Albion River: investment adviser

Albion retains broad flexibility to invest on behalf of the Funds in accordance with the investment objectives, strategies and guidelines specified in each Fund’s limited partnership agreement, limited liability company operating agreement and/or private placement memoranda, as applicable (collectively, the “Offering Documents”). Albion does not tailor its investment advice to match the needs of any specific investor in any Fund (each such individual an “Investor,” and, collectively, the “Investors”). As of December 31, 2025, Albion manages approximately $2,062,000,000 (calculated based on regulatory assets under management) on a discretionary basis on behalf of the Funds.

Albion will generally offset the management fees paid by a Fund in the amount of consulting fees, commitment fees, monitoring fees, director’s fees, break-up fees, success fees or other renumeration (whether in the form of cash, securities or otherwise and net of any reimbursement of transaction or other out-of-pocket expenses) paid to Albion (or its affiliates or subsidiaries (including, without limitation, the Principal, but excluding any persons retained by Albion as operating executives)) for services rendered by such persons in their respective capacities and to the extent related to the investment activities of the Fund. If amounts to be applied to reduce the management fees in any period exceed the management fees payable for such period, such excess will be applied to reduce the management fees payable in the next period and each succeeding period thereafter until the full amount has been applied to offset the management fee. Any such offsets will be conducted in the manner described in the applicable Fund’s Offering Documents. Please refer to Item 6 below for a discussion of potential “performance-based fees” Albion may earn. Generally, fees for advisory services are negotiable. The Adviser may waive or modify the management fees and other “performance-based fees” for Investors that are members, employees or affiliates of the Adviser, relatives of such persons, and for any other Investors, in its sole discretion. Organizational Expenses The Funds will bear, directly or through reimbursement of the Adviser (or its affiliates), all of the costs and all out-of-pocket expenses associated with the organization of the Fund and the syndication of interests therein, including, without limitation, offering, legal, compliance, accounting, travel, consulting and filing expenses.(collectively, “Organizational Expenses”). All Organizational Expenses paid or reimbursed by

any Fund in excess of such Fund’s pro rata share of the cap on Organizational Expenses may result in an offset against the management fee, as further described in the respective Fund’s Offering Documents. Partnership Expenses Each Fund will generally pay all expenses attributable such Fund’s activities and investments (“Partnership Expenses”), including, but not limited to: (i) Organizational Expenses; (ii) legal, accounting, audit, financial administration (including third-party administrators) custodial and other professional fees as well as consulting fees relating to services rendered to such Fund; (iii) banking, brokerage, broken-deal, registration, qualification, finders, depositary and similar fees or commissions; (iv) fees, due diligence costs and other costs, expenses and liabilities incurred in identifying, evaluating, acquiring, holding, valuing, restructuring and disposing of portfolio investments, including all fees and expenses of legal counsel and financial advisers incurred in connection therewith, all fees, costs and expenses for research and subscription services incurred in connection therewith, all travel costs and other transaction-related expenses; (v) transfer, capital and other taxes, duties and costs incurred in acquiring, holding, selling or otherwise disposing of Partnership assets; (vi) the fees and expenses of retaining any third party to manage, service or collect any portion of such Fund’s assets or assets held by the Adviser’s affiliates (including the applicable general partner) for the benefit of the Fund; (vii) insurance premiums, indemnifications, costs of litigation (whether actual, threatened or otherwise anticipated), costs of mediation or other dispute resolution processes and other extraordinary expenses; (viii) costs of financial statements and other reports to the Investors (including, expenses associated with the preparation or distribution of Partnership-related or investment-related financial statements, tax returns, tax estimates, Schedule K-1s, investor information portals or websites through which such reports are distributed) as well as costs of all governmental returns, reports and other filings, including Form PF; (ix) costs of meetings of the Investors (including the reasonable travel and other out-of-pocket costs incurred by the Adviser and its affiliates in attending such meetings); (x) costs of the advisory board (if applicable); (xi) interest expenses; (xii) financing and borrowing costs; (xiii) advertising and public notice costs; (xiv) costs with respect to the dissolution, winding up, or termination of such Fund; (xv) the Management Fee; (xvi) placement agent fees (provided that any placement agent fees will either (A) reduce, on a dollar for dollar basis, the Management Fee otherwise payable to the Adviser or its affiliates, or (B) be paid by the Adviser or its affiliates and not charged as an expense); and (xvii) any other expenses not listed in the preceding clauses (i) through (xvi) that are not normal operating expenses of the Adviser and/or its affiliates. Except as set forth above, the Adviser and its affiliates (including, without limitation, the general partners of the Funds) are responsible for their own day-to-day operating expenses, such as compensation of their staff and the cost of office space, office equipment, communications, utilities and other normal overhead expenses. In all cases, details concerning applicable fees and expenses will be set forth in each respective Client’s Offering Documents.

assets well. The nature of such compensation, however, creates a potential conflict of interest among the Adviser (and its affiliates), its associated persons, and its Clients. Specifically, such performance-based compensation may create an incentive for Albion to cause a Client to make investments that are riskier and more speculative than it would otherwise make. Further, because Albion may at some point have multiple Clients, at times it may need to allocate investment opportunities of limited availability across its Funds. In such situations, some accounts may offer higher management fees and/or performance-based compensation potential than others. In those instances, Albion may have an incentive to favor accounts for which it receives higher performance-based compensation since it will receive a greater profit if the investment generates a positive return. To ensure equitable treatment of all Clients irrespective of such fee considerations, Albion has adopted an investment allocation policy that sets out the criteria for determining allocations, the most important of which are investment objective and strategy, existing portfolio composition and available liquidity. Albion will seek to address any conflicts through careful vetting of investment opportunities by its investment professionals and disclosure of investments to limited partners through capital call notices and periodic reports. Additionally, the Principal and certain investment professionals of Albion will often invest in the Clients, both directly and indirectly (e.g., through general partner commitments or direct investments as limited partners), which is intended to align the interests of Albion and those of the Clients. Albion’s performance-based compensation is charged in compliance with Rule 205-3 under the Advisers Act. Detailed information regarding the carried interest borne by Investors in the Funds will be contained in the applicable Fund’s Offering Documents. Potential investors should not consider an investment in any Fund without fully understanding the Fund’s compensation structure.

Accordingly, future Investors may include high net worth individuals and a variety of institutional investors (e.g., trusts, employee benefit plans, endowments, foundations, corporations, and other types of entities, including private funds of funds) meeting the terms of the exceptions and exemptions under which the Funds operate. In addition, employees and other persons associated with Albion and/or its affiliates may be Investors in the Funds. The Adviser and/or its affiliates retain absolute discretion to admit or deny any potential Investor in any of the Funds. Once an Investor has invested in a Fund, it generally will not be able to pledge, assign, sell, exchange, or transfer its interest (or any portion thereof) in the Fund, and no assignee, purchaser or transferee may be admitted as a substitute investor, except with the consent of Albion, which consent may be given or withheld in its sole and absolute discretion. Albion expects each Fund to qualify for exclusion from the definition of “investment company” under the Company Act pursuant to either Section 3(c)(1) or Section 3(c)(7) thereunder, and to offer interests to potential investors pursuant to Regulation D or Regulation S under the Securities Act. This Brochure is designed solely to provide information about Albion and should not be considered to be an offer of interests in any Fund or any future Client. Any such offer may be made only by delivery to the prospective investor of the applicable Offering Documents. Investors considering an

investment in any Fund should consult with their own investment, tax and/or legal consultants prior to investing.

Detailed information regarding the investment strategies of the Fund is contained in the applicable Offering Documents. Investors should not consider an investment in any Fund without fully understanding the Fund’s investment strategy. Each Fund’s strategy involves a number of material risks, including, but not limited to: the lack of a liquid public market for investments and therefore a restricted ability to sell positions; the severe restriction on the ability of Investors in the Fund to withdraw their capital; and the ability of Albion and its investment professionals to correctly identify and assess good investment opportunities, particularly given the often early stage of development of the businesses invested in, their frequent need for additional capital and the often rapidly shifting dynamics and intense competition that characterize the industries in which they operate. Additional material risks likely applicable to Albion’s investment strategy (and securities the Funds invest in) include, but are not limited to, the following (capitalized terms not defined herein shall have the meanings ascribed to them in the Fund’s Offering Documents): RISK OF LOSS. An investment in the Fund is speculative and involves significant risk. The profitability of the Fund depends on the Investment Manager correctly assessing the future price movements of the securities, commodities and other financial instruments in which the Fund invests and the movement of interest rates. These price movements may be volatile and are subject to numerous factors which are neither within the control of nor predictable by the Investment Manager. Such factors include, without limitation, a wide range of economic, political, competitive, market, legal, operational and other conditions or events (including, without limitation, natural disasters, acts of terrorism or war) which may affect investments in general or a specific security, commodity or other financial instrument in which the Fund invests. There can be no assurance that the Investment Manager will be successful in accurately predicting price movements. Accordingly, Limited Partners may incur substantial losses on their investments in the Fund, and it is possible that the Fund’s performance will fluctuate substantially from period to period. COMPETITION. The securities industry, the various markets in which the Investment Manager participates and the varied strategies and techniques engaged in by the Investment Manager are extremely competitive and each involves a high degree of risk. The Fund and the Investment Manager compete with firms, including, without limitation, many of the larger securities and investment banking firms, which have substantially greater financial resources and larger research staffs and more traders than the Investment Manager, which may place the Fund at a competitive disadvantage. MARKET VOLATILITY. The profitability of the Fund depends upon the Investment Manager correctly assessing the future price movements of stocks, bonds, options on stocks, other securities, currencies, regulated futures contracts and other commodities and the movements of interest rates. There can be no

assurance that the Investment Manager will be successful in accurately predicting price and interest rate movements. UNCERTAIN ECONOMIC, SOCIAL AND POLITICAL ENVIRONMENT. Consumer, corporate and financial confidence may be adversely affected by current or future tensions around the world, fear of terrorist activity and/or military conflicts, localized or global financial, public health or other crises or other sources of political, social or economic unrest. Such erosion of confidence may lead to or extend a localized or global economic downturn. Further, the outcomes of U.S. elections create uncertainty with respect to legal, tax and regulatory regimes in which the Fund, the General Partner, the Investment Manager and their affiliates may operate. A climate of uncertainty may reduce the availability of potential investment opportunities and increase the difficulty of modeling market conditions, potentially reducing the accuracy of financial projections. Any significant changes in, among other things, economic policy (including with respect to interest rates and foreign trade), the regulation of the asset management industry, tax law, immigration policy and/or government entitlement programs could have a material adverse impact on the Fund and its investments. In addition, limited availability of credit for consumers, homeowners and businesses, including credit used to acquire businesses, in an uncertain environment or economic downturn may have an adverse effect on the economy generally and on the ability of the Fund to execute its strategy. This may slow the rate of future investments by the Fund and result in longer holding periods for investments. For example, Russia’s large-scale invasion of Ukraine on February 24, 2022 has led to various countries, including the United States, imposing economic sanctions on certain Russian individuals and Russian corporate and banking entities. A number of jurisdictions have also instituted broader sanctions on Russia, including banning Russia from global payments systems that facilitate cross-border payments. The sanctions are broad and will likely cause declines in the value and liquidity of Russian securities, downgrades in the credit ratings of Russian securities, devaluation of Russia’s currency, and increased market volatility and disruption in Russia and throughout the world, including in the United States. Sanctions and similar measures, such as banning Russia from financial transaction systems that facilitate international transfers of funds, could limit or prevent the Fund from selling and buying impacted securities both in Russia and in other markets. Such measures will likely cause significant delay in the settlement of impacted securities transactions or prevent settlement altogether. The lack of available market prices for such securities may cause the Fund to use fair value procedures to value certain securities. The consequences of the war and sanctions may negatively impact other regional and global economic markets in which the Fund participates. Additionally, Russia may take counter measures or engage in retaliatory actions—including cyberattacks and espionage—which could further disrupt global markets and supply chains, adversely impacting the Fund’s operations. Companies in other countries that do business with Russia and the global commodities market for oil and natural gas, especially, will likely feel the impact of the sanctions. These sanctions, together with the potential for a wider armed or cyber conflict, could increase financial market volatility globally, including in the United States, and, as a result, negatively impact the Fund’s performance beyond any direct exposure to Russian issuers or securities. GOVERNMENT ECONOMIC INTERVENTIONS. In response to turmoil in the financial markets beginning in 2020 following the COVID-19 pandemic, the U.S. Government, Federal Reserve, U.S. Treasury and other governmental and regulatory bodies have taken a number of actions designed to stabilize the financial markets, including the enactment of the Families First Coronavirus Response Act and the Coronavirus Aid, Relief and Economic Security Act, both of which are sweeping stimulus bills intended to bolster the U.S. economy and provide emergency assistance to qualifying businesses and individuals. There can be no assurance that, in the long term, these actions will improve the efficiency and stability of U.S. financial markets. To the extent the financial markets do not respond favorably to any of these actions or such actions do not function as intended, the Fund’s financial performance may be harmed. In addition, because the programs are designed, in part, to improve the markets for certain of the Fund’s target assets, the establishment of these programs may result in increased competition for attractive opportunities in the Fund’s target assets or, in the case of government-backed refinancing and modification programs, may have

the effect of reducing the revenues associated with certain of the Fund’s target assets. Such policy changes may expose fixed-income and related markets to heightened volatility and may reduce liquidity for certain Fund investments, which could cause the value of the Fund’s investments and net asset value to decline. If the Fund invests in derivatives tied to fixed income markets, it may be more substantially exposed to these risks than a fund that does not invest in derivatives. The U.S. Government, the Federal Reserve, the U.S. Treasury and other governmental and regulatory bodies may take additional actions in the future to address the financial crisis and stimulate the economic recovery. The Investment Manager cannot predict whether or when such actions may occur, and such actions could have an adverse effect on the Fund’s business, results of operations and financial condition. LIQUIDITY. Many of the investments that are made by the Fund will lack liquidity. Accordingly, the Fund’s ability to respond to market movements may be impaired and the Fund may experience adverse price movements upon liquidation of its investments. Furthermore, the Investment Manager may invest in securities, commodity futures or other financial instruments that are thinly traded. This could present a problem in realizing the prices quoted and in effectively trading the position(s). In many situations, the Investment Manager may invest in illiquid investments which could result in significant loss in value should the Investment Manager be forced to sell the illiquid investments as a result of rapidly changing market conditions or as a result of margin calls or other factors. ACCURACY OF PUBLIC INFORMATION. The Investment Manager selects investments for the Fund, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Investment Manager by the issuers or through sources other than the issuers. Although the Investment Manager evaluates all such information and data and ordinarily seek independent corroboration when the Investment Manager considers it is appropriate and reasonably available, the Investment Manager is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. INVESTMENTS IN UNDERVALUED SECURITIES. The Investment Manager may seek to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Fund’s investments may not adequately compensate for the business and financial risks assumed. The Fund will make certain speculative investments in securities which it believes to be undervalued, however, there are no assurances that the securities purchased will in fact be undervalued. In addition, the Fund may be required to hold such securities for a substantial period of time before realizing their anticipated value. During this period, a portion of the Fund’s assets would be committed to the securities purchased, thus possibly preventing the Fund from investing in other opportunities. PREFERRED AND HYBRID SECURITIES RISKS. The Fund may invest in preferred stock and hybrid securities, which may have special risks. Preferred and hybrid securities may include provisions that permit the issuer, at its discretion, to defer distributions for a stated period without any adverse consequences to the issuer. If the Fund owns a preferred or hybrid security that is deferring its distributions, the Fund may be required to report income for tax purposes even though it has not yet received such income. Some preferred and hybrid securities are non-cumulative, meaning that the dividends do not accumulate and need not ever be paid. There is no assurance that dividends or distributions on non-cumulative preferred securities in which the Fund invests will be declared or otherwise made payable or paid. Preferred and hybrid securities are subordinated to bonds and other debt instruments in an issuer’s capital structure in terms of priority to corporate income and liquidation payments and, therefore, will be subject to greater credit risk than more senior debt instruments. Because preferred stock and hybrids are generally junior to debt securities and other obligations of the issuer, deterioration in the credit quality of the issuer will cause

greater changes in the value of such instruments than senior debt securities with similarly stated yield characteristics. Preferred and hybrid securities may be substantially less liquid than many other securities, such as common stocks or U.S. government securities. OPTIONS. The Investment Manager may utilize options in furtherance of their investment strategies. Option positions may include both long positions, where the Investment Manager is the holder of put or call options, as well as short positions, where the Investment Manager is the seller (writer) of an option. Although option techniques can increase investment return, they can also involve a higher level of risk compared with their underlying securities. For example, the expiration of unexercised long options effectively results in loss of the entire cost, or premium paid for the option. Conversely, the writing of an uncovered put or call option can involve, similar to short selling, a theoretically unlimited risk of an increase in the Fund’s cost of selling or purchasing the underlying securities, commodities or other financial instruments in the event of exercise of the option. FIXED INCOME SECURITIES. The Fund may invest in bonds or other fixed income securities, including, without limitation, commercial paper, municipal bonds and “higher yielding” (including non-investment grade and therefore, higher risk) debt securities. The Fund will therefore be subject to credit, liquidity and interest rate risks. Higher-yielding debt securities are generally unsecured and may be subordinated to certain other outstanding securities and obligations of the issuer, which may be secured on substantially all of the issuer’s assets. The lower rating of debt obligations in the higher-yielding sector reflects a greater probability that adverse changes in the financial condition of the issuer or in general economic conditions or both may impair the ability of the issuer to make payments of principal and interest. Non-investment grade debt securities may not be protected by financial covenants or limitations on additional indebtedness. In addition, evaluating credit risk for debt securities involves uncertainty. Also, the market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. It is likely that a major economic recession could disrupt severely the market for such securities and may have an adverse impact on the value of such securities. In addition, it is likely that any such economic downturn could adversely affect the ability of the issuers of such securities to repay principal and pay interest thereon and increase the incidence of default for such securities. LEVERAGE. The Investment Manager may employ leverage, including, without limitation, through the use of borrowed funds and investments in options, such as puts and calls, regulated futures contracts, warrants and credit default swaps. Also, they may engage in short sales. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. If the Investment Manager uses leverage with respect to a position, any losses would be more pronounced than if leverage were not used, and a relatively small price movement in a security or other financial instrument may result in immediate and substantial losses to the Fund. The level of interest rates generally, and the rates at which such funds may be borrowed in particular, could affect the operating results of the Fund. DERIVATIVE INSTRUMENTS. The Investment Manager may invest Fund capital with or through third parties through swaps, total return swaps and other derivative instruments. The Investment Manager may take advantage of opportunities with respect to certain other derivative instruments that are not presently contemplated for use or that are currently not available, but that may be developed, to the extent such opportunities are both consistent with their investment objectives and legally permissible. Special risks may apply to instruments that are invested in by the Fund in the future that cannot be determined at this time or until such instruments are developed or invested in by the Fund. Certain swaps, total return swaps and other derivative instruments may be subject to various types of risks, including, without limitation, market risk, liquidity risk, the risk of non-performance by the counterparty, including, without limitation, risks relating to the financial soundness and creditworthiness of the counterparty, legal risk and operations risk.

SHORT SALES. The Investment Manager may sell securities short. Selling securities short risks losing an amount greater than the proceeds received. Theoretically, securities sold short are subject to unlimited risk of loss because there is no limit on the price that a security may appreciate before the short position is closed. In addition, the supply of securities that can be borrowed fluctuates from time to time. The Investment Manager may be subject to losses if a security lender demands return of the lent securities and an alternative lending source cannot be found or if the Investment Manager is otherwise unable to borrow securities which are necessary to cover their positions. CONCENTRATION OF HOLDINGS. At any given time, the Fund’s assets may become highly concentrated within a particular company, industry, asset category, trading style or financial or economic market. In such event, the Fund’s portfolio will be more susceptible to fluctuations in value resulting from adverse economic conditions affecting the performance of that particular company, industry, asset category, trading style or financial or economic market, than a less concentrated portfolio would be. As a result, if the Fund’s investment portfolio becomes concentrated, its aggregate return may be volatile and may be affected substantially by the performance of only one or a few holdings. The Investment Manager is not obligated to hedge its positions. FAILURE OF BROKERAGE FIRMS. U.S.-registered broker dealers which may carry the accounts of the Fund generally segregate all customer funds to be allocated to listed securities trading in compliance with SEC and FINRA regulations. If such assets were not so segregated, the Fund would be subject to the risk of the failure of the broker. Even given proper segregation, in the event of the insolvency of the broker, the Fund may be subject to a risk of loss of its funds and may be able to recover only a pro rata share (together with all other securities customers of such broker) of assets, such as U.S. Treasury bills, specifically traceable to the Fund’s account. In broker insolvencies, customers have, in fact, been unable to recover from the broker’s estate the full amount of their “customer” funds. In addition, under certain circumstances, such as the inability of another client of the broker or the broker itself to satisfy substantial deficiencies in such other client’s account, a customer (including the Fund) may be subject to a risk of loss of its funds on deposit with a broker dealer, even if such funds are properly segregated. In the case of any such bankruptcy or loss, the Fund might recover, even in respect of property specifically traceable to it, only a pro rata share of all property available for distribution to all of the broker’s clients. The Fund may trade with or hold accounts at foreign broker dealers registered under the laws and regulations of other countries. Such brokers and/or dealers may not be subject to the same or similar customer fund regulations (including, without limitation, customer segregation requirements) as those existing in the United States. The financial failure of the parties with which the Fund trades in the over-the-counter (“OTC”) markets could also result in substantial losses, as the Fund will deal with such persons as principal and there is no requirement that such parties segregate counterparty funds held by them in respect of such trading. Further, the Fund is subject to additional risks where it is a party to a securities lending arrangement and the counterparty to the arrangement becomes insolvent and/or defaults on its obligations, including, without limitation, the risk that collateral will not be returned and/or repurchased or the Fund will not be permitted to exercise its remedies in accordance with the provisions of the relevant securities lending agreement. ELECTRONIC TRADING FACILITIES. The Fund in its trading activities, may, at the discretion of the Investment Manager, make use of electronic trading and/or communication networks. Most electronic trading facilities are supported by computer- (including internet) based component systems for the orderrouting, execution, matching, registration or clearing of trades. As with all facilities and systems, they are vulnerable to temporary disruption or failure. Trading on an electronic trading system may differ not only from trading in an open-outcry market or telephonic market but also from trading on other electronic trading systems. The Fund, in undertaking transactions on an electronic trading system, will be exposed to risk associated with the system, including the failure of hardware and software. The result of any system failure may be that a trade order is either not executed according to its instructions or is not executed at all. The Fund’s ability to limit or recover certain losses may be subject to limits on liability imposed by, without

limitation, foreign or domestic law or regulation, the Fund’s own or its brokers’ internet service provider, other systems providers, market factors, foreign or domestic banking or other market regulations, and/or telephonic or other communications providers. SYSTEMIC RISK. World events and/or the activities of one or more large participants in the financial markets and/or other events or activities of others could result in a temporary systemic breakdown in the normal operation of financial markets. Such events could result in the Investment Manager losing substantial value caused predominantly by liquidity and counterparty issues (as noted above), which could result in the Fund incurring substantial losses. NON-U.S. INVESTMENTS; EMERGING MARKET RISK. The Investment Manager may invest all or a portion of its assets in non-U.S. securities and interests denominated in non-U.S. currencies and/or traded outside of the United States, including, without limitation, emerging market securities and interests. Such investments require consideration of certain risks not typically associated with investing in securities traded in the United States or other assets. Such risks include, among other things, unfavorable currency exchange rate developments, restrictions on repatriation of investment income and capital, imposition of exchange control regulation, confiscatory taxation, and economic or political instability in foreign nations. In addition, there may be less publicly available information about certain non-U.S. companies than would be the case for comparable companies in the United States, and certain non-U.S. companies may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those of U.S. companies. MARKET DISLOCATION AND ILLIQUIDITY. Recent events in the sub-prime mortgage market and other areas of the fixed income markets in the United States have caused significant dislocations, illiquidity and volatility in the structured credit, leveraged loan and high-yield bond markets. These events have had repercussions on the global financial markets, including, without limitation, the markets in which the Fund trades and invests, by restricting the availability of credit generally, and reducing liquidity levels across virtually all markets globally. The foregoing events could lead to an overall weakening of the U.S. and global economies. Any resulting economic downturn could adversely affect the Fund’s investments. Such marketplace events also may restrict the ability of the Fund to sell or liquidate investments at favorable times and/or for favorable prices and/or cause the Fund to have limited access to credit. The Fund may be adversely affected by a decrease in market liquidity (e.g., by impairing the Fund’s ability to adjust their positions and risk in response to trading losses or other adverse developments). The size of the Fund’s positions may magnify the effect of a decrease in market liquidity for the instruments traded. Changes in the overall market leverage (e.g., deleveraging or liquidations by other market participants of the same or similar positions) also may adversely affect the Fund’s positions. INFLATION RISK. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Fund purchases a 5-year bond in which it can realize a coupon rate of five percent (5%), but the rate of inflation is six percent (6%), then the purchasing power of the cash flow has declined. For all but inflation linked bonds, adjustable bonds or floating rate bonds, the Fund is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security. To the extent that interest rates reflect the expected inflation rate, floating rate bonds have a lower level of inflation risk. CURRENCY RISK. The Fund may make investments which will be denominated in one or more currencies other than U.S. Dollars and as a result, may be exposed to currency exchange risk. Changes in exchange rates between currencies or the conversion from one currency to another may cause the value of a Fund’s investments to diminish or increase. Currency exchange rates may fluctuate over short periods of time and are generally determined by supply and demand in the currency exchange markets and the relative merits of investments in different countries, actual or perceived changes in interest rates and other complex factors.

Currency exchange rates can be affected unpredictably by intervention (or the failure to intervene) by governments or central banks, or by currency controls or political developments. Furthermore, the Fund may incur costs in connection with conversions between various currencies. Currency exchange dealers realize a profit based on the difference between the prices at which they are buying and selling various currencies. Thus, a dealer normally will offer to sell currency to the Fund at one rate, while offering a lesser rate of exchange should the Fund desire immediately to resell that currency to the dealer. The General Partner does not expect to hedge the Fund’s exposure to currency fluctuations. GENERAL ECONOMIC CONDITIONS. The success of any investment activity is affected by general economic conditions, which include the level and volatility of interest rates, credit spreads and equity valuations and the extent and timing of investor participation in the markets for both equities and interestsensitive instruments. Unexpected volatility or illiquidity in the markets in which the Fund holds positions could cause the Fund to incur losses. SYSTEMS RISK AND CYBERSECURITY. The Investment Manager relies extensively on computer programs and systems (and may rely on new systems and technology in the future) for various purposes, including trading, clearing and settling transactions, evaluating investments, monitoring portfolios and generating risk management and other reports. Certain of the Investment Manager’s operations are dependent on systems operated by third parties, including prime brokers, administrators, market counterparties and their subcustodians and service providers. Notwithstanding the diligence that the Investment Manager may perform on such service providers, the Investment Manager may not be in a position to verify the risks or reliability of such information technology systems. CHANGES IN U.S. GOVERNMENT DEFENSE SPENDING. The Fund may make investments in entities where U.S. government sales constitute a significant portion of their consolidated sales. Such revenues largely result from contracts awarder under various U.S. government programs, primarily defense-related programs with the U.S. Department of Defense, and a broad range of programs with the U.S. intelligence community and other departments and agencies. U.S. government defense spending may fluctuate for various reasons, including as a result of potential changes in policy or budgetary positions or priorities, U.S. domestic and broader geopolitical events, macroeconomic conditions, and the ability of the U.S. government to enact relevant legislation, such as appropriations bills. Any such changes could negatively affect the operations, financial conditions, and liquidity of the Fund’s investments, and thus the performance of the Fund. PORTFOLIO COMPANY RISKS. Smaller companies often experience unexpected problems in the areas of product development, manufacturing, marketing, financing, and general management, which, in some cases, cannot be adequately solved. In addition, such companies may require substantial amounts of financing which may not be available through institutional private placements or the public markets. The percentage of companies that survive and prosper can be small. Investments in more mature companies in the expansion or profitable stage may also involve substantial risks. Such companies typically have obtained capital in the form of debt and/or equity to expand rapidly, reorganize operations, acquire other businesses, or develop new products and markets. These activities by definition involve a significant amount of change in a company and could give rise to significant problems in sales, manufacturing, and general management of these activities. To the extent that any Investment is made in a Portfolio Company with a leveraged capital structure or any Portfolio Company borrows or enters into other financing transactions requiring periodic payments, such investment will be subject to increased exposure to adverse economic factors such as a significant rise in interest rates, a severe downturn in the economy or deterioration in the condition of such company or its industry. If such a company is unable to generate sufficient cash flow to meet principal and interest payments on its indebtedness, the value of any equity investment by the Fund in such company could be significantly reduced or even eliminated. In addition, the success of any venture is dependent upon the availability of high quality personnel. Competition for qualified personnel at any stage of development can be intense. Turnover of personnel can seriously disrupt a Portfolio Company’s business plan. Similarly,

the ability of a Portfolio Company’s personnel to accept and make the transitions that occur as the company matures is difficult to predict or manage. No assurance can be given that the Portfolio Companies will be able to attract and retain the qualified personnel necessary for success. LIMITED OPERATING HISTORY OF PORTFOLIO COMPANIES. Portfolio Companies could have limited operating histories by which to assess their ability to achieve, sustain and increase revenues or profitability. A Portfolio Company’s financial results will be affected by many factors, including: (i) the ability to successfully identify a market or markets in which there is a need for its products; (ii) the ability to successfully negotiate strategic alliances, licensing and other relationships for product development, marketing, distribution and sales; (iii) the progress of research and development programs with respect to the development of additional products and enhancements to existing products; (iv) the ability to protect proprietary rights; and (v) competing technological and market developments, particularly companies that have substantially greater resources. There can be no assurance that the Portfolio Companies will be able to achieve and maintain cost efficient operations or that any of their products or services will achieve a significant level of market acceptance. The development and commercialization of their products or services will require additional development, sales and marketing and other significant expenditures. The required level and timing of such expenditures will impact their ability to achieve profitability and positive cash flows from operations at the levels projected, or at all. There can be no assurance that the Portfolio Companies will ever achieve significant commercial revenues or profitability. RISKS ASSOCIATED WITH MANAGEMENT OF GROWTH. To achieve their projected revenues and other targeted operating results, the Portfolio Companies may be required to rapidly implement and improve operational, financial and management control systems on a timely basis, together with maintaining effective cost controls, and any failure to do so would have a material adverse effect on their business, financial condition and results of operations. The success of their growth plans will depend in part upon their ability to continue to attract, retain and motivate key personnel. Failure to make the required expansions and upgrades could have a material adverse effect on their business, financial condition, results of operations and relationships with their corporate partners. The results of operations for the companies will also be adversely affected if revenues do not increase sufficiently to compensate for the increase in operating expenses resulting from any expansion and there can be no assurance that any expansion will be profitable or will not adversely affect their results of operations. RELIANCE ON PORTFOLIO COMPANY MANAGEMENT. The day-to-day operations of each Portfolio Company will be the responsibility of its own management team. Although the Manager will monitor the performance of the Fund’s Investments and will screen for and, if necessary, recruit capable management, there can be no assurance that such management will be able to operate any such Portfolio Company in accordance with the Fund’s expectations. In addition, the loss to a Portfolio Company of a member of its management team could be detrimental to the development of the Portfolio Company. DEPENDENCE ON UNPROVEN TECHNOLOGIES AND PRODUCTS. The Portfolio Companies’ business plans may depend in part upon the successful completion of technologies and or products or identification of one or more markets which require the Portfolio Companies’ respective technologies or products. Following this, any success will then depend on the successful development and deployment of the products and technologies which may not work, or may not be economically viable. MARKET UNCERTAINTIES. Even if the Portfolio Companies’ product development efforts are successful, their ultimate success will depend upon market acceptance of the concepts and the products. The Portfolio Companies may have not engaged in any formal market research studies with respect to the establishment of a market for their products. No assurance can be given that the market they establish will be sufficient for operations to achieve profitability in the near future or that there is even a market for their products. There also can be no assurance that performance errors and deficiencies will not be found, or if found, that

they will be able to successfully correct such performance errors and deficiencies in a timely manner or at all. Even if the concepts gain initial market acceptance, competitors are likely to introduce concepts with comparable price and performance characteristics. This competition may result in reduced future market acceptance for their products and decreasing sales and lower gross margins which could have a material adverse effect on the business, financial condition and results of operations of the Fund and the Portfolio Companies. CONCENTRATION IN INDUSTRIES WITH RELIANCE ON GOVERNMENT CONTRACTS. Portfolio Companies are expected to be concentrated within industries that have material reliance on government contracts. Such contracts are typically subject to competitive bidding and there can be no assurances that a Portfolio Company will be awarded new contracts or have re-existing contracts renewed. The failure to be awarded new contracts or have contracts pre-existing contracts renewed may have a materially negative impact on the impacted Portfolio Company’s operations. In addition, the availability of government contracts may be subject to political prerogatives. There can be no assurances on how future administrations prioritize funding or the effects thereof on Portfolio Companies. SUSTAINABILITY RISKS. Portfolio Companies may be exposed to “sustainability risks,” including environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the Portfolio Companies. The Manager, the Fund, the Portfolio Companies, and other parties, such as service providers or Portfolio Company counterparties, may be negatively affected by sustainability risks. If appropriate for an Investment, sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the Investment may be undertaken; however, there can be no assurance that all such risks will be mitigated in whole or in part, nor identified prior to the date the risk materializes. The Fund and the Portfolio Companies may maintain or bear the cost of insurance to protect against certain sustainability risks, where available on reasonable commercial terms, although such insurance, if maintained, would be expected to be subject to customary deductibles, exclusions and coverage limits and may not be sufficient to recoup all losses and may not be maintained. Sustainability risks may therefore adversely affect the performance of the Fund and its Investments. ENVIRONMENTAL MATTERS. Real property is subject to U.S. federal and state environmental laws, regulations, and administrative rulings which, among other things, establish standards for the treatment, storage and disposal of solid and hazardous waste. Real property owners are subject to U.S. federal and state environmental laws which impose joint and several liability on past and present owners and users of real property for hazardous substance remediation and removal costs. These laws often impose such liability without regard to whether the owner knew of, or was responsible for, the presence of such hazardous or toxic substances. In addition, the Fund’s potential liability as to any property owned by a Portfolio Company is generally not limited under such laws and regulations and could exceed the value of the property and/or the aggregate assets of the owner. The presence of such substances, or the failure to remediate such substances properly, may also adversely affect the owner’s ability to sell or lease the property or to borrow using the property as collateral. The Fund also may be liable for environmental contamination of properties that are sold or for the release of hazardous or toxic substances from such properties. Some laws and regulations impose liability for the release of certain materials into the air or water from a property, including asbestos, and such release can form the basis for liability to third persons for personal injury or other damages. Other laws and regulations can limit the development of, and impose liability for, the disturbance of wetlands or the habitats of threatened or endangered species. It is possible that future environmental laws, ordinances or regulations or new interpretations of existing environmental laws, ordinances or regulations will impose material environmental liabilities on the Fund due to its Investment in certain Portfolio Companies. In addition, some environmental laws create a lien on the contaminated site in favor of the government for damages and costs it incurs in connection with the contamination. The costs of defending any future environmental claims, performing any future environmental remediation,

management or removal, satisfying any such environmental liabilities or responding to any changed environmental conditions could materially adversely affect the Fund’s financial condition, results of operations, cash flow and the ability to make distributions to Members. NO ASSURANCE OF ADDITIONAL CAPITAL FOR INVESTMENTS. Even if a Portfolio Company is successful generating revenues, it may require additional financing to continue product development, testing and, ultimately, manufacturing, marketing and other operational activities. Moreover, its cash requirements may vary materially due to research and development results, product testing results, changing relationships with strategic partners, changes in the focus and direction of its research and development programs, competitive and technological advances of competitors, and other factors. Additional financing may not be available when needed or on acceptable terms. If additional financing is not available, the Portfolio Company may need to delay, scale back or eliminate certain of its product development, marketing or other activities, or even be forced to cease operations and liquidate. FOLLOW-ON INVESTMENTS. Following the Fund’s Initial Investment and any Follow-On Investments in a Portfolio Company, the Fund may have opportunities to make additional subsequent investments in that Portfolio Company. The Fund may lack sufficient funds, or otherwise decide not, to make those investments. The failure to make subsequent investments could jeopardize the Portfolio Company’s viability and the Fund’s prior investments, or may result in a missed opportunity for the Fund to increase its participation in a successful operation. RISKS FROM THE PROVISION OF MANAGERIAL ASSISTANCE. The Fund may designate directors to serve on the boards of directors of the Portfolio Companies. A board member designated by the Fund will likely owe fiduciary duties to persons other than the Fund. The designation of directors and other measures contemplated could expose the assets of the Fund to claims by a Portfolio Company, its security holders and its creditors for breaches of fiduciary duties, securities claims and other director-related claims. The exercise of control over a Portfolio Company may impose additional risks of liability for environmental damage, product or manufacturing defects, failure to supervise management, violation of governmental regulations and other types of liability for which the limited liability generally characteristic of business ownership may be ignored. If these liabilities were to occur, the Fund could suffer losses in its Investments. In addition, the Fund may also participate in Portfolio Company financings at valuations lower than the valuations in preceding rounds of financing. Disputes arising out of such down-round financings may result in the Fund being named as a defendant in litigation. Typically, Portfolio Companies will have insurance to protect directors and officers, but this insurance may be inadequate. The Fund will also indemnify the Manager and its owners, among others, for liabilities incurred in connection with operations of the Fund, including liabilities arising from such lawsuits. Such indemnification obligations and other liabilities could be substantial. While the Manager intends to manage the Fund in a way that will minimize exposure to these risks, the possibility of successful claims cannot be precluded. DIVIDEND POLICY. The Portfolio Companies are not expected to have a plan to repurchase their securities or to pay dividends to stockholders such as the Fund. There is no plan to pay dividends and the intent of the Fund is to reinvest cash flow in compounding growth.

As a result of the foregoing, the Adviser, certain affiliated entities serving as general partners to the Funds, the Principal and their respective affiliates (the “Affiliated Parties”) may have conflicts of interests in allocating their time and activity between the Funds and other accounts, in allocating investments among the Funds and other accounts, and in effecting transactions for the Funds and other accounts, including ones in which the Affiliated Parties may have a greater financial interests. The Adviser and its affiliates will strive to act in a manner that it considers fair, reasonable and equitable in allocating its time and investment opportunities among the Funds and the other accounts.

Submitted reports are reviewed by the CCO or his delegate. Violations of the Code are punishable by sanctions including fines and termination of employment. Albion, its partners, and/or its employees could give advice and take action for their own accounts or the Funds that differs from advice given, and action actually taken on behalf of the Funds. In addition, Albion partners and/or employees could invest in third-party private investment funds that invest in some of the same securities Albion invests in on behalf of the Funds. Further, from time to time, Albion, its affiliates, their employees, and/or their partners could have an investment position or interest in the same securities recommended to or owned by Albion. As such, Albion could purchase or sell for the Funds securities of an issuer in which Albion, its affiliates, their employees, and/or their partners also have an investment position or interest. Albion has established procedures within the Code and a personal trading policy, intended to limit conflicts of interest in cases where Albion, a related person or any employee, buys, sells or otherwise has an interest in securities recommended by Albion to its Funds. Albion, its partners, and/or its employees may come into possession of material non-public or other confidential information which, if disclosed, might affect an investor’s decision to buy, sell, or hold a security. Under applicable law, Albion, its partners, and its employees are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other third party. Accordingly, should Albion, its partners, and/or its employees come into possession of material non-public or other confidential information with respect to any company, they will generally be prohibited from communicating such information to, or using such information for the benefit of, the Clients. Albion has adopted a policy on insider trading in accordance with Section 204A under the Advisers Act, which

establishes procedures to prevent the misuse of material non-public information by Albion, its partners, and its employees. For additional information about the Code or to request a copy, please contact our CCO at (571) 321-5328 or mark.schneiderman@albionriver.com.

As a result, although Albion generally will seek reasonable rates for such services, the market for such services involves more subjective evaluations than public securities brokerage transactions, and the Funds may not pay the lowest commission or fee for such services. Albion will seek to obtain best execution for all transactions in public securities. To the extent purchase and sale orders can be aggregated, Albion will try to aggregate such orders as it deems appropriate and in accordance with the applicable Fund’s Offering Documents and in the best interests of such Fund. To the extent applicable, though unlikely, Albion will have the discretion to direct some brokerage business to brokers who refer Investors to its Funds. Because such referrals, if any, are likely to benefit Albion (but will provide an insignificant (if any) benefit to the Client), Albion will have a conflict of interest with its Clients when allocating brokerage business to a broker who has made such referrals. To prevent brokerage commissions from being used to pay referral fees, Albion will not allocate brokerage business to a referring broker unless it has been determined in good faith that the commissions payable to such broker are reasonable in relation to those available from non-referring brokers offering services of substantially equal value to the Client Account. Currently, Albion has no formal soft dollar arrangements in place. Albion may, in its discretion, deem it to be in the best interests of its Funds to reallocate or “cross” securities transactions between Funds. Albion maintains policies and procedures intended to limit the potential conflicts of interest inherent in these transactions. Cross transactions will only be effected if they are deemed to be in the best interests of the particular Clients involved and will be conducted in compliance with such policies and procedures and applicable law.

To comply with Rule 206(4)-2 (the “Custody Rule”) of the Advisers Act, Albion will strive to provide annual audit reports to Investors within 120 days following each Fund’s fiscal year end.

Albion (or its affiliates) may offer certain Investors, upon verbal request or through written side letter agreements, additional information and reporting that other Investors may not receive, and such information may affect an Investor’s decision to request a withdrawal, to the extent permitted by the Funds, or transfer of its interests. Albion’s CCO, as relevant, will internally review the information provided to Investors in order to detect and prevent potential concerns with respect to information flow, such as a combination of enhanced transparency and liquidity that could benefit particular Investors to the detriment of other Investors.

To comply with these requirements, Albion will ensure that funds and securities of the Funds (except certain privately offered securities) are maintained in custodial accounts with “qualified custodians.” To further comply with custody requirements, Albion will require (1) the appointment of an independent public accounting firm that is registered with the Public Company Accounting Oversight Board to conduct an annual audit of the Funds’ financial statements; (2) distribution of the audited financial statements within 120 days of the fiscal year-end to each Investor in the Funds; and (3) upon liquidation of the Funds, the performance of a liquidation audit and distribution of the related financial statements to Investors promptly upon completion of such audit. Any securities not custodied at a qualified custodian will be held pursuant to the privately offered securities exception of the Custody Rule. Investors should carefully review the audited financial statements of the Funds upon receipt and should compare these statements to any account information provided by Albion. Management personnel will be available to assist in reviewing and understanding any such reports.

While the general partners and/or managers of the Funds are ultimately be responsible for the management, policies and operation of the Funds, they grant authority to Albion to make investment recommendations and monitor investments, as more fully described in the investment advisory agreements executed between such entities and the Funds at the outset of the advisory relationships. In all cases, however, this discretion is to be exercised in a manner consistent with the investment strategies and objectives of the Funds, as detailed in the applicable Offering Documents. When making investment recommendations, Albion observes the investment policies, limitations and restrictions that are applicable to the Funds.