Dellora Investments LP: investment adviser

investment vehicles, one or more separately managed account clients (“SMAs”) and may serve as investment adviser and/or sub-adviser to various other advisory clients, including SMAs and other private investment funds (each a “Client”, collectively, “Clients”). The investments of the Funds are managed in accordance with their investment objectives, strategies and guidelines applicable to the Fund and are not tailored to any particular Investor in the Fund (an “Investor”). Dellora does not provide individualized investment advice to such Investors with respect to their investment in the Fund; therefore, Investors should consider whether the Fund meets their investment objectives, risk tolerance and financial situation.

The investments of the SMA will be managed pursuant to the terms of a separate Investment Management Agreement with the SMA (the “SMA Agreement”). As the Client’s agent with respect to the SMA, Dellora, when it deems appropriate and without prior consultation with Client, may: (a) buy, sell, exchange, convert and otherwise invest or trade in any stocks, bonds, options, units and other securities, including money market instruments at such times and in such manner as Dellora determines.

Please see Item 5 – Fees and Compensation for more information. Wrap Fee Programs

Dellora does not participate in wrap fee programs.

Type and Value of Assets Currently Managed

As of February 1, 2026, Dellora manages approximately $148.4M on a discretionary basis and $0 on a non-discretionary basis.

Incentive allocations for the Long Only Fund are subject to an outperformance amount with respect to each incentive allocation period. Dellora complies with Rule 205-3 under the Investment Advisers Act of 1940, to the extent required by applicable law. Dellora deducts management fees, performance allocations and fees directly from client accounts but may bill a client for such amounts on request. Fees with respect to the SMA

Fees are negotiable, but generally, Dellora will charge an annual fee of 1.5% (0.375% per quarter) of the account balance. Dellora is also entitled to receive an annual incentive fee equal to the incentive allocation percentage multiplied by the applicable income. The incentive allocation percentage is 15%. The applicable income is the positive amount equal to the balance of the account minus the high watermark.

A limited partner may generally withdraw all or any portion of the balance in its capital account as of the last day of the calendar quarter immediately following the twelve-month period after the date that the capital account was established and the last day of each calendar quarter thereafter. Requests for withdrawal must be in writing at least sixty (60) calendar days prior to the request withdrawal date.

In the case of an SMA Client, except as may be otherwise negotiated in particular cases, the holder of an individually managed account may terminate the account by giving 30 days’ prior written notice after the lock-up period of eight (8) full calendar quarters.

The capital account of an investor admitted to the Funds other than on the first calendar day of a calendar quarter will be subject to a pro rata portion of the management fee charged for such quarter based upon the portion of the quarter for which it is an investor. No portion of the management fee will be refunded if an investor is permitted to withdraw on a date other than the end of a calendar quarter.

Each account is responsible for its own costs and expenses related to investments and operations, including trading costs and expenses (such as brokerage commissions, expenses related to short sales, and clearing and settlement charges), and research related expenses. Each Fund is responsible for its own ongoing legal and regulatory filings, administrative, valuation, auditing and accounting, entity-level taxes, insurance, and, bookkeeping fees and

expenses, and the fees and expenses charged by any fund administrator for its accounting, bookkeeping and other services. Dellora bears its own operating, general, administrative and overhead costs and expenses, other than the expenses described above. All or part of these costs and expenses may be paid, however, by securities brokerage firms and futures commission merchants that execute clients’ securities trades, as discussed in Item 12 – Brokerage Practices below. Dellora and its supervised persons do not receive a brokerage commission or any other compensation attributable to the sale of securities or investment products.

Minimum account sizes for separate other Client accounts vary depending on the type of investment advisory services to be performed and in certain circumstances may be negotiable. Separate Client account investment advisory services are generally available to individuals and institutional accounts with a minimum account at the discretion of the Investment Manager.

However, each prospective Investor should carefully review the applicable offering and other governing documents before deciding to invest in a Fund.

General Economic Conditions. The success of the Funds activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in law, tax considerations and tax treatment, trade barriers, currency exchange controls and national and international political circumstances (including wars, terrorist acts and security operations). These factors may affect the level and volatility of the prices and liquidity of the Funds and could impair the Funds’ profitability or result in losses. Dellora may consider some or all of these factors when making trading decisions. The Funds could incur material losses even if Dellora reacts quickly to difficult market conditions, and there can be no assurance that the Funds will not suffer material losses and other adverse effects from broad and rapid changes in market conditions in the future. Even a well-analyzed approach may not protect the Funds from significant losses under certain market conditions.

Business and Regulatory Risks of Alternative Investment Funds. The financial services industry generally, and the activities of alternative investment funds and their managers in particular, have been subject to intense and increasing regulatory scrutiny. Such scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance and other related costs. Increased regulatory oversight may also impose additional administrative burdens on the General Partners and/or the Adviser, including, without limitation, responding to examinations, investigations, and document requests, implementing new policies and procedures and complying with recordkeeping and reporting obligations. Such burdens may divert such parties' time, attention and resources from portfolio management activities. The regulatory environment for alternative investment funds is evolving, and changes in the regulation of private funds and their investing activities may adversely affect the ability of the Funds to pursue its investment program, the value of the investments held by the Funds and the Funds’ ability to obtain leverage. There has been an increase in governmental, as well as self-regulatory, scrutiny of the alternative investment industry in general. It is impossible to predict whether changes in regulations may occur, but any regulations that restrict the Funds’ activities could have a material adverse effect on the Funds’ investments. In addition,

such regulatory scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance and other related costs.

Catastrophic Risks. The Funds may be subject to the risk of loss arising from direct or indirect exposure to a number of types of other catastrophic events, including without limitation (i) public health crises, including any outbreak of COVID-19 (and its variants), SARS, H1N1/09 influenza, Zika, avian influenza, other coronaviruses, Ebola or other existing or new epidemic diseases, or the threat or fear thereof; or (ii) major events or disruptions, such as hurricanes, earthquakes, tornadoes, fires, flooding and other natural disasters (which may be caused, or enhanced in frequency and severity, by climate change factors); acts of war, military conflicts, social or political unrest or terrorism, including cyberterrorism; or major or prolonged power outages or network interruptions. Such events could exacerbate political, social and economic risks previously mentioned and result in significant breakdowns, delays and other disruptions on a local, regional and global scale, which may have adverse effects on the operating performance of the Funds and its portfolio companies. The extent of the impact of any such catastrophe or other emergency on the Funds’ and its portfolio companies' operational and financial performance will depend on many factors, including the duration and scope of such emergency, the extent of any related travel advisories and restrictions, the impact on overall supply and demand for goods and services, investor liquidity, consumer confidence and levels of economic activity, and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. In particular, to the extent that any such event occurs and has a material effect on global financial markets or specific markets in which the Funds participates (or has a material effect on any Fund portfolio companies or locations in which such portfolio companies or the Investment Manager operates or on any of their respective personnel), the risks of loss could be substantial and could have a material adverse effect on the Funds or the ability of Dellora to fulfill its investment objectives.

Market Disruption and Geopolitical Risk. Military conflicts (including those involving Iran and Ukraine) can cause (and have caused) significant disruptions to the global financial system as well as a displacement of millions of people, causing an acute refugee crisis. Conflicts such as these increase the threat of nuclear accidents or attacks, cyberattacks and further regional or global conflicts (including a potential expansion of the conflicts to other countries), among other potentially dire consequences. Armed conflicts, military strikes, retaliatory actions, or political instability in key regions may cause significant market volatility, disruptions to global trade, and commodity price spikes. With respect to the Iranian conflict, In February – March 2026, the United States and Israel launched major military operations in Iran, followed by Iranian retaliatory strikes across the Middle East. These events resulted in volatility across global equity markets as energy prices moved higher in response to supply concerns. With respect to the Russia-Ukraine conflict, in response to Russia’s actions, multiple countries and governing bodies, including the United States, the United Kingdom and the European Union (“EU”), have put in place global sanctions and other severe restrictions or prohibitions on the activities of certain individuals and businesses connected to Russia and/or Belarus. In addition, the impacts of military conflicts on the supply chain and commodity prices can be profound and may result in substantial inflation in one or more countries (or globally). However, the ultimate impact of the conflicts and their effects on global economic and commercial activity and conditions, and on the

operations, financial condition and performance of the Funds, their investments or any particular industry, business, currency or country and the duration and severity of those effects, is impossible to predict. Global geopolitical events may have a significant adverse impact on, and result in significant losses to, the Funds and their investments, which could result in a partial or total loss of investment for investors.

Cybersecurity Breaches and Identity Theft. The information and technology systems of the General Partners, the Adviser, their affiliates, the Funds and their service providers and their portfolio companies may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons, other security breaches and/or usage errors by their respective professionals. The techniques used to obtain unauthorized access to data, disable or degrade service or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Although the General Partners, the Adviser and/or their affiliates have implemented, or expect to implement, measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the General Partners, the Investment Adviser, their affiliates, one or more of the Funds, their service providers and/or their portfolio companies may have to make a significant investment to fix or replace them. The failure of these systems for any reason could cause significant interruptions in such parties' operations and/or a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to investors (and the beneficial owners of investors). Such a failure could harm the reputation of the General Partners, the Adviser, their affiliates, the Funds and/or their portfolio companies, subject any such entity and their respective affiliates to legal claims and/or otherwise affect their business and financial performance. Specifically, cyberattacks and the failure of such systems may interfere with the processing of investor subscriptions or withdrawals, impact the Funds’ ability to value its assets, cause the release of confidential information and/or subject the Funds to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. The Funds also may incur substantial costs for cyber-security risk management to prevent any cyber incidents in the future. The Funds and the investors could be negatively impacted as a result. Business Continuity and Disaster Recovery. The business operations of the General Partners, the Adviser, their affiliates, the Funds and their portfolio companies may be vulnerable to disruption in the case of catastrophic events such as fires, natural disaster (e.g., tornadoes, floods, hurricanes and earthquakes), terrorist attacks or other circumstances resulting in property damage, network interruption and/or prolonged power outages. Although the General Partners, the Adviser and/or their affiliates have implemented, or expect to implement, measures to manage risks relating to these types of events, there can be no assurances that all contingencies can be planned for. These risks of loss can be substantial and could have a material adverse effect on the Funds and the investors’ investments therein.

General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If the Adviser’s evaluation of an investment opportunity should prove incorrect, the Funds could experience losses as a result

of a decline in the market value of securities in which the Funds holds a long position. The risk management techniques that may be used by the Adviser do not provide any assurance that the Funds will not be exposed to a risk of significant investment losses. No guarantee or representation is made that the Funds’ investment programs will be successful, that the Fund will achieve its targeted returns or that there will be any return of capital to investors. In addition, investment results may vary substantially over time.

Equity Securities. The Funds may invest in equity and equity-related securities, including, without limitation, equity investments acquired in connection with restructured debt securities or instruments, or in connection with reorganizations and/or restructurings of debt securities, equity securities or other obligations and assets of undervalued, operationally challenged and/or financially troubled companies or institutions. A risk of investing in the Funds is that equity securities held by the Funds may decline in value. Equity securities fluctuate in value in response to many factors, including the activities and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates, general economic environments and/or certain geo-political events. In addition, equity securities that the Adviser believes are undervalued or incorrectly valued may not ultimately be valued by the markets in the manner that the Adviser anticipates. Biotechnology and Pharmaceutical Sectors. Investing in securities and other instruments of biotechnology and pharmaceutical companies involves substantial risks, including (but not limited to) the following: certain companies in the portfolio of the Funds may have limited operating histories, scarcity of management and marketing personnel with appropriate scientific or medical training may result in slow or impeded growth of a company, the possibility of lawsuits related to patents or products, obsolescence of products, change in government policies, changes in investor sentiments and preferences with regard to biotechnology and pharmaceutical sectors investments (some of which are generally perceived as risky), volatility in the U.S. stock markets that affects the prices of healthcare company securities resulting in substantial volatility in the performance of the Funds and the fact that many companies in the biotechnology and pharmaceutical sectors are subject to extensive government regulation.

Short Sales. The Adviser may engage in short selling on behalf of the Funds. Short selling involves selling securities that are not owned by the Funds. A short position is established when the Funds borrow securities from securities brokers or other institutions and sells them in an open market transaction with an obligation to return the borrowed securities at a later date. Short selling allows the Funds to profit from the decline in the price of the securities by purchasing the securities at a price that is lower than the price at which they were initially sold, in each case, to the extent such decline exceeds the transaction costs and cost of borrowing the securities. In addition, the short sales may act as a hedge against long positions in the same or related securities in the Funds’ portfolios in the event that the price of the securities decline. Foreign Securities. The Funds may invest in securities of foreign companies, governments and government agencies. Investing in such securities, which are generally denominated in foreign currencies, and the use of forward foreign currency exchange contracts, involves

unusual risk not typically associated with investing in securities issued by U.S. companies or by the U.S. government or its agencies or instrumentalities. Investing in emerging markets poses greater risks and a greater potential for returns than investing in developed countries. Securities of companies in these emerging markets are generally more volatile and may be much more volatile than securities issued by companies located in developed countries. The Funds may be affected favorably or unfavorably by exchange control regulations or changes in the exchange rate between such currencies and the U.S. dollar. Moreover, individual foreign economies may compare unfavorably with the U.S. economy in growth of gross national product, rate of inflation, rate of savings and capital reinvestment, resource selfsufficiency, balance-of-payment positions and in other respects. Some of the countries in which the Funds may invest have laws and regulations that currently preclude or severely restrict direct foreign investment in securities of their companies. Securities of some foreign companies are less liquid and their prices are more volatile than securities of comparable U.S. companies. Investing in foreign securities creates a greater risk of securities clearance and settlement problems. Further, some of the securities in which the Funds may invest may be thinly traded and relatively illiquid or may cease to be traded after the Funds invest in them. In addition to being illiquid, such securities may be issued by unseasoned companies and may be highly speculative. In addition, the Funds occasionally may acquire relatively large positions in a few securities. In such cases, and in the event of extreme market activity, the Funds may not be able to liquidate investments promptly, if the need should arise, which could materially and adversely affect the results of such investments. Concentration of Investments; Limited Diversification and Sector Investing. The Funds may hold a limited number of positions at any given time and the Funds may hold relatively large positions in few securities. As a result of the Funds’ possible lack of diversification, a significant loss in any one position may have a material adverse effect on the net asset value of the Funds’ rate of return. Likewise, any fluctuation in the overall value of securities in the biotechnology and pharmaceutical sectors in which the Adviser expects to invest likely will have a material effect on the performance of the Funds.

Use of Leverage. The Funds may employ leverage in connection with its investment strategies and/or for any other purpose deemed necessary, desirable or appropriate at such times, in such amounts and subject to such terms and conditions as the General Partners and/or the Adviser may determine in its sole and absolute discretion. Such leverage may take a variety of forms, including, but not limited to, margin borrowing from securities brokers and dealers, loans, repurchase agreements, derivative instruments that are inherently leveraged, and other financing arrangements, as determined by the General Partners in their sole and absolute discretion. The use of leverage increases both the possibility for gain and the risk of loss. Leverage employed by the Funds may be secured by the securities holdings and other assets of the Funds, as applicable. Under certain circumstances, a lender may demand an increase in the collateral that secures such obligations, and if the Funds are unable to provide additional collateral, the lender could liquidate assets held in the account to satisfy such obligations. In addition, the amount of the Funds’ borrowing and the interest rates on that borrowing, both of which will fluctuate, may have an effect on the Funds’ profitability. Additionally, leverage typically will cause the Funds’ net asset values to increase or decrease at a greater rate than if leverage were not used. In addition, the use of leverage may cause a U.S. tax-exempt investor to realize UBTI.

Options. The Funds may engage in the trading of options when appropriate. Specific market movements of the securities underlying an option cannot accurately be predicted. The purchaser of an option is subject to the risk of losing the entire purchase price of the option. The writer of an option is subject to the risk of loss resulting from the difference between the premium received for the option and the price of the security underlying the option which the writer must purchase or deliver upon exercise of the option.

Company Capitalization. The Funds may invest in securities of companies with various capitalizations where such companies meet the investment criteria described herein. While such companies may provide significant potential for appreciation, such investments, particularly small-capitalization securities, involve higher risks in some respects than do investments in securities of larger companies. The prices of small capitalization and even medium-capitalization and mid-capitalization securities are often more volatile than prices of large capitalization securities and the risk of bankruptcy or insolvency of many smaller companies (with the attendant losses to long investors) is higher than for larger, "blue-chip" companies. In addition, due to thin trading in some small-, mid- and medium-capitalization securities, an investment in those securities may be illiquid. The small-, mid- and mediumcapitalization securities may, at times, significantly underperform the large capitalization securities and may do so in the future. A related concern for short sale risk is that smaller companies tend to be more readily acquired. The foregoing risks are just some of the most significant risks that may apply to an investment in the Fund. Investing in any securities involves a significant risk of loss of both income and principal that Investors should be prepared to bear. Investment safety and satisfactory performance is in no way guaranteed.

Dellora’s employees, affiliates or their related persons may also invest directly in the Fund or another fund managed in the future by Dellora. In addition, if Dellora manages multiple funds, it may have conflicts of interest in allocating time and resources to such other funds. As a result of the foregoing, Dellora and its personnel may have conflicts of interest in allocating their time and activity between clients, in allocating investments among funds and other entities, and in effecting transactions between funds and other entities, including ones in which Dellora or its personnel may have a greater financial interest. To address these potential conflicts of interests in its material relationships, Dellora has adopted policies and procedures, including a Code of Ethics (the “Code”). Under the Code, in general, all Dellora personnel, including directors, officers, and employees of Dellora, must put the interests of Dellora’s clients first and must act honestly and fairly in all respects in dealings with clients. For a more detailed discussion of the Code and conflicts of interest policies, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.

Next, the Code sets forth guidelines for professional standards for Dellora’s associated persons (managers, officers and employees). Under the Code’s professional standards, Dellora expects its associated persons to put the interests of its clients first, ahead of personal interests. In this regard, Dellora associated persons are not to take inappropriate advantage of their positions in relation to Dellora’s clients. Third, the Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. Dellora’s associated persons may not invest in the same securities or the same sector recommended to the Funds. Any proposed employee transaction involving reportable transactions including making an investment in a private placement, requires pre-clearance. It is Dellora’s policy that if a conflict arises, the instance will be resolved in the favor of the Client to the full extent that is possible given the specific circumstances, and that appropriate measures will be taken to document the issue, add new policies and procedures when relevant, and enforce the matter with all employees of Dellora. These policies are designed to discourage and prohibit personal trading that would disadvantage clients, including the Funds. The Code also provides for disciplinary action as appropriate for violations.

Recommending, or Buying or Selling for Client Accounts, Securities in which Dellora or its Related Persons Have Material Financial Interests

Dellora does not act as principal in any transactions. Dellora has adopted a personal trading policy and procedures to protect against these material conflicts. No employee of Dellora is permitted to transact in any security to the detriment of any Client or Investor.

Recommending or Buying or Selling for Client Accounts, Securities at or about the Same Time Dellora or its Related Persons Buy or Sell the Same Securities for Their Own Accounts. Dellora and its related persons do not enter into securities transactions with Clients. Employees are encouraged to invest side by side with Clients and in Dellora’s strategy by investing in its Fund.

Under the Code, Dellora’s associated persons are prohibited from trading in securities on the basis of material, non-public information or communicating material, non-public information about the issuer of any security to any other person.

The General Partner As disclosed above, Kevin Pyun, the principal owner of Dellora, is also the Manager of Dellora Investments Fund GP LLC and Dellora Long Only Fund GP LLC, the General Partners of the Funds. Please see Item 10 – Other Financial Industry Activities and Affiliates for more information on the conflicts of interests presented when Dellora recommends an investment in the Fund.

Therefore, Dellora may use brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination) and may be used in servicing any or all of Dellora’s clients. Therefore, research services received may not be used for the account for which the particular transaction was effected. Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision‐making process. Dellora will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning

of Section 28(e). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment manager and a broker‐dealer and other relevant parties such as custodians); trading software operated by a broker‐dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the Securities and Exchange Commission or a self‐regulatory organization such as comparison services, electronic confirms or trade affirmations.

In some instances, Dellora may receive a product or service that may be used only partially for functions within Section 28(e) (e.g., an order management system, trade analytical software or proxy services). In such instances, Dellora will make a good faith effort to determine the relative proportion of the product or service used to assist Dellora in carrying out its investment decision making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting Dellora in carrying out its investment decision‐making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Dellora from its own resources. Research and brokerage services obtained by the use of commissions arising from the client's portfolio transactions may be used by Dellora in its other investment activities and thus, a client may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided.

Because many of those services could benefit Dellora, it may have a conflict of interest in allocating client brokerage business. In other words, Dellora could have an incentive to execute client transactions through a broker or dealer that provides valuable services or products and pay transaction commissions charged by that broker or dealer which may be higher than Dellora might otherwise be able to negotiate. Dellora could also have an incentive to cause clients to engage in more securities transactions than would otherwise be optimal in order to generate soft dollars with which to acquire research products and services.

Although Dellora will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. The receipt of such products or services and the determination of

the appropriate allocation in the case of “mixed use” products or services creates a potential conflict of interest between Dellora and its clients. Dellora does not currently use soft dollars but may use soft dollars in the future.

In selecting brokers and negotiating commission rates, Dellora will take into account the financial stability and reputation of brokerage firms, and the research, brokerage or other services provided by such brokers. Dellora may place transactions with a broker or dealer that refers potential Investors to the Funds advised by Dellora (or an affiliate), if otherwise consistent with seeking best execution; provided Dellora is not selecting the broker‐dealer in recognition of the referral of potential Investors. When appropriate, Dellora may, but is not required to, aggregate client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will generally be allocated securities based on the average price achieved for such trades. More specifically, each client that participates in an aggregated order will participate at the average share price for all of Dellora’s transactions in that security or other instrument on a given business day and transaction costs will be shared pro rata based on each client's participation in the transaction. No client will be favored over any other client as a result of such aggregation. Brokerage commission rates will not be reduced because of such aggregation. In some instances, average pricing may result in higher or lower execution prices then otherwise obtainable by a single client. Dellora believes that its aggregation policy is lawful and consistent with its duty to seek best execution for all its clients. During the last fiscal year, Dellora directed Client transactions to particular brokers based on each broker’s reputation, financial strength and stability, efficiency of execution and error resolution, the size of the transactions and the market for the security, and the comprehensiveness and frequency of available research services and products provided by the broker.

Dellora’s authority may be subject to conditions imposed by a client, examples of which may include: (i) where the client restricts or prohibits transactions in a certain industry, issuer or security and/or (ii) where the client directs that some or all account transactions be effected through specific brokers or dealers. In the latter case, the client is responsible for negotiating the terms and conditions (including, but not limited to, commission rates) relating to all services to be provided by such brokers. Dellora will assume no responsibility for obtaining the best prices or any particular commission rates for transactions with or through any such broker for such client’s account. A client must recognize that it may not obtain rates as low as it might otherwise obtain if Dellora had discretion to select brokers or dealers other than those chosen by the client. Any client providing instructions to Dellora regarding direction of brokerage transactions must notify Dellora in writing if the client desires Dellora to cease executing transactions with or through any such broker or dealer. Dellora is independently owned and operated and is not affiliated with any broker-dealer.

Jefferies LLC (the “Prime Broker”) is the current Prime Broker for Dellora.

Any compensation paid to such placement agents that Dellora may engage, will not impact the fees paid by investors in the Funds. Neither Dellora nor any of its related persons directly or indirectly compensate any person for referrals to the Fund.

Dellora (through the General Partners) is deemed to have custody of certain assets of the Funds. Dellora is required to maintain the funds and securities (except for securities that meet the privately offered securities exemption in the Custody Rule) over which it has custody with a qualified custodian. Qualified custodians include banks, brokers, futures commission merchants and certain foreign financial institutions. The Custody Rule imposes on advisers with custody of clients’ funds or securities certain requirements concerning reports to such clients (including underlying investors) and

surprise examinations relating to such clients’ funds or securities. However, an adviser need not comply with such requirements with respect to pooled investment vehicles subject to audit and delivery if each pooled investment vehicle (i) is audited at least annually by an independent public accountant and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to their investors, all limited partners, members or other beneficial owners within 120 days (180 days in the applicable case of a fund of fund adviser) of its fiscal year-end. Dellora relies upon this audit exception with respect to the Fund.

As described in Item 4 - Advisory Business, Dellora also provides SMA clients advice on a discretionary basis. For discretionary accounts, Dellora is appointed by the SMA Client, giving Dellora the authority to carry out various activities in the account, generally including the following: (i) trade execution and (ii) the withdrawal of advisory fees directly from the account. Dellora then directs investment of the client’s portfolio using its discretionary authority. The client may limit the terms to the extent consistent with the client’s investment advisory agreement with Dellora and the requirements of the client’s custodian.

If a material conflict of interest over proxy voting arises between Dellora and a Client, Dellora will vote all proxies in accordance with the policy described above. If Dellora determines that this policy does not adequately address the conflict of interest, Dellora will notify the Client

of the conflict and request that the Client consent to Dellora’s intended response to the proxy solicitation. If the Client consents to Dellora’s intended response or fails to respond to the notice within a reasonable time specified in the notice, Dellora will vote the proxy as described in the notice. If the Client objects in writing to Dellora’s intended response, Dellora will vote the proxy as the Client directs. A Client can obtain a copy of Dellora’s proxy voting policy and a record of votes cast by Dellora on behalf of that Client by contacting Dellora at 203-632-6341 or by sending an email to DelloraIR@dellora.com.