Twin Lions Management: investment adviser

The General Partner has ultimate responsibility for decisions relating to management and operations made on behalf of the Fund and has ultimate responsibility for the investment decisions made on behalf of the Fund but has delegated certain responsibilities to Twin Lions. In addition to advising the Fund, Twin Lions also provides investment advice to Twin Lions SPV II LP and Cassini Partners, L.P. – Twin Lions Management LLC Series. Twin Lions GP LLC is the general partner of Twin Lions SPV II LP. The Twin Lions Fund, Cassini Partners, L.P. – Twin Lions Management LLC Series, and Twin Lions SPV II LP are referred to individually as a “Fund” and collectively as the “Funds”. Additional detailed information about Twin Lions is provided below, including information about Twin Lions’ advisory services, investment approach, personnel, affiliations and brokerage practices. Twin Lions’ principal place of business is in Stamford, CT. Twin Lions manages each Fund pursuant to the investment guidelines set forth in the relevant governing and offering documents of each Fund, including any limited partnership agreement, term sheet, private placement memorandum, investment advisory agreement, and/or subscription agreement (each an “Offering Document,” and collectively, the “Offering Documents”). The Offering Documents for each Fund contain more detailed information about each Fund, including a description of the investment objective and strategy or strategies employed by Twin Lions in advising the Fund, and related restrictions that serve as a limitation on Twin Lions’ advice or management. Twin Lions will not generally tailor its advisory services to the individual investors or limited partners in the Funds (each an “Investor” and collectively the “Investors”) or provide Investors with the right to specify or restrict each Fund’s investment objectives or any investment or trading decisions. Accordingly, an investment in any of the Funds does not create a client-adviser relationship between such Investors and Twin Lions. Twin Lions’ investment objective in advising the Funds is to achieve a high long-term rate of return while maintaining prudent risk management. Twin Lions will invest primarily in equity securities. Each Investor is strongly encouraged to undertake appropriate due diligence on Twin Lions and the Funds prior to making an investment decision. This inquiry may include, but is not limited to, a review of the relevant Offering Documents for each Fund and the additional details about Twin Lions’ investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and each Fund’s Offering Documents). In considering whether Twin Lions’ advisory services or an investment in a Fund is appropriate to the Investor’s own circumstances, such determination should be based on all relevant

factors including, but not limited to, the Investor’s own investment objectives, liquidity requirements, tax situation, and risk tolerance before making an investment decision. Additional detailed information about Twin Lions is provided below, including information about Twin Lions’ advisory services, investment approach, brokerage practices, personnel, and affiliations. Twin Lions does not participate in wrap fee programs. As of June 1, 2026, Twin Lions advises approximately $215,869,723 on a discretionary basis.

The $100 million threshold was established as of April 2018 and has been indexed to inflation subsequent to April 2018. For simplicity, the foregoing example does not reflect the impact of such indexation. The Management Fee (if any) for each Fund is deducted on a quarterly basis in advance based upon the value of each Investor’s capital account as of the first day of each calendar quarter. The Management Fee will be prorated for any period that is less than a full calendar quarter. Fees are deducted from each Fund’s custodial or Prime Brokerage account(s). Twin Lions may reduce, waive, or calculate differently the Management Fee for certain Investors in the Funds, including but not limited to, members, employees, affiliates, or relatives of Twin Lions, or for certain strategic and/or large Investors. Operating Expenses of the Funds The Funds will bear all expenses relating to their ongoing structure and operation (either directly or indirectly by reimbursing Twin Lions or the General Partner for amounts incurred by either of them on behalf of the Funds), including: the Management Fee; all investment-related costs and expenses (i.e., expenses that, in Twin Lions’ sole discretion, are related to the investment of the Funds’ assets, whether or not such investments are consummated), including commissions and charges, interest on margin accounts and other indebtedness, expenses relating to short sales, clearing and settlement charges, option premiums and custodial and service fees, research-related expenses (including research-related travel expenses) and expenses relating to consultants, attorneys, brokers or other professionals or advisors who provide research, advice or due diligence services with regard to investments; fees and expenses related to portfolio exposure and performance management systems, risk management services and software related to trade reconciliation, treasury, margin, financial and counterparty management, risk monitoring, performance reporting, valuation quotation services (e.g., Bloomberg terminals, historical and live financial data and other similar services and data feeds) and trade order management systems (including systems

that facilitate trade compliance, commission management, stock locates and transaction cost analysis, and third party service providers used for implementation, custom reporting, updates, consultations, support, maintenance, monitoring and data extracts); each Fund’s legal, accounting, tax preparation and other taxrelated expenses (including preparation and mailing costs of financial statements, tax returns and other reports to Investors), auditing, consulting and other professional expenses; third-party administration costs, fees and expenses (including any costs, fees and expenses related to investor communications, relations, reporting or other investor materials, performance information, data extraction and other types of reporting and any audit or accounting services provided by a third-party administrator); compliance and reporting expenses and expenses attributable to regulatory filings that are made with respect to the Funds or their assets (including Section 13, Section 16, Form D, Form PF, Form N-PX the Foreign Account Tax Compliance Act, anti-money laundering compliance, state security filings, general regulatory compliance and non-U.S. position reporting filings, if applicable, and any other non-U.S. filings) and all compliance costs and expenses associated with the Funds in complying with the rules related to private fund advisers under the Advisers Act; each Fund’s pro rata share of Fund-related insurance costs (including the pro rata portion of director’s and officer’s insurance, errors and omissions insurance, fidelity insurance and other similar policies covering Twin Lions, the General Partner, and/or the members of any advisory committee); any taxes (including, without limitation, any withholding taxes, transfer taxes, stamp duties and other governmental or self-regulatory agency-related charges or duties); all costs and expenses incurred in attempting to protect and enhance the value of the Funds’ investments (including any fees and expenses associated with any pending or threatened litigation, audit, investigation, administrative or other proceeding, as well as any settlement costs); fees and expenses related to any activist-related activities; fees and expenses of any independent advisory committee members and any independent Fund representative; any fees and expenses related to a Fund’s liquidation, if applicable; fees paid to proxy and securities class action advisory firms; expenses relating to the offer and sale of a Fund interest and withdrawals and transfers thereof; other reasonable expenses related to the purchase, sale, preservation or transmittal of the Funds’ assets; and any extraordinary expenses (e.g., indemnification expenses). The Funds do not have their own separate employees or offices, and do not reimburse Twin Lions for salaries or office rent. Twin Lions is responsible for all of its overhead expenses of an ordinary and recurring nature, such as rent, supplies, secretarial expenses, its direct compliance expenses, stationery, charges for furniture and fixtures, salaries, and bonuses of its employees. Organizational Expenses The Funds will generally bear all costs and expenses relating to: (a) the organization of the Funds; and (ii) the offer and sale of interests in the Funds (including government filing fees, stamp duties or other taxes, legal and accounting fees, printing and mailing expenses and any other organizational costs) (collectively, “Organizational Expenses”). To the extent that Twin Lions or the General Partner incur any Organizational Expenses payable by the Funds, Twin Lions or the General Partner will be reimbursed by the Funds for the applicable amounts unless such reimbursement is waived by Twin Lions or the General Partner. The Funds may amortize their Organizational Expenses over a period of up to 60 months from the date each Fund commences operations, although, if deemed to be appropriate, amortization of such amounts may be accelerated as determined by the General Partner in its sole discretion.

As described in detail in the Offering Documents for the Twin Lions Fund, the General Partner will receive an Incentive Allocation from the Twin Lions Fund in an amount equal to 20% of the Twin Lions Fund’s outperformance (if any) over a 6% per annum hurdle return, allocated over a three-year period and subject to reduction for underperformance during such period. In the event that an Investor makes a partial or complete withdrawal of its interests or its interests are mandatorily withdrawn at any time other than the end of a fiscal year, the General Partner will be entitled to the Incentive Allocation with respect to the withdrawn amount, calculated as though the date of such withdrawal were the last day of the fiscal year. The General Partner may, in its sole discretion, waive or modify the Incentive Allocation for Investors that are members, partners, principals, employees or affiliates of the General Partner or Twin Lions, relatives or entities of such persons, and for certain strategic and/or large Investors. In addition, the General Partner may, in its sole discretion, cause all or a portion of the Incentive Allocation otherwise allocable to it to be allocated to one or more other persons or entities. Performance-based allocation and fee arrangements may create an incentive for Twin Lions to recommend investments which may be riskier or more speculative than those which would be recommended under a different arrangement. As described herein, Twin Lions advises the Funds (and may advise other private funds or client accounts in the future), and this would, in turn, require Twin Lions to allocate investments amongst multiple client accounts. Such an allocation arrangement may also create an incentive to favor higher performance allocation or performance fee accounts over other accounts in the allocation of investment opportunities. Twin Lions has procedures designed and implemented to ensure that the Funds (and any future private fund or client accounts) are treated fairly within the limits of the investment constraints and objectives of each Fund, and to prevent this potential conflict from influencing the allocation of investment opportunities among multiple client accounts. These procedures include, to the extent orders are aggregated, that orders are average priced.

Twin Lions believes that opportunities meeting all three criteria are rare, so capital will be concentrated in Twin Lions’ best ideas. Twin Lions feels strongly that volatility and beta are not accurate measures of true investment risk. Rather, Twin Lions believes that investment risk is best defined as “the probability and potential severity of permanent capital loss.” To mitigate the risk of permanent capital loss, Twin Lions seeks to invest in businesses that it understands well and that are available at a substantial discount from its estimate of intrinsic value. Twin Lions believes that purchasing securities well below intrinsic value creates a margin of safety which acts as a buffer against adverse developments. In addition to requiring a substantial margin of safety for each investment, Twin Lions seeks to mitigate risk by maintaining adequate diversification so that a bad outcome on one or two investments will not cause inordinate damage to the overall portfolio. Under normal conditions, Twin Lions expects the Twin Lions Fund’s portfolio to consist of approximately 8-15 positions. The Twin Lions Fund will rarely, if ever, use leverage as part of its investment strategy. From time to time, Twin Lions may cause the Twin Lions Fund to sell securities short for hedging purposes or in pursuit of profit. Twin Lions has observed that attractive value can present itself in a variety of asset classes and geographies. Therefore, Twin Lions believes it would be counterproductive to restrict the Twin Lions’ investment universe (other than to industries and businesses Twin Lions can understand). In advising the Twin Lions Fund, while Twin Lions intends to invest primarily in publicly traded equity securities, Twin Lions will consider investments in other asset classes if and when it sees compelling opportunities. For example, Twin Lions may evaluate a variety of special situations such as merger securities, spinoffs, liquidations, privatizations, distressed credit instruments, thrift conversions, rights offerings, warrants, etc. Under normal circumstances, Twin Lions expects to invest the majority of the Twin Lions Fund’s capital in companies based in the United States, although it will consider investments in any geography so long as the risk/reward relationship is attractive. Flexibility In advising the Twin Lions Fund, Twin Lions intends to pursue the investment strategy described above as long as such strategy is in accordance with the Twin Lions Fund’s investment objective. In addition, it may also formulate and implement new approaches to carry out the investment objective of the Twin Lions Fund. While it is anticipated that in advising the Twin Lions Fund, Twin Lions will invest primarily in equities, Twin Lions has broad and flexible investment authority. Accordingly, Twin Lions’ investments may at any

time include, without limitation, long or short positions in U.S. or non-U.S. publicly traded or privately issued or negotiated common stocks, preferred stocks, stock warrants and rights, corporate debt, bonds, notes, participations, convertible securities, fixed income securities, swaps, options (purchased or written), futures contracts, commodities, forward contracts, foreign exchange (including but not limited spot transactions, forwards, futures on currencies and non-deliverable forwards) and other derivative instruments, partnership interests and other securities or financial instruments including those of investment companies and cash and cash equivalents. Twin Lions may create or organize (alone or in conjunction with others, including Twin Lions, the General Partner or other affiliates) or otherwise utilize special purpose subsidiaries, co-investment vehicles, feeders or other special purpose investment vehicles, particularly in instances where Twin Lions, in its sole discretion, determines that there is a potential strategic, tax, regulatory or similar advantage to such structure. There can be no assurance that the Funds will realize their investment objectives. Key Risk Factors The following are material risks involved in Twin Lions’ investment strategy in relation to advising the Funds. There can be no assurance that Twin Lions’ investment objective in managing the Funds will be achieved, and that the Investors in the Funds will not incur losses. The risks described below are not meant to be a comprehensive collection of all risks with which Investors in the Funds will be confronted. Each Investor in the Funds is also encouraged to consult with Twin Lions to review the specific risk parameters of, and assets that comprise, each Fund’s portfolio at any given time and from time to time. Investors should also read the Offering Documents in their entirety for a more detailed discussion of the risks of investing in the Funds and consult with their own legal, tax and accounting advisors prior to undertaking an investment in the Funds. Risk of Loss. Investing in securities involves risk of loss that Investors should be prepared to bear. All investments in securities and other financial investments involve substantial risk of volatility arising from numerous factors that are beyond the control of Twin Lions, including market conditions, changing domestic or international economic or political conditions, changes in tax laws and government regulation and other factors. Dependence on Twin Lions. Twin Lions has discretion to select investments for the Funds. All management decisions will be made by Twin Lions. Accordingly, no potential Investor should invest in a Fund advised by Twin Lions unless it is willing to entrust all aspects of the management of the Funds to Twin Lions, who will have considerable discretion in the types of securities in which each Fund will invest. Investments for the Funds will be dependent upon the skill, judgment and expertise of Timothy Abbott, the Principal of Twin Lions, and if Mr. Abbott was no longer able to perform such function, the Funds could be adversely affected. Reliance on the Principal. As discussed, Twin Lions relies heavily on the expertise and efforts of Timothy Abbott, the Principal of Twin Lions. The Principal is responsible for all of the major decisions affecting the Funds. Should the Principal determine to discontinue managing the affairs of, or withdraw from, Twin Lions, or should the Principal die, become incapacitated or, for some other reason, be unable to effectively manage the affairs of Twin Lions, the business and results of the operations of the Funds may be adversely affected. Lack of Liquidity of the Funds’ Investments. The Funds’ assets may include securities and other financial

instruments or obligations that are thinly-traded or for which no market exists and/or which are restricted

as to their transferability under applicable securities laws. The sale of any such investments may be possible only at substantial discounts, and it may be extremely difficult to accurately value any such investments. Nature of Investments. In accordance with the Funds’ investment objectives, Twin Lions has broad discretion in making investments for the Funds. Investments will consist of assets that may be affected by business, financial market or legal uncertainties and are subject to a number of risks. There can be no assurance that Twin Lions will correctly evaluate the nature and magnitude of the various factors that could affect the value of and return on the Funds’ investments. Prices of investments may be volatile and are inherently difficult to predict. Any of these factors may significantly affect the results of the Funds’ activities and the value of its investments. No guarantee or representation is made that the investment objective of the Funds will be achieved. Equity-Related Securities in General. In advising the Funds, Twin Lions will invest in equity securities, which represent ownership interests in their respective issuers and generally carry the most risk associated with a specific issuer’s capital structure. The value of equity securities fluctuates in response to issuer, political, market and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and “growth” stocks can react differently from “value” stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks and public health emergencies have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. Lack of Diversification of Positions. Twin Lions’ investment program for the Funds will not necessarily be widely diversified. Accordingly, the investment portfolio of the Funds may be subject to more rapid changes in value than would be the case if the Funds maintained a wide diversification among companies, securities and types of securities. Micro to Medium Capitalization Companies. In advising the Funds, Twin Lions may invest in companies with micro- to medium-sized market capitalizations. These types of securities, particularly the securities of smaller-capitalization companies, involve higher risks in some respects than do investments in securities of larger companies. For example, prices of such securities are often more volatile than prices of securities of large-capitalization companies. Smaller companies often lack the management experience, financial resources, product diversification, and competitive strength of larger companies. Additionally, due to thin trading in some such securities, an investment in these securities may be more illiquid than those of larger capitalization companies. High Growth Industry Related Risks. The Funds may have investments in the securities of high growth companies. These securities may be very volatile. Certain of the high growth companies in which the Funds may invest, may allocate, or may have allocated, greater than usual amounts to research and product development. The securities of such companies may experience above-average price movements associated with the perceived prospects of success of the research and development programs. In addition, companies in which the Funds may invest could be adversely affected by lack of commercial acceptance of a new product or products or by technological change and obsolescence. Some of these companies may have limited operating histories. As a result, these companies may face undeveloped or limited markets, have limited products, have no proven profit-making history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses.

Further, many high growth companies with proprietary technology rely on a combination of patent, copyright, trademark and trade secret protection and non-disclosure agreements to establish and protect their proprietary rights, which may be essential to the growth and profitability of the company. There can be no assurance that a particular company will be able to protect these rights or will have the financial resources to do so, or that competitors will not develop or patent technologies that are substantially equivalent or superior to the technology of a company in which the Funds invest. Conversely, other companies may make infringement claims against a company in which the Funds invest, which could have a material adverse effect on such company. The markets in which many high-growth companies operate are extremely competitive. New technologies and improved products and services are continually being developed, rendering older technologies, products and services obsolete. Moreover, competition can result in significant downward pressure on pricing. There can be no assurance that companies in which the Funds invest will successfully penetrate their markets or establish or maintain competitive advantages. Consumer and Retail Companies. In advising the Funds, Twin Lions may invest in the securities of companies in the consumer and retail sectors. The securities of companies in the consumer and retail sectors can be volatile and the marketplace in which these companies operate may be extremely competitive. As such, there can be no assurance that the market position of a company in whose securities the Funds hold a position will be stable as the products and services of competitors evolve. Moreover, competition can result in significant downward pressure on pricing and margins. Additionally, consumer tastes and preferences can change very quickly with the result that a company’s market share may change rapidly if consumer focus shifts. The value of securities in this sector may also be affected by changing consumer confidence, disposable household income, government regulation or legislative changes, demographics and commodity prices, which can be highly volatile. Accordingly, the Funds’ investment portfolio may be subject to more rapid changes in value than would be the case if the Funds were required to maintain a wide diversification among issuers, industries, geographic areas, capitalizations or types of investments. Consumer Staples Companies. Consumer staples companies are subject to government regulation affecting their products, which may negatively impact these companies’ performance. For instance, government regulation may affect the permissibility of using various food additives and production methods of companies that make food products, which could affect company profitability. Tobacco companies may be adversely affected by the adoption of proposed legislation and/or by litigation. Also, the success of food, beverage, household and personal product companies may be strongly affected by consumer interest, marketing campaigns and other factors affecting supply and demand, including the performance of the overall domestic and global economy, interest rates, competition and consumer confidence and spending. To the extent the Funds invest in consumer staples companies, the Funds will be exposed to the foregoing risks. Media / Telecommunications / Technology Companies. In advising the Funds, Twin Lions may invest in the securities of companies in the telecommunications industry, the media industry and the technology industry. Certain telecommunications, media and technology and related companies in which the Funds invest face significant risks, including, without limitation, regulatory, operational, technological and competitive risks. Telecommunications services are subject to regulation at the Federal level by the Federal Communications Commission (the "FCC") and at the state level by public utilities commissions. Additionally, a significant portion of the media industry is subject to regulation by the FCC under Federal laws and regulations, including the Communications Act of 1934 and the Telecommunications Act of 1996. FCC rules and regulations have been subject to numerous appeals to both the courts and to Congress and it remains

difficult to accurately predict the impact of any potential new legislation or court action on any company within the telecommunications, media and technology industries. The telecommunications and media industries are experiencing significant technological change, including improvements in the capacity and quality of currently deployed technology. This causes uncertainty about future customer demand for products and services and the prices that the companies will be able to charge for these services. The rapid change in technology may lead to the development of alternative products and services that consumers prefer over existing offerings. Certain of the technology and technology-related companies in which the Funds invest may allocate, or may have allocated, greater than usual amounts to research and product development. The securities of such companies could experience above-average price movements associated with the perceived prospects of success of the research and development investments. In addition, companies in which the Funds invest could be adversely affected by lack of commercial acceptance of a new product or services or by technological change and obsolescence. Further, many companies with proprietary technology rely on a combination of patent, copyright, trademark and trade secret protection and non-disclosure agreements to establish and protect their proprietary rights, which may be essential to the growth and profitability of the company. There can be no assurance that a particular company will be able to protect these rights or will have the financial resources to do so, or that competitors will not develop or patent technologies that are substantially equivalent or superior to the technology of a company in which the Funds invest. Conversely, other companies may make infringement claims against a company in which the Funds invest, which could have a material adverse effect on such company. The markets in which many telecommunications, media, and technology companies operate are extremely competitive. New technologies and improved products and services are continually being developed, rendering older technologies, products and services obsolete. Moreover, competition can result in significant downward pressure on pricing. Current and potential competitors in telecommunications and media include long distance companies, local telephone companies, cable companies, wireless operators, broadcast networks, cable networks, television stations, radio broadcasters, publishers, videogame developers and distributors, advertising companies, entertainment and leisure companies, Internet service providers, electric utilities and other companies that offer network services and media content and delivery. Current and potential competitors in technology include communications equipment providers, software companies, hardware providers and semiconductor companies among others. Many of these companies have a strong market presence, brand recognition and existing customer relationships, all of which contribute to intensifying competition and may affect the growth prospects of the telecommunications industry, the media industry and the technology industry. The competition is likely to intensify as a result of the entrance of new competitors and the rapid development of new technologies, products, and services. There can be no assurance that companies in which the Funds may invest will be able to successfully predict which of many possible future technologies, products, or services will be important to maintain a competitive position or what expenditures will be required to develop and provide these technologies, products or services. Each company’s ability to compete successfully will depend on marketing, sales and service delivery, and on the company’s ability to anticipate and respond to various competitive factors affecting the industry, including new services that may be introduced, changes in consumer preferences, demographic trends, economic conditions, and discount pricing and other strategies deployed by the many industry participants. To the extent that a company in which the Funds invest does not keep pace with technological advances or fails to timely respond to changes in competitive factors in the industry, the company could lose market share or experience a decline in revenue and net income.

Some of the companies in which the Funds may invest could have limited operating histories. As a result, these companies may face undeveloped or limited markets, have limited products, have no proven profitmaking history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses. Industrials Sector. In advising the Funds, Twin Lions may invest in the securities of companies in the industrials sector, such as those involved in construction and manufacturing, transportation (e.g., rails and roads), aerospace and defense, industrial machinery and equipment and electrical components and equipment. The industrials sector includes, among other industries, aerospace and defense, building products, electrical equipment and machinery, as well as transportation, construction and engineering services. The industrials sector, and companies operating therein, can be significantly affected by general economic trends, including employment, economic growth, and interest rates, changes in consumer sentiment and spending, commodity prices, legislation, government regulation and spending, import controls and worldwide competition. For example, adverse changes in the prices of certain commodities and unit volume reductions resulting from an oversupply of materials used in industrials and energy equipment and services industries can adversely affect those industries. Furthermore, companies in the industrials sector can also be adversely affected by liability for environmental damage, depletion of resources and mandated expenditures for safety and pollution control. Any of the foregoing could have an adverse impact on any investments the Funds may make in the industrials sector and, therefore, on the Funds’ performance. Financial Sector. In advising the Funds, Twin Lions may invest in the securities and other instruments of companies operating in the banking and financial sector. Investing in financial services companies presents special risks. The financial statements of such companies are frequently complex and may fail to present fully their financial position or predict their future revenue, credit losses and funding ability. Financial services companies are particularly exposed to general economic risk and to funding risk caused by loss of market and customer confidence. In circumstances where financial services companies experience sudden sharp declines in share price or widening of credit spreads, there may also be a significant increase in counterparty and custody risk, including for the Funds. Financial services companies are highly regulated and in recent years have increasingly been the subject of regulatory actions that in certain cases have caused substantial volatility in their security prices. Applicable regulations, including in the U.S., also typically limit the percentage of a bank’s securities that can be owned by an investor without regulatory approval. Short Sales. From time to time, Twin Lions may cause the Funds to sell securities short for hedging purposes or in pursuit of profit. Short selling, or the sale of securities not owned by a Fund, involves certain risks. Such transactions expose a Fund to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed by a Fund in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein a Fund might be compelled, at the most disadvantageous time, to replace borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. Hedging Transactions. Although Twin Lions may utilize a variety of financial instruments, such as derivatives, options, interest rate swaps, swaptions, caps and floors, futures and forward contracts generally for risk management purposes, there can be no assurances that a particular hedge is appropriate, or that a certain risk is measured properly. Further, while Twin Lions may enter into hedging transactions for a Fund to seek to reduce risk, such transactions may result in a poorer overall performance and

increased (rather than reduced) risk for the Fund than if it did not engage in any such hedging transactions. Moreover, the Funds will always be exposed to certain risks that cannot be hedged, such as credit risk (relating both to particular securities and counterparties). In addition, Twin Lions may choose not to enter into hedging transactions with respect to some or all of the Funds’ positions. Leverage. Although Twin Lions does not expect to do so under ordinary circumstances, in advising the Funds, Twin Lions may utilize leverage in its investment strategy. This may result in a Fund controlling substantially more assets than its equity. Leverage increases returns to the Funds if the Funds earns a greater return on investments purchased with borrowed funds than the Funds’ cost of borrowing such funds. However, the use of leverage exposes the Funds to additional levels of risk, including: (i) greater losses from investments than would have otherwise been the case had the Funds not borrowed to make the investments; (ii) margin calls or interim margin requirements may force premature liquidations of investment positions; and (iii) losses on investments where the investment fails to earn a return that equals or exceeds a Fund's cost of borrowing such funds. In the event of a sudden, precipitous drop in value of a Fund's assets, the Fund might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying its losses. Non-U.S. Securities. Investing in securities of non-U.S. governments and companies that are generally denominated in non-U.S. currencies and utilizing options on non-U.S. securities involves certain considerations comprising both risks and opportunities not typically associated with investing in securities of the United States Government or United States companies. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of foreign taxes, less liquid markets and less available information than is generally the case in the United States, higher transaction costs, less government supervision of exchanges, brokers and issuers, greater risks associated with counterparties and settlement, difficulty in enforcing contractual obligations, lack of uniform accounting and auditing standards and greater price volatility. In addition, accounting and financial reporting standards that prevail outside of the U.S. generally are not as high as U.S. standards and, consequently, less information is typically available concerning companies located outside of the U.S. than for those located in the U.S. As a result, Twin Lions may be unable to structure its transactions to achieve the intended results or to mitigate all risks associated with international markets. It may also be difficult to enforce a Fund's rights in such markets. The protections accorded to the Funds under certain U.S. investments and other laws and regulations may be unavailable for transactions on foreign exchanges and with foreign counterparties. The investments of the Funds that are denominated in non-U.S. currencies are subject to the risk that the value of a particular currency will change in relation to the U.S. dollar. Twin Lions may try to hedge these risks, but there can be no assurance that such strategies will be implemented or, if implemented, will be effective. Special Situations and Distressed Securities. In advising the Funds, Twin Lions may invest in companies involved in (or the target of) acquisition attempts or tender offers or in companies involved in work-outs, liquidations, spin-offs, reorganizations, bankruptcies and similar transactions. In any investment opportunity involving any such type of special situation, there exists the risk that the contemplated transaction either will be unsuccessful, take considerable time or will result in a distribution of cash or a new security the value of which will be less than the purchase price of the security or other financial instrument in respect of which such distribution is received. Similarly, if an anticipated transaction does not in fact occur, a Fund may be required to sell its investment at a loss. Because there is substantial uncertainty concerning the outcome of transactions involving financially troubled companies in which Twin

Lions may invest on behalf of the Funds, there is a potential risk of loss by a Fund of its entire investment in such companies. Derivatives. Twin Lions may trade both exchange-traded and over the counter (“OTC”) derivatives, including, without limitation, futures, forwards, swaps, options, and contracts for differences, as part of its investment approach. Those instruments can be highly volatile and expose investors to a high risk of loss. The low initial margin deposits normally required to establish a position in such instruments permit a high degree of leverage. As a result, depending on the type of instrument, a relatively small movement in the price of a contract may result in a profit or a loss which is high in proportion to the amount of funds deposited as initial margin and may result in unquantifiable further loss exceeding any margin deposited. In addition, daily limits on price fluctuations and speculative position limits on exchanges may prevent prompt liquidation of positions resulting in potentially greater losses. The pricing relationships between derivatives and the instruments underlying such derivatives may not correlate with historical patterns, potentially resulting in unexpected losses. Further, when used for hedging purposes, there may be an imperfect correlation between these instruments and the investments or market sectors being hedged. Transactions in OTC contracts may involve additional risk as there may be no market on which to close out an open position. It may therefore be impossible to liquidate an existing position, to assess the value of a position or to assess the exposure to risk. Contractual asymmetries and inefficiencies can also increase risk. These can include break clauses, whereby a counterparty can terminate a transaction based on a certain reduction in net asset value, incorrect or disputed collateral calls or delays in collateral recovery. The Funds may also sell covered and uncovered options on securities and other assets. To the extent that such options are uncovered, the Funds could incur an unlimited loss. Options. Options trading is not a core part of Twin Lions’ investment strategy, although Twin Lions may cause the Funds to purchase or write options from time to time. Trading options is highly speculative and may entail risks that are greater than investing in other financial instruments. Prices of options are generally more volatile than prices of other financial instruments. In trading options, Twin Lions may speculate on market fluctuations of the underlying financial instrument (e.g., a security, an index, a commodity, exchange rate or other instrument), while only investing a small percentage of value relative to a Fund’s potential exposure. The price of any option is a function of direction (e.g., whether the option is a “put”—the right to sell— or a “call”—the right to buy), the time to expiry and the implied volatility of the underlying instrument, among other factors. In advising the Funds, Twin Lions may “sell” or “write” an option, which means it receives a small payment, or premium, relative to a notional amount, or Twin Lions may “buy” an option, which means it pays a premium to receive exposure to a larger notional amount. A “seller” of options is generally exposed to the entire notional amount of the option contract, and can be exposed to even more risk if it is selling a call option. A “buyer” of options risks losing all of its investment if the option expires “out of the money” (i.e., the trade goes against that option buyer). Trading options is a highly specialized activity and entails greater than ordinary investment risks. Because option premiums paid or received by an investor are often small in relation to the market value of the investments underlying the options, buying and selling put and call options can result in large amounts of leverage. As a result, the leverage offered by trading in options could cause an investor's asset value to be subject to more frequent and wider fluctuations than would be the case if the investor did not invest in options. Risk Control Framework. No risk control system is fail-safe, and no assurance can be given that any risk control framework employed by Twin Lions will achieve its objective. No assurance can be given that historical trading patterns will accurately predict future trading patterns.

Commodities and Futures Contracts. Twin Lions may enter into futures contracts from time to time on behalf of the Funds. Trading in futures contracts and options thereon is a highly specialized activity which may entail greater than ordinary investment risks. Futures markets are highly volatile and may be influenced by factors such as changing supply and demand relationships, governmental programs and policies, national and international political and economic events, and changes in interest rates. In addition, because of the low margin deposits normally required in futures trading, a high degree of leverage may be typical of a futures trading account. As a result, a relatively small price movement in a futures contract may result in substantial losses to the trader. Futures trading may also be illiquid. Certain exchanges do not permit trading in particular futures contracts at prices that represent a fluctuation in price during a single day's trading beyond certain set limits. If prices fluctuate during a single day's trading beyond those limits, Twin Lions could be prevented from promptly liquidating unfavorable positions and could thus be subject to substantial losses. Brokerage and Custodial Risk. There are risks involved in dealing with the custodians or Prime Brokers who settle trades. Twin Lions maintains a custody accounts with its Prime Brokers and primary custodians, Fidelity Prime Services and Interactive Brokers LLC. Although Twin Lions monitors the Prime Brokers and believes that they are appropriate custodians, there is no guarantee that the Prime Brokers, or any other custodian that the Funds may use from time to time, will not become bankrupt or insolvent. While both the U.S. Bankruptcy Code and the Securities Investor Protection Act of 1970 seek to protect customer property in the event of a bankruptcy, insolvency, failure or liquidation of a broker-dealer, there is no certainty that, in the event of a failure of a broker-dealer that has custody of Fund assets, the Funds would not incur losses due to its assets being unavailable for a period of time, the ultimate receipt of less than full recovery of its assets, or both. Limited Withdrawal and Transfer Rights from the Funds. An Investor in the Funds generally will be permitted to withdraw all or any part of any capital contribution only in accordance with the terms described in the Offering Documents. Further, transfers of the Interests will be permitted only with the written consent of the General Partner. Accordingly, the Interests should only be acquired by investors willing and able to commit their funds for an appreciable period of time. Market Risk. The profitability of a significant portion of the Funds’ investment program depends to a considerable extent upon Twin Lions correctly assessing the future course of price movements of specific securities and other investments. There can be no assurance that Twin Lions will be able to accurately predict such price movements. In addition, certain of Funds’ investments may have limited liquidity. During periods of stress in the markets, prices for securities with less liquidity typically suffer significantly more than more liquid, exchange-traded equities. This lack of liquidity, together with a failure to accurately predict market movements, may adversely affect the market value of investments from time to time. Projections. Projected operating results of a company in which Twin Lions invests will be based primarily on financial projections prepared by such company’s management and/or developed by Twin Lions. Projections are inherently uncertain and subject to factors beyond the control of Twin Lions or the relevant company. In all cases, projections are only estimates of future results that are based upon assumptions made at the time the projections are developed. There can be no assurance that the results set forth in the projections will be attained, and actual results may be significantly different than the projections. Also, general economic factors, which are not predictable, can have a material effect on the

reliability of projections. Non-Disclosure of Positions. In an effort to protect the confidentiality of its positions, Twin Lions generally will not disclose its positions to Investors on an ongoing basis. However, the General Partner, in its sole discretion, may permit such disclosure on a select basis to certain Investors. Incentive Allocation. The reallocation of a percentage of the Funds’ net profits to the General Partner, from the Investors may create an incentive for Twin Lions, an affiliate of the General Partner, to cause the Funds to make investments that are riskier or more speculative than would be the case if this allocation were not made. Since the Incentive Allocation is calculated on a basis that includes unrealized appreciation of assets, such allocation may be greater than if it were based solely on realized gains. In addition, in the event that an Investor makes a partial or complete withdrawal of its interests or its interests are mandatorily withdrawn at any time other than the end of a fiscal year, the General Partner will be entitled to the Incentive Allocation with respect to the withdrawn amount, calculated as though the date of such withdrawal were the last day of the fiscal year. This may result in the Investor being subject to an Incentive Allocation during the year even though the Investor does not have net profits based on the entire year’s performance (i.e., due to losses that occur after the withdrawal). Further, due to the multi-year nature of the incentive compensation for the Twin Lions Fund, an Investor may be charged an Incentive Allocation and/or a Withdrawal Allocation in a year in which no net profits are allocated to such Investor. Side Letters. Twin Lions may enter into agreements (sometimes referred to as “side letters”) with certain prospective or existing Investors whereby such Investors may be subject to terms and conditions that are more advantageous than those afforded to other Investors. For example, such terms and conditions may provide for: (i) special rights to make future investments in the Funds, other investment entities or managed accounts; (ii) special withdrawal rights relating to frequency or notice; (iii) a reduction or rebate in the Management Fee, the Incentive Allocation or Withdrawal Allocation to be paid by the Investor; (iv) rights to receive reports on a more frequent basis or that include information not provided to other Investors (including, without limitation, more detailed information regarding portfolio positions); and/or (v) such other rights as may be negotiated by the General Partner and such Investors. The modifications are solely at the discretion of the General Partner and may, among other things, be based on the size of the Investor’s investment or affiliated investment entity, an agreement by an Investor to maintain such investment in a Fund for a significant period of time, or other similar commitment by an Investor to the Funds. Cybersecurity Risk. The Funds, Twin Lions, the General Partner and their respective service providers, including banks, broker-dealers, custodians and their affiliates, may be subject to operational and information security risks resulting from cyber-attacks. Cyber-attacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, unauthorized asset transfers, and various other forms of cybersecurity breaches. Cyber-attacks affecting the Funds, Twin Lions, the General Partner, or their respective service providers may adversely impact Investors. For instance, cyber-attacks may interfere with the processing or execution of Fund transactions, cause the release of confidential information, including private information about Investors, subject the Funds, Twin Lions, the General Partner or their respective affiliates to regulatory fines or financial losses or cause reputational damage. Additionally, cyberattacks or security breaches (e.g., hacking or the unlawful withdrawal or transfer of funds) affecting any of the Funds’ key service providers, such as Twin Lions, banks, broker-dealers, custodians or other counterparties holding Fund assets, may cause significant harm, including the loss of capital. Similar types of cybersecurity risks are also present for issuers of securities in which the Funds may invest. These risks

could result in material adverse consequences for such issuers and may cause the Funds’ investments in such issuers to lose value. Risk Management Failures. Although Twin Lions attempts to identify, monitor and manage significant risks, these efforts do not take all risks into account and there can be no assurance that these efforts will be effective. Similarly, Twin Lions may be ineffective in implementing or applying risk management techniques. Any inadequacy or failure in risk management efforts could result in material losses to the Funds. Dependence on Service Providers. Twin Lions depends upon its counterparties and other businesses that are not controlled by Twin Lions or the General Partner that provide services to the Funds (collectively, the “Service Providers”). Examples of Service Providers include the fund administrators and the Prime Brokers, as well as the Funds’ custodians, legal counsel, and auditors. Errors are inherent in the operations of any business, and although Twin Lions will adopt measures to prevent and detect errors by, and misconduct of, counterparties and Service Providers, and transact with counterparties and Service Providers that it believes to be reliable, such measures may not be effective in all cases. Errors or misconduct could have a material adverse effect on the Funds’ and Investors’ investments therein. Due Diligence Risks. Before making investments, Twin Lions intends to conduct due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to each investment. When conducting due diligence and making an assessment regarding an investment, Twin Lions will rely on resources available to it, including information provided by the target of the investment and, in some circumstances, third party investigations. The due diligence process may at times be subjective with respect to newly organized companies for which only limited information is available. Accordingly, there can be no assurance that the due diligence investigation that Twin Lions will conduct with respect to any investment opportunity will reveal or highlight all relevant facts that may be necessary or helpful in evaluating such investment opportunity. Further, there can be no assurance that such an investigation will result in an investment being successful. Twin Lions may be required to undertake its investment analyses and decisions on an expedited basis to take advantage of investment opportunities. Therefore, no assurance can be given that Twin Lions will have knowledge of all circumstances that may adversely affect an investment. Investment Flexibility. Twin Lions has broad and flexible authority to invest the Twin Lion Fund’s capital. In particular, Twin Lions is not required to invest any particular percentage of the Twin Lion Fund’s portfolio in any type of investment, sector or region, and the amount of the portfolio which is invested in any type of investment, long or short, or which is weighted in different countries or different sectors can change at any time based on the availability of attractive market opportunities. Accordingly, at any time, the Twin Lions Fund may have significant investments in strategies, sectors or instruments not specifically described in the Offering Documents and therefore be subject to risks that are not specifically described in the Offering Documents. Prospective Investors must recognize that, by investing in the Twin Lions Fund, they are placing their capital under the full discretionary management of Twin Lions and authorizing Twin Lions to trade for the Twin Lions Fund. There can be no assurance that Twin Lions will be successful in applying its approach, and there is material risk that an investor may suffer significant impairment or total loss of its capital. Effect of Substantial Withdrawals. A substantial amount of withdrawals by one or more investors could require Twin Lions on behalf of the Twin Lions Fund to liquidate positions to raise the cash necessary to fund the withdrawals at a time when market conditions are adverse or when such liquidations are otherwise not in the best interests of non-withdrawing investors. The Twin Lions Fund may then be forced to sell its more liquid positions, which may cause an imbalance in the portfolio that could have a material

adverse effect on the remaining Investors. Further, it may be impossible or impracticable to liquidate a sufficient amount of securities to meet withdrawals and redemptions because a portion of the portfolio at any given time may be invested in securities for which the market is or becomes illiquid. Substantial withdrawals and redemptions could also significantly restrict the Twin Lions Fund’s ability to obtain financing or transact with derivatives counterparties needed for its trading strategies, which would have a further material adverse effect on performance. Further, a reduction in the size of the Twin Lions Fund will likely result in expenses of the Twin Lions Fund being proportionately higher for remaining Investors. Withdrawals, or redemptions by investors in the Twin Lions Funds may have a more significant impact on the Twin Lions Fund than may be the case in investment vehicles with larger investor bases. Operational Risk. Operational risk is the potential for loss caused by a deficiency in information, communication, transaction processing, or settlement and accounting systems. Twin Lions (or its agents) maintains controls that include systems and procedures to record and reconcile transactions and positions and to obtain necessary documentation for its trading activities. However, no system of controls is foolproof, and a failure of such controls could result in a material loss to the Funds. Legal and Regulatory Risks of Hedge Funds. Legal, tax and regulatory changes could occur that may adversely affect the Funds. In particular, changes in the regulation of hedge funds may adversely affect the value of investments held by the Funds and the ability of the Funds to obtain the leverage it might otherwise obtain or to pursue its trading strategies. In addition, securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. Regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivative transactions and funds that engage in such transactions is subject to modification by government and judicial actions. The effect of any future regulatory change could be substantial and adverse, including, for example, increased compliance costs, the prohibition of certain types of trading and/or the inhibition of the Funds’ ability to pursue certain of its investment strategies as described herein and in the Offering Documents. Brokerage and Custodial Arrangements. Twin Lions is authorized to determine the broker(s) or dealer(s) to be used for each securities transaction for the Funds. In selecting brokers or dealers to execute transactions, Twin Lions need not solicit competitive bids and does not have an obligation to seek the lowest commission cost available. It is not Twin Lions’ practice to negotiate “execution only” commission rates, thus the Funds may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. Although Twin Lions 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 Twin Lions and the Funds. In selecting brokers and negotiating commission rates, Twin Lions will consider the financial stability and reputation of brokerage firms, and the research, brokerage or other services provided by such brokers. Twin Lions may place transactions with a broker or dealer that (i) provides Twin Lions (or an affiliate) with the opportunity to participate in capital introduction events sponsored by the broker-dealer, or (ii) refers investors to the Funds or other products advised by Twin Lions, if otherwise consistent with seeking best execution, provided Twin Lions is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of Investors to the Funds.

Soft Dollar Arrangements. Section 28(e) of the Securities Exchange Act of 1934 (“Section 28(e)”), 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. Except for services that would be a Fund expense or as otherwise described below, Twin Lions 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 brokerdealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. The use of commissions arising from a Fund’s investment transactions for services other than research and brokerage will be limited to services that would otherwise be a Fund expense. The use of commissions to obtain such other services would be outside the parameters of Section 28(e). In some instances, Twin Lions 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, Twin Lions will make a good faith effort to determine the relative proportion of the product or service used to assist Twin Lions 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 Twin Lions in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by the Funds’ transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Twin Lions from its own resources. Research and brokerage services obtained using commissions arising from the Funds’ portfolio transactions may be used by Twin Lions in its other investment activities and thus, the Funds may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. When appropriate, Twin Lions may, but is not required to, aggregate orders to achieve more efficient execution or to provide for equitable treatment among the Funds. Funds participating in aggregated trades will be allocated securities based on the average price achieved for such trades. Twin Lions reserves the right, in its sole discretion, to change the brokerage and custodial arrangements described above without further notice to Investors in the Funds. Generative AI Risk. Twin Lions may use certain artificial intelligence (“AI”) tools, including generative AI models, in connection with the Firm’s research. These tools entail certain risks, including that they may generate content that is inaccurate, incomplete, biased, or misleading, even where such content appears

authoritative, and that sensitive or proprietary information could be exposed to third-parties or incorporated into model training if improperly input into such tools.

Personal Trading The Code provides that access persons must obtain pre-approval from the CCO prior to buying or selling a Reportable Security in a Covered Account (as such terms are defined in the Code). Reportable Securities generally include stocks, bonds, and derivatives relating thereto, as well as interests in limited partnerships and other private funds, with certain limited exceptions (e.g. for U.S. government obligations, mutual funds, and exchange-traded funds that track a broad-based index such as the S&P 500). Covered Accounts generally include accounts that an access person controls or in which an access person may be deemed to have beneficial ownership (such as the account of a spouse or minor child), but exclude accounts over which the access person has no direct or indirect influence or control (such as accounts over which the access person has granted full investment discretion to an unaffiliated investment adviser).

Twin Lions believes that these policies put client interests first and will mitigate inherent conflicts of interest with access persons trading for their personal accounts or accounts that the access person controls or in which the access person may be deemed to have beneficial ownership. Exceptions to the personal trading policy are handled on a case-by-case basis. However, Twin Lions will maintain a restricted list, and personal trading requests to trade in securities on the restricted list will be denied. Gifts and Entertainment, Political Activities and Outside Activities The Code provides that gifts and entertainment must be reasonable in light of industry practices and should never be given or received if the purpose is to influence the recipient. Twin Lions requires access persons to report or receive approval for the receipt or giving of gifts and entertainment under certain circumstances. The Code also generally requires access persons to obtain prior approval before the access person, a spouse or certain other immediate family members makes a political contribution or engages in certain campaign-related fundraising activities. This policy is intended to prevent scenarios whereby an access person may make a contribution or engage in an activity to influence the selection of Twin Lions as an investment adviser for a governmental entity. Finally, the Code provides that, without prior approval, access persons are generally not permitted to engage in certain types of outside business activities. This policy is intended to prevent material conflicts of interest that could arise from an access person’s personal activities. Cross Trades From time to time, Twin Lions may engage in cross trades for portfolio rebalancing or other purposes. In the event that Twin Lions executes such a trade, it generally will instruct the custodian for the Funds participating in the trade to book the transaction at the closing price on the day of the transaction (or at a price determined in accordance with Twin Lions’ Valuation Policy if an official closing price is not available). Twin Lions will not receive any fee or commission in connection with any cross trade. Twin Lions does not intend to engage in principal transactions. Additional Considerations From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities, partners and personnel in connection with client transactions. Twin Lions has established written policies and procedures, which contain procedures to monitor and resolve conflicts and will endeavor to resolve conflicts in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Further, the Code includes policies and procedures designed to prevent insider trading and facilitate the protection of material, non-public information, including non-public information about the activities of Funds. Twin Lions’ Code of Ethics is available to clients upon request.

It is not Twin Lions’ practice to negotiate “execution only” commission rates, thus the Funds may be deemed to be paying for research, brokerage or other services provided by a broker-dealer which are included in the commission rate. Twin Lions may, from time to time, speak at conferences and programs for investors interested in investing in hedge funds which are sponsored by Prime Brokers. These conferences and programs may be a means by which Twin Lions can be introduced to potential investors or clients. Prime Brokers normally are not compensated for providing such "capital introduction" opportunities. In addition, Prime Brokers or custodians may provide financing and other services to the clients. Twin Lions may place portfolio transactions for the Funds with such firms, if Twin Lions determines that it is otherwise consistent with seeking best execution. In no event will Twin Lions select a broker-dealer as a means of remuneration for recommending Twin Lions or the Funds or affording Twin Lions with the opportunity to participate in capital introduction programs. Research and Other Soft Dollar Benefits Twin Lions may use "soft dollars" generated through brokerage transactions for research and brokerage and research-related products and services. Usage of soft dollars will fall within the safe harbor provided under Section 28(e). Twin Lions will evaluate the execution of broker-dealers on an ongoing basis as they are used and periodically conduct a review of the execution performance of broker-dealers executing its clients’ transactions to make a good faith determination that the value of research and brokerage services received is reasonable in relation to the amount of commissions paid. Research services within Section 28(e) for which Twin Lions may use soft dollars can include, without limitation, access 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)’s safe harbor for which Twin Lions uses soft dollars can include: services related to the execution, clearing and settlement of securities transactions and functions incidental thereto. These services may include, among other things, order management systems, electronic trading platforms, trade analytics, and data and analytics services used in connection with trading and investment decision-making.

Trade Order Aggregation Twin Lions may aggregate purchase and sale orders of investments held by Funds with similar orders being made simultaneously for other accounts if, in Twin Lions’ reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to such Fund based on an evaluation that the Fund will be benefited by relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In some instances, the purchase or sale of investments for a Fund may be effected simultaneously with the purchase or sale of like investments for another Fund(s). Such transactions may be made at slightly different prices due to, among other factors, the volume of investments purchased or sold. In such event, the average price of all investments purchased or sold in such transactions may be determined, in Twin Lions’ sole discretion, and the Fund(s) may be charged or credited, as the case may be, with the average transaction price. Allocation of Trades Twin Lions may determine that certain investments are suitable for acquisition by multiple Funds. If Twin Lions is not able to acquire the desired aggregate amount of such securities on terms and conditions which Twin Lions deems advisable, Twin Lions will endeavor in good faith to allocate the limited amount of such securities acquired among the various Funds for which Twin Lions considers them to be suitable on a pro rata basis. Pursuant to Twin Lions’ policy related to the allocation of trades, Twin Lions may deviate from allocating trades on a pro rata basis for a variety of reasons, including, but not limited to, (i) differences in brokerage relationships between the Funds, (ii) differences in the investment policies and strategies of the Funds, and (iii) differences in the Funds’ cash flows, liquidity, and existing portfolio exposures. Cross Trades and Principal Transactions From time to time, Twin Lions may engage in cross trades for portfolio rebalancing or other purposes. In the event that Twin Lions executes such a trade, it generally will instruct the custodian for the Funds participating in the trade to book the transaction at the closing price on the day of the transaction (or at a price determined in accordance with Twin Lions’ Valuation Policy if an official closing price is not available). Twin Lions will not receive any fee or commission in connection with any cross trade. Twin Lions does not intend to engage in principal transactions. Trade Errors Pursuant to the exculpation and indemnification provided by the Funds to Twin Lions and its affiliates and personnel, Twin Lions and its affiliates and personnel will generally not be liable to the Funds for any act or omission, absent bad faith, gross negligence, willful misconduct or actual fraud of such person, and the Funds will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Funds, absent bad faith, gross negligence, willful misconduct or actual fraud of such person. As a result of these provisions, the Funds (and not Twin Lions) will benefit from any gains resulting from trade errors and other errors and will generally be responsible for any losses (including additional trading costs) resulting from trade errors and other errors, absent bad faith, gross negligence, willful misconduct or actual fraud of the relevant person. Twin Lions will not offset any such gains and losses resulting from trade errors and other errors unless the underlying transactions constitute a single transaction or closely related series of transactions.

While Twin Lions is subject to the Custody Rule, it is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that each Fund distribute its audited financial statements, prepared in accordance with U.S. generally accepted accounting principles, to all investors within 120 days of the end of such Fund’s fiscal year. Investors should carefully review the audited financial statements of the Funds upon receipt.

Twin Lions will vote proxies as it deems necessary or appropriate, on a case-by-case basis. Prior to voting, Twin Lions will determine whether a conflict of interest exists that is material to the vote. If such a conflict exists, Twin Lions will either resolve the conflict or refer the proxy vote to an outside service for its independent consideration. In certain circumstances, Twin Lions may refrain from voting proxies where Twin Lions believes that voting would not be in the best interest of the Funds, taking into consideration the time required to vote the proxies and the anticipated benefit to the Funds. If you have any questions about Twin Lions’ proxy policy, its proxy record-keeping procedures or if you would like any further information about how proxies are voted, please contact the CCO.