more financial institutions. See discussion of “Borrowing and Leverage” in this Item 8 above. The Adviser may be 26 | P a g e

permitted elect, in its sole discretion, to utilize Fund-level borrowing, rather than calling capital from investors. Conflicts of interest could arise in that the use of Fund-level borrowing typically delays the need for investors to make contributions to a Fund, or results in short-term gains to a Fund, which generally enhances that Fund’s performance figures (particularly because internal rate of return calculations depend on the amount and timing of capital contributions). Such an effect generally benefits the marketing efforts of the Adviser and its affiliates and increases the likelihood that any hurdle or preferred return component in the Fund’s carried interest arrangements will be met. In other circumstances the use of Fund-level borrowing can increase the base of a Fund’s management fee calculation, such as during periods where management fees are based in whole or in part on an acquisition cost that includes a borrowing component. Subject to any limitations in the governing documents, this scenario might incentivize the Adviser to permanently fund the acquisition and ongoing capital needs of a Fund’s investments with the proceeds of borrowings rather than draw down capital contributions. Performance-Based Fees; Carried Interest – The existence of carried interest creates an incentive for the Adviser to make riskier or more speculative investments on behalf of a Fund than it might otherwise make in the absence of such performance-based compensation. The terms of the carried interest could incentivize the Adviser to make decisions regarding the timing and structure of realization transactions or financings (or re-financings) of investments that may not be in the best interests of investors. For gains attributable to the carried interest to qualify as long-term capital gain for U.S. federal income tax purposes, the holding period for the asset leading to such gains generally must exceed three years. For investors, gains on assets held for more than one year will generally qualify as long-term capital gain. Long-term capital gain recognized by non-corporate U.S. taxpayers is generally subject to U.S. federal income tax at preferential rates. These disparate holding period requirements could lead to conflicts of interest. The Adviser has an incentive to take actions intended to maximize the amount of gains from assets held for more than three years, even though investors will not necessarily derive any additional U.S. federal income tax benefit from the longer holding period. For example, the Adviser will have an incentive to (i) refrain from making investments expected to generate gains within three years, (ii) refrain from selling or engaging in other transactions for investments that would lead to capital gain if the investment has not been held for more than three years or (iii) structure follow-on investments in a manner intended to maximize the amount of gain attributable to a Fund’s existing interests in such investments. Such actions could reduce the amount realized from a Fund’s investments and adversely affect the amount and timing of distributions to a Fund’s investors. Additionally, the percentage of profits the Adviser is entitled to receive and the terms applicable to such carried interest distributions may be different between Funds. Because the opportunity to receive an amount of carried interest distributions is based on the success of investments made by a Fund, to the extent that the Fund’s carried interest percentage or terms differ from other Funds, the Adviser could be incentivized to dedicate increased resources and allocate more profitable or more attractive investment opportunities to such other Funds bearing higher carried interest percentages or other more favorable terms. Co-Investments – From time-to-time, the Adviser will, in its sole discretion, provide or commit to provide co-investment opportunities to one or more investors and/or other persons, in each case on terms to be determined by the Adviser in its sole discretion. Conflicts of interest can be expected to arise in the allocation of such co-investment opportunities. The allocation of co-investment opportunities, as determined by the Adviser in its sole discretion, may not be in the best interests of a Fund or any individual Fund investor. In exercising its sole discretion in connection with such coinvestment opportunities, the Adviser is permitted to consider some or all of a wide range of factors, 27 | P a g e

which include the likelihood that an investor may invest in a future fund sponsored by the Adviser or its affiliates. A co-investment by a non-Fund investor could give rise to certain risks not present in investments where a third-party is not involved, including the possibility that a third-party coinvestor may at any time have economic or business interests or goals that are inconsistent with those of the Fund, or may be in a position to take action contrary to the investment objectives of the Fund. In addition, the Fund may in certain circumstances be liable for actions of its third-party coinvestor. Broken Deal Expenses – In connection with pursuing investment opportunities to help the Fund’s investment strategy, the Adviser and Funds generally incur fees, costs and expenses in connection with prospective investments and other transactions that are not consummated, including, without limitation, all due diligence fees, costs and expenses, legal and accounting fees, costs and expenses related to tangible work product generated, fees, costs and expenses of lenders, investment banks and other financing sources in connection with arranging financing for such prospective investment or other transaction, deposits or draw-down payments forfeited in connection with it, reverse break-up fees or termination fees, expense reimbursement amounts or other amounts payable to the sellers, targets, advisors, service providers or other counterparties or third parties, related to such transaction, or other liabilities or obligations in respect of such unconsummated transactions or investment opportunities (including travel costs and ancillary expenses (which can include first or business class commercial airfare or private or charter airfare, incurred in connection with it)) (collectively, “Broken Deal Expenses”). Broken Deal Expenses are expected, from time to time, to be significant, and in such circumstances the Fund will incur substantial costs and expenses with no opportunity for a return. Further, in the case of certain Funds, to the extent a co-investor has not agreed to share Broken Deal Expenses with such Fund with respect to an unconsummated investment, the Fund will generally bear all of the broken deal expenses relating to that potential investment notwithstanding that such co-investors may have benefitted from the opportunity to review, investigate and otherwise assess that potential coinvestment. Gifts and Entertainment – Brokers, counterparties, service providers and other third parties with whom we do business occasionally provide gifts and entertainment to our principals and employees. From time to time, we expect to enter into business transactions and relationships on behalf of a client with the donors of such gifts and entertainment. Such gifts and entertainment create a conflict of interest in our selection and retention of these donors as service providers for clients. To address this conflict, we have adopted policies and procedures to: (1) monitor gifts and entertainment given and received by our principals and employees; and (2) limit the value of gifts and entertainment given and received. *** The foregoing list of conflicts of interest does not purport to be a complete enumeration or explanation of the conflicts of interest involved in an investment in a Fund.

Any investor that is referred to CAM will receive additional disclosure information which will include relevant details regarding material financial interests and compensation surrounding the utilization of these services. There is no requirement for the Adviser to recommend the services of CAM, nor are investors obligated to utilize CAM’s services in order to invest in the Peakline Partner Funds. The Adviser is governed by a Board of Directors, whose Directors overlap with the Board of Directors of Cresset Capital Management, LLC, which in turn owns and controls CAM. Because the overlapping Directors will govern both the Adviser and CAM, such overlapping Directors could have an incentive to favor one such investment adviser over the other. These overlapping Directors could also face competing obligations among each investment adviser from a time commitment and cost allocation perspective. To address these conflicts, the Adviser will monitor such competing interests and take any steps it deems appropriate to ensure that its clients and investors are ultimately treated fairly and equitably over time. Willis Stein & Partners Management III, L.P. The Adviser is affiliated, through common ownership, with Willis Stein & Partners Management III, L.P. (herein “Management III”), a Delaware limited partnership and general partner of several private equity funds. Investors in the Funds will not be offered private equity funds of Management III. The Adviser shares premises and employees with Management III, however, Management III has no other business dealings in connection with the Adviser’s investment advisory business or services provided to the Funds, and the Adviser has no reason to believe that this sharing with Management III creates a conflict of interest. All appropriate and necessary security policies and procedures are in place to ensure security of Fund information. Caretta Partners, LLC The Adviser is affiliated, through common ownership, with Caretta Partners, LLC (“Caretta”). Caretta is a private equity and venture capital firm specializing in early stage, growth equity, and buyout investments. The Adviser shares premises with Caretta, however, Caretta has no other business dealings in connection with the Adviser’s investment advisory business or services provided to the Funds, and the Adviser has no reason to believe that this sharing with Caretta creates a conflict of interest. All appropriate and necessary security policies and procedures are in place to ensure security of Fund information. While certain of the Adviser’s supervised persons 29 | P a g e

and Fund investors are currently invested in Caretta, which occurred prior to the establishment of the Funds, the Adviser does not currently offer any investment opportunities in or managed by Caretta. VennPoint Real Estate, LLC The Adviser is affiliated, through common ownership, with VennPoint Real Estate, LLC (“VennPoint”). VennPoint invests in real estate for local communities, focused on the development, redevelopment and acquisition of property. While certain supervised persons and Fund investors are currently invested in VennPoint, which occurred prior to the establishment of the Funds, the Adviser does not currently offer any investment opportunities in or managed by VennPoint. True Capital Insurance Services, LLC True Capital Insurance Services, LLC (“TCIS”), is an affiliated insurance brokerage company, licensed as such in AZ, CA, FL, TX, TN, and WA, offering life and disability insurance placed through various carriers. TCIS also provides consulting services related to minimizing risk and protecting assets through health, umbrella, and property and casualty insurance. Certain licensed agents are authorized to act on behalf of TCIS and may sell life and disability insurance placed through various carriers. These services may be offered to clients of CAM, an affiliate of the Adviser, who may also be investors in the Adviser’s Funds. The Adviser does not utilize any of TCIS’s services and there is no requirement that a TCIS agent recommend TCIS or its services to the Adviser, nor are any investors in the Adviser’s Funds obligated to utilize TCIS or any of its services. Additionally, the Adviser does not receive any compensation or fees from the activities of TCIS. While the Adviser endeavors at all times to put the interests of its clients/investors first, the affiliated relationship between TCIS and the Adviser inherently creates a conflict of interest as both entities are under common control. This conflict is disclosed to all clients/investors of the Adviser if offered any TCIS service. See “Cresset Asset Management, LLC” in this section above for further information. Cresset Trust Company, LLC The Adviser is affiliated, through common control, with Cresset Trust Company, LLC (“CTC”) (fka Meristem Trust Company, LLC). CTC received its Certificate of Authority to transact business as a South Dakota-chartered public trust company effective March 30, 2015. All account administration and trust company operations are performed in South Dakota through services agreements with South Dakota Trust Company, LLC, and SDTC Services, LLC. Through this affiliation, trust services can be offered to investors of the Adviser and the Adviser’s funds can be offered to CTC trust clients. Conflicts arise due to this affiliation where CTC is responsible for making investment decisions for an investor’s trust and where the potential for additional economic benefit exists when such decisions involve an affiliated fund of the Adviser. Accordingly, if CTC has a role in making investment decisions, it agrees that any decision will be made independent of any consideration relative to the economic impact of such investments. Further, all investment recommendations of trust accounts will be based solely on the best interests of the trust. As an SEC registered investment adviser to Funds, the Adviser does not utilize the trust services of CTC or receive any direct or indirect economic benefit due to this affiliation.

30 | P a g e

The Connable Office, a Cresset Company The Adviser is affiliated, through common control, with The Connable Office, Inc. (the “Connable Office”), a Michigan-based multi-family office and organized as a private trust company. Through this affiliation, the Connable Office’s trust services can be offered to investors of the Adviser and the Adviser’s funds can be offered to trust clients of the Connable Office. Conflicts arise due to this affiliation where the Connable Office is responsible for making investment decisions for an investor’s trust and where the potential for additional economic benefit exists when such decisions involve an affiliated fund of the Adviser. Accordingly, if the Connable Office has a role in making investment decisions, it agrees that any decision will be made independent of any consideration relative to the economic impact of such investments. Further, all investment recommendations of trust accounts will be based solely on the best interests of the trust. Monticello Associates, LLC The Adviser is affiliated, through common control, with Monticello Associates, LLC (“Monticello”), who is also a registered investment adviser with the SEC. Monticello offers asset management consulting services to its clients, which includes endowments, foundations, high net-worth families, and retirement plans. The Adviser may refer investors to utilize the advisory services of Monticello. Due to the affiliation, owners will benefit financially in their individual capacity if investors utilize the advisory services of Monticello. Any investor that is referred to Monticello will receive additional disclosure information which will include relevant details regarding material financial interests and compensation surrounding the utilization of these services. There is no requirement for the Adviser to recommend the services of Monticello, nor are investors obligated to utilize Monticello’s services in order to invest in the Peakline Partner Funds.

The Code covers a range of topics that address employee ethics and conflicts of interest, including insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. To request a copy of our Code, please contact us at (312) 429-2401 or via email at info@peakline.com. B.

Personal Trading with Material Interest

The Adviser allows Supervised Persons and personnel of affiliated entities as referenced in Item 10 (herein collectively as “Peakline Entities”) to purchase or sell the same securities that may be recommended to and/or purchased on behalf of its Clients or Fund Investors. The Adviser does not act as principal in any transactions. In addition, the Adviser itself does not act as the general partner 31 | P a g e

of a Fund or advise an investment company, though certain of its affiliate entities act in such capacity. The Adviser does not have a material interest in any securities traded in Client or Investor accounts. C.

Personal Trading in Same Securities as Clients

The Adviser allows Supervised Persons and personnel of Peakline Entities to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address and manage such conflicts. When trading for personal accounts, Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material nonpublic information. Supervised Persons may receive more favorable terms when investing alongside Clients in the same investment opportunities, such as reduced or waived fees and/or carried interest. This risk is mitigated by the Adviser conducting a coordinated review of personal accounts and the accounts of its Clients. We have also adopted written policies and procedures to detect the misuse of material, non-public information. Related Persons of the Adviser may invest alongside Client Funds in certain investment opportunities, and certain personnel or Related Persons may also have an interest in the allocation of investors among the Funds. These circumstances create conflicts of interest because the Adviser and its personnel may have material financial interests that could influence decisions regarding the allocation of investors to particular Funds or the allocation of investment opportunities among participating Funds and Related Persons. The Adviser has adopted policies and procedures governing allocation designed to identify, manage, and mitigate these conflicts, including policies governing the allocation of investors among the Funds and the allocation of investment opportunities. The Adviser allocates investors among the Funds will not give preferential treatment to Related Persons. Similarly, in the event an investment opportunity is oversubscribed, other investment vehicles of Related Persons will be excluded from participation to ensure that Client Funds receive priority. D.

Personal Trading at Same Time as Client

The Adviser allows Supervised Persons and personnel of Peakline Entities to purchase or sell the same securities that may be held by the Funds. In these instances, Supervised Persons trades are typically executed after trades in the Funds. At no time will the Adviser, or any Supervised Person of the Adviser, transact in any security to the detriment of any Client. *** The foregoing list of conflicts of interest does not purport to be a complete enumeration or explanation of the conflicts of interest involved in an investment in a Fund.

In placing each transaction for the Fund involving a Custodian, the Adviser will seek “best execution” of the transaction except to the extent it may be permitted to pay higher brokerage commissions in exchange for brokerage and research services. When seeking best execution, the main factor is not the lowest cost, but whether the transaction represents the overall best qualitative execution, taking into consideration the full range of a broker-dealer/custodian’s services, including among other things, execution capability, commission rates, responsiveness, and reputation of the Custodian. Following are additional details regarding the brokerage practices of the Adviser: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an investment adviser enters into an agreement to place security trades therewith in exchange for research and other services. The Adviser does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. 2. Brokerage Referrals – The Adviser does not receive compensation from any third party in connection with the selection of a Custodian. 3. Directed Brokerage – The Adviser has the sole discretion over the purchase and sale of investments (including the size of such transactions) and the Custodian, if any, to be used to effect transactions. B.

Aggregating and Allocating Trades

As each of the Funds has different underlying investments, there is generally not an opportunity to aggregate orders among the Funds. To the extent that more than one investment opportunity is suitable for multiple Funds, the Adviser will seek to allocate the opportunity in a manner that is fair and equitable to each eligible Fund in accordance with the Offering Documents of such Funds and in accordance with its Allocation Policy. Additionally, in instances in which a Fund's investment opportunity is oversubscribed, the Adviser will allocate the investment opportunity among investors in such Fund in accordance with its Allocation Policy and the applicable Offering Documents. The Adviser’s Allocation Policy prioritizes entities that have entered into most-favored-nations arrangements with the Adviser and takes into account factors including, but not limited to, the size of the investment, risk management considerations, and the tax, legal, contractual and/or regulatory burdens applicable to an investor, as well as the nature and scope of the relationship between the Adviser and the investor.

Investors are encouraged to notify the Adviser if changes occur in their personal financial situation that might impact the appropriateness of investing in a Fund.

The Adviser may use promoters to refer investors, and may compensate such promoters for those services. In using promoters, the Adviser must comply with Advisers Act Rule 206(4)-1 and any related state securities requirements. Except for employees and certain affiliated persons of the Adviser, in accordance with exemptions under the rule, the promoter must disclose certain aspects of its relationship with the Adviser if receiving compensation greater than the de minimis amount.

Copies of the annual audited financial statements, which are prepared in accordance with generally accepted accounting principles, are distributed to all investors within the following time frames of the end of the fiscal year of the Fund: 120 days for funds, 180 days for fund of funds, and 260 days for fund of funds of funds. Investors should carefully review statements received from thirdparty custodians and should compare the audited annual financial statements received from a Fund against the account statements received from the qualified custodian.