Seven Fleet Capital Management LP: investment adviser

Seven Fleet currently provides investment advisory services to the following private investment funds: (a) Seven Fleet Partners LP (the “Domestic Fund”); (b) Seven Fleet Offshore Fund Ltd., (the “Offshore Fund” and, together with the Domestic Fund, the “Feeder Funds”); and (c) Seven Fleet Master Fund LP (the “Master Fund” and, together with the Feeder Funds, the “Funds” and each a “Fund”). Notwithstanding the foregoing, Seven Fleet is required to invest all of the capital of the Feeder Funds in limited partnership interests of the Master Fund, other than cash and cash equivalents held for investment into the Master Fund, distributions to investors and/or payment of operating expenses. Seven Fleet Advisors LLC (the “General Partner”), an affiliate of Seven Fleet, is the general partner of the Domestic Fund and the Master Fund. The General Partner is a “relying adviser” that is also controlled and principally owned by the Principal. The General Partner has ultimate responsibility for decisions relating to the management and operations made on behalf of the Domestic Fund and the Master Fund. The General Partner has delegated certain responsibilities, including investment management of the Domestic Fund and the Master Fund, to Seven Fleet. Seven Fleet currently provides discretionary investment advice to a separate fund which is managed and operated by a third party, and may in the future provide discretionary advise to other funds and accounts, pursuant to separate investment management agreements (the “Other Accounts,” and together with the Funds, the “Client Accounts”). Additional detailed information about Seven Fleet is provided below, including information about Seven Fleet’s advisory services, investment approach, personnel, affiliations, and brokerage practices. Seven Fleet provides discretionary investment management services to the Funds pursuant to investment guidelines set forth in the relevant governing and offering documents of the Funds, including any limited partnership agreement, investment management agreement, private placement memorandum and/or subscription agreement, as the case may be (each an “Offering Document,” and collectively, the “Offering Documents”). Seven Fleet does not tailor its advisory services to the individual investors of a Fund (each an "Investor" and collectively the “Investors”), or provide Investors with the right to specify, or restrict the Funds’ investment objectives or any investment or trading decisions. With respect to any Other Accounts, Seven Fleet may contract with such Other Account to adhere to limited risk and/or operating guidelines imposed by such Other Account. Seven Fleet negotiates such arrangements on a case-by-case basis. Each Investor/Client Account is strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant governing documents and the additional details about Seven Fleet’s investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and each Client Account’s governing documents) in considering whether Seven Fleet’s advisory services/ an

investment in the Funds are appropriate to its own circumstances, based on all relevant factors including, but not limited to, their own investment objectives, liquidity requirements, tax situation and risk tolerance before making an investment decision. Seven Fleet’s investment objective is to generate attractive risk-adjusted returns primarily by investing in publicly traded equity securities of biotechnology companies. The investment strategy seeks to generate uncorrelated returns by trading around events such as clinical trial readouts, regulatory decisions, commercial milestones, and corporate transactions. Seven Fleet believes that these events typically exhibit lower beta characteristics, allowing the Client Accounts to invest across various market conditions. Seven Fleet does not participate in wrap fee programs. As of April 30, 2026, Seven Fleet managed $434,581,362 in regulatory assets under management, all of which are managed on a discretionary basis.

The General Partner generally receives performancebased allocations from the Master Fund on an annual basis in arrears and upon redemptions and withdrawals by Investors. Management fees, performance-based compensation and/or expenses may be reduced, rebated, discounted or waived in certain circumstances, including, without limitation, with respect to investments in the Feeder Funds by Seven Fleet’s personnel and/or other related persons. The Other Accounts have management fees and performance-based compensation that differ in one or more respects from those applicable to Investors in the Funds since they are negotiated on a case-by-case basis. However, performance fees are generally paid on an annual basis and upon the withdrawal of capital. Other Fees and Expenses Subject to an expense cap, the Master Fund will bear, or reimburse Seven Fleet and/or the General Partner for advancing the expenses of the Funds, including, without limitation, the following: (i) expenses related to the research, execution and monitoring of actual and prospective investments (whether or not consummated) and the consummation of investments, including, without limitation, the following: thirdparty investment sourcing fees; consulting fees; expert fees; fees and expenses of and related to obtaining research, analytics and market data (including, without limitation, third-party data sources and any information technology hardware, software and data subscriptions (such as Bloomberg and FactSet) or other technology incorporated into the cost of obtaining such research and market data); due diligence expenses including, without limitation, consulting and appraisal fees; investment- and research-related travel expenses consistent with Seven Fleet’s travel policy; any outsourced trading provider fees; brokerage and prime brokerage fees, commissions and expenses (including the costs of negotiating, documenting and/or amending agreements with prime brokers, ISDAs and other agreements with trading and financing counterparties); expenses relating to borrowing securities to be sold short; clearing and settlement charges; custodial fees and expenses; bank service fees; interest expenses and other borrowing costs; fees and expenses of proxy research and voting services; broken deal expenses; fees and expenses

of third-party professionals, including, without limitation, consultants, investment bankers, attorneys, accountants and service providers who, in each case, provide services to the Funds or provide services to Seven Fleet, the General Partner or the Principal (on matters that would not have arisen but for their respective advisory relationships with the Funds); and expenses relating to engagement with a company irrespective of the outcome of such engagement, such as shareholder and management communication, soliciting proxies, hiring proxy advisory consultants, hosting shareholder forums, hiring public relations consultants and proposing or nominating directors or executives, including sourcing, recruiting, standby and indemnification and other expenses, regardless of whether the nomination is successful; (ii) organizational fees and expenses and fees and expenses incurred in connection with the offering and sale of interests in the Funds; (iii) operational expenses, including, without limitation, the following: fees and expenses relating to information technology hardware, software or other technology (including, without limitation, costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including, without limitation, reporting obligations) in connection with the activities of the Funds, and facilitate and manage the order execution of securities or otherwise manage the Funds (such as portfolio management systems and order management systems); fees and expenses of third-party risk management products, models and services; third-party administrative fees and expenses, including fees and expenses of the administrator and any middle and/or back office service provider; fees and expenses of third-party professionals, including, without limitation, consultants, valuation service providers, attorneys, accountants and tax preparers; third-party audit and tax preparation expenses; insurance expenses, including, without limitation, premiums for cybersecurity insurance and liability insurance (including directors and officers liability insurance and errors and omission insurance) covering the Funds, the General Partner, Seven Fleet and the principals, directors, officers, employees, managers, partners, members, affiliates or agents of any of the foregoing; fees and expenses associated with director and governance committee meetings and meetings of the Investors as a whole; costs of preparing and distributing reports and notices to Investors (including the development, implementation and maintenance of an investor electronic delivery site and/or system); entity-level taxes; fees and expenses related to compliance with applicable law and regulations in connection with the activities of the Funds, including, without limitation, any governmental, regulatory, licensing, filing, reporting or registration expenses, fees or taxes (including, without limitation, fees and expenses incurred in connection with the preparation and filing of Form PF, Section 13 filings, Section 16 filings and other similar regulatory filings for the Funds or Seven Fleet, the General Partner or the Principal on matters that would not have arisen but for their respective advisory relationships with the Funds, and any filings or reporting with respect to compliance with FATCA, AEOI or similar laws enacted in other jurisdictions, as well as any foreign tax regime registrations, tax filings and associated annual fees and expenses); and any fees and expenses related to compliance with anti-money laundering laws and regulations applicable to the Funds (including AML officer fees and expenses); and (iv) extraordinary expenses, including, without limitation, the following: the costs of any litigation or investigation involving the activities of the Funds (including attorney’s fees and investigative fees and expenses); the cost of settlements and indemnification expenses (including advances thereof) (for clarity, Seven Fleet and the General Partner are authorized to commit the Funds to potential indemnity obligations toward certain counterparties entering into agreements with the Funds for the provisions of services and otherwise); fees and expenses incurred in connection with any tax audit by any U.S. federal, state or local authority, including, without limitation, any related administrative settlement and judicial review; and fees and expenses incurred in connection with the reorganization, restructuring, dissolution, winding-up or termination of any of the Funds. The expenses that are charged to the Other Accounts are determined on a case-by-case basis.

Other Fees and Expenses Seven Fleet may allocate a portion of the capital of the Client Accounts to exchange-traded funds or similar fee-bearing products that are managed by other investment managers. In that case, such Client Accounts generally would be responsible for paying any and all management fees and expenses associated with such products, which would be in addition to those discussed above. General To the extent a Client Account shares trading and other expenses with other Client Accounts managed by Seven Fleet or its affiliates, such Client Account will bear an equitable share of the associated expenses, taking into account its written agreements with such Client Accounts and applicable facts and circumstances, including the relative size of the applicable entity or account, the nature or source of the product or service and the benefits derived from and the extent of use of the product or services. Nonetheless, the portion of an expense that Seven Fleet allocates to a Client Account for a particular product or service might not reflect the relative benefit derived by such Client Account from that product or service in any particular instance. Furthermore, it is possible that under some of Seven Fleet’s advisory contracts it may not require a Client Account to incur certain expenses, despite the fact that such Client Account will receive a benefit in connection with Seven Fleet’s incurrence of such expenses (and in such Seven Fleet will bear the pro rata share of such expense that would otherwise be allocated to such Client Account). Seven Fleet’s expense allocations often depend on inherently subjective determinations, but the expense allocations made by Seven Fleet will be in good faith. However, in all cases, subject to applicable legal, regulatory, contractual or similar restrictions, Seven Fleet will make expense allocation decisions in its sole discretion in good faith. Seven Fleet and its personnel generally can be expected to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of Client Accounts, including benefits and other discounts provided from service providers. For example, airline travel or hotel stays incurred as a Client Account expense typically result in cash rebates, “miles,” “points” or credit in loyalty/status programs, and such benefits and/or amounts will exclusively benefit Seven Fleet and/or such personnel even though the cost of the underlying service is borne by the Client Accounts. The value of such benefits and perquisites will neither be subject to an offset against fees or expenses payable by clients nor will they otherwise be shared with Client Accounts and/or portfolio investments. The Principal serves on the board of directors of certain portfolio companies of the Client Accounts, and in such capacity is reimbursed by such companies for travel costs and other expenses related to attendance at portfolio company board meetings.

As management fees and performance-based compensation are based directly on the net asset value of Client Accounts, Seven Fleet will be subject to a conflict of interest in valuing the assets held in the Client Accounts. To the extent that Seven Fleet is responsible for valuing a Client Account’s assets, Seven Fleet will follow its documented valuation policies in order to mitigate this risk.

The existence of performance-based compensation may create certain conflicts of interest. More specifically, it may create an incentive for Seven Fleet to pursue riskier or more speculative investments, then it would be the case if there were no performance-based fees. Seven Fleet recognizes that it has a fiduciary duty and as such must act in the best interests of its Client Accounts. The specific terms applicable to performance-based fees and allocations may differ among the various Client Accounts. This may result in a conflict of interest when Seven Fleet and its affiliates allocate opportunities among these Client Accounts because there may be an incentive to favor allocations to Client Accounts that have higher performance-based fees and allocations. To avoid such conflict of interest, Seven Fleet will follow documented procedures in allocating opportunities amongst the Client Accounts (as discussed in Item 12 of this Brochure), which would not take into account the performancebased fees and allocations to which such Client Accounts are subject. Notwithstanding the foregoing, there can be no assurance that certain allocation decisions will not directly or indirectly adversely affect the Client Accounts, even if such decisions are made in good faith. Allocations are subject to a significant degree of discretion exercised by Seven Fleet, including, but not limited to, in connection with portfolio rebalancing, investing in new, different or additional investment strategies and in connection with admissions and withdrawals of investors to and from the private investment funds that Seven Fleet manages. Even allocations designed to mitigate conflicts do not eliminate the possibility that an allocation of assets will not adversely affect the Client Accounts. Seven Fleet will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, a Client Account solely because Seven Fleet purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another Client Account if, in Seven Fleet’s reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for such other Client Account. Seven Fleet’s personnel and/or other related persons may invest in one or more of Seven Fleet’s Clients Accounts. In such case, Seven Fleet may have an incentive to favor Client Account(s) in which Seven Fleet has a greater economic interest and/or may have a conflict of interest in allocating investment opportunities among those Client Accounts and other Client Accounts. In order to mitigate these potential conflicts, Seven Fleet will generally follow the documented procedures referenced above.

Investment Strategy Seven Fleet brings technical experience in evaluating the fundamentals of therapeutics companies, including an understanding of biology, clinical trial design, biostatistics, regulatory pathways, and competitive dynamics. Seven Fleet intends to use this experience to generate long and short ideas based on its views of the anticipated outcomes of key events. Since value dislocations are frequent in the biotechnology sector, typical holding periods will range from weeks to months to years, with position size changing based on correction of value dislocations, outcome of events, and/or other factors. The majority of the Client Accounts’ portfolios will include long and short positions of common stock, with options used for risk management or enhancement of returns. The Client Accounts may from time to time make investments in late growth stage private companies. While the Client Accounts intend to primarily invest in U.S. securities, the Client Accounts may from time to time acquire non-U.S. securities. Investment Process Seven Fleet will deploy an investment process that spans three categories of analysis: 1) Technical analysis, including assessment of preclinical and clinical data, clinical need and market opportunity, regulatory risk, manufacturing requirements, and competitive dynamics. 2) Equity analysis, including cash requirements, balance sheet, and trading dynamics. 3) Valuation analysis, which applies a comprehensive framework incorporating elements such as stage, therapeutic modality, and indication to quantify value relative to peers. These three elements are incorporated to seek to analyze the likely outcome of an event, anticipated price movements, and size positions based on the desired risk-reward profile. In advising the Client Accounts, Seven Fleet will typically take long positions if Seven Fleet believes that a company has a depressed valuation relative to peers, a high probability of technical or regulatory success relative to what is being priced into the stock, indications of high strategic or investor interest, and a credible management team. Seven Fleet will typically take short positions in the Client Accounts if Seven Fleet believes that a company has an upcoming catalyst with low probability of success, a weak rationale for the development program based on biology, clinical data, or clinical trial design, and tractable trading dynamics based on volume and short interest. Initial position sizing will be determined by assessing a number of factors, including, without limitation: strength of the fundamental science driving the investment; expected financial risk/reward return profiles; expected time horizon of the investment thesis; factor considerations such as liquidity, short interest and position crowding; and portfolio balances across parameters such as sub-sectors and types of investment. Monitoring of portfolio investments will generally be focused on the risk/reward profile given changing securities prices, and on new data points regarding the key drivers that have been identified for each company.

The development of an investment strategy for the Client Accounts is an ongoing process. The strategies, techniques and methods described above will therefore be modified by Seven Fleet over time. There is no limitation on the investment strategies, techniques, methods or processes that Seven Fleet may adopt for the Client Accounts or the factors that Seven Fleet may consider in analyzing investments for the Client Accounts. Depending on conditions and trends in securities markets and the economy generally, Seven Fleet may pursue other objectives, or employ other strategies, techniques, methods or processes, that it considers appropriate and in the best interests of the Client Accounts, without notice to, or the consent of, investors. Summary of Material Risks There can be no assurance that Seven Fleet’s investment objective in managing the Client Accounts will be achieved, and that the Client Accounts will not incur losses. Each Investor is also encouraged to consult with Seven Fleet to review the specific risk parameters of, and assets that comprise, the Client Accounts’ portfolio at any given time and from time to time. The risk factors described below are not intended to be an exhaustive listing of all potential risks associated with an investment in the Client Accounts. Investment and Trading Risks. All securities investments risk the loss of capital. Seven Fleet believes that the investment program and Seven Fleet’s research techniques will mitigate this risk through a careful selection of securities and other financial instruments; however, no guarantee or representation is made that the investment program will be successful or that the Client Accounts will not incur losses. The investment program may utilize investment techniques including, but not limited to, trading in put and call options, the use of leverage and short sales, which in practice can, in certain circumstances, increase the adverse impact to which the Client Accounts may be subject. In certain transactions, the Client Accounts may not be “hedged” against market fluctuations or, in reorganization or liquidation situations, may not accurately value the assets of the subject company or the degree of legal and regulatory risk associated with investments in the securities of companies in such situations. This can result in losses, even if the proposed transaction is consummated. Seven Fleet will attempt to assess the foregoing risk factors, and others, in determining the extent of the position it will take in the relevant securities and the price it is willing to pay for such securities; however, such risks cannot be eliminated. Investment Analysis. When assessing investment opportunities, Seven Fleet relies on resources that may have limited or incomplete information. In particular, Seven Fleet relies on publicly available information and data filed with various government regulators or made directly available to Seven Fleet by the issuers of securities or through sources other than the issuers. Although Seven Fleet expects that it will evaluate information and data as it deems appropriate and will seek independent corroboration when reasonably available, Seven Fleet will not evaluate all publicly available information and data and cannot confirm the completeness, genuineness or accuracy of the information and data that it evaluates. As a result, there can be no assurance that the due diligence exercise carried out by Seven Fleet will reveal or highlight all relevant facts that may be necessary or helpful in evaluating investment opportunities. Any failure to have identified the relevant facts may result in an inappropriate investment decision, which may have a material adverse effect on the value of any investment in the Client Accounts. Concentration of Investments. Subject to any limitations adopted by Seven Fleet from time to time, the Client Accounts are not restricted in the amount of their capital that they may commit to any issuer or security, and at times the Client Accounts may hold a relatively large concentration in a limited number of issuers or securities. Losses incurred in connection with those investments could have a material adverse effect on the Client Accounts’ overall financial condition. This is because the value of the Client Accounts’

investment portfolios will be more susceptible to any single occurrence affecting one or more of those issuers or securities than would be the case with a more diversified investment portfolio. In addition, because the Client Accounts invest solely in the biotechnology sector, poor performance of such sector will have a greater effect than if the Client Accounts invested in a wide variety of sectors. Investing in Biotechnology Companies. Many of the biotechnology companies in which Seven Fleet may invest on behalf of the Client Accounts are in a developmental stage and will have little or no revenue, and the value of such companies will be largely dependent upon their research and development (R&D) pipelines. Accordingly, the value of such investments will especially be affected by problems related to product development, testing, regulatory compliance, manufacturing, sales and marketing capabilities and competition. Moreover, any time a biotechnology company is developing a new drug, there is significant uncertainty around both the ultimate costs and expenses that will be incurred and the time it will take a company to bring the drug to market, if the drug is brought to market at all (which itself is a significantly uncertain proposition). In addition, biotechnology companies are affected by general trends related to the demand for health-related products and services as well as the uncertainty of the results of clinical trials and approval of their products by the Food and Drug Administration (the “FDA”) or a foreign equivalent. Biotechnology product development is heavily regulated by the FDA and other agencies and a very small percentage of the biotechnology products developed are approved for sale by the FDA or a foreign equivalent. Even if approved, there can be no assurance that the products will be commercially successful. The success of the biotechnology companies will depend, among other factors, on their ability, and the ability of any licensors, to obtain and maintain patent protection for their products and technologies and to preserve trade secrets. There can be no assurance that patents licensed to companies will be valid or will afford companies protection against competitors with similar technologies. The enforcement of patent rights may require costly litigation. The introduction of new drugs and medical devices can be subject to potential product liability risks which are inherent in the testing, manufacturing, marketing and sale of such drugs and medical devices. Product liability insurance for the biotechnology industry is expensive, if available at all, and no assurance can be given that any company in which the Client Accounts invest will have adequate insurance coverage or that a product liability claim would not have a material adverse effect on such company. General Risk of Investing in the Biotechnology Sector. Investing in securities and other instruments of company in the biotechnology space involves substantial risks, including, but not limited to: certain companies in the Client Accounts’ portfolios may have limited operating histories; scarcity of management and marketing personnel with appropriate scientific or medical training may slow or impede companies’ growth; the possibility of lawsuits related to patents or products; obsolescence of products; change in government policies; changing investor sentiments and preferences with regard to the sector investments (some of which are generally perceived as risky) may have an adverse effect on the price of underlying securities; volatility in the U.S. stock markets affecting the prices of biotechnology company securities may cause the Client Accounts’ performance to experience substantial volatility; and many companies in this sector are subject to extensive government regulation. General Equity Securities Risks. In advising the Client Accounts, Seven Fleet will invest in equity securities. Equity securities fluctuate in value in response to many factors, including the activities, results of operations and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic environments. In addition, events such as epidemics, pandemics, political instability, terrorism and natural disasters may be unforeseeable and contribute to market volatility in ways that may adversely affect the Client Accounts’ positions. Small to Medium Capitalization Companies. In advising the Client Accounts, Seven Fleet may invest their assets in the stocks of companies with small- to medium-sized market capitalizations. While Seven

Fleet believes these investments often provide significant potential for appreciation, these stocks, particularly smaller-capitalization stocks, involve higher risks in some respects than do investments in stocks of larger companies. For example, prices of such stocks are often more volatile than prices of largecapitalization stocks. Smaller companies often lack management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, due to thin trading in some such stocks, an investment in these stocks may be more illiquid than that of larger capitalization stocks. Securities of Growth Companies. In advising the Client Accounts, Seven Fleet will invest in securities of companies in their growth stage. Growth stocks are typically more volatile than value stocks due to their relatively high valuations and sensitivity to investor perceptions of the issuer’s growth potential. As a result, the price of growth equities may experience a larger decline on a forecast of lower earnings or other negative development than would a value stock or the market average in general. Certain growth companies may have more limited product lines or markets and may be less financially secure than more established companies. If a product fails or there are other adverse developments, or if management changes, the company may lose substantial value, especially for smaller growth companies. PIPE Investing. In advising the Client Accounts, Seven Fleet will make private placement investments in public companies (“PIPEs”) from time to time. These are typically securities issued pursuant to Regulation D under the Securities Act to “accredited investors” such as the Client Accounts. The issuer’s common stock is publicly traded on a U.S. securities exchange or listed on the over-the-counter market; however, the securities acquired by the Client Accounts (in the case of equity or preferred securities) or the underlying securities (in the case of warrants, options, or convertible securities) are unregistered and subject to re-sale restrictions, but these securities may have registration rights that require the issuer to register them for resale by the Client Accounts following the date of issue. Certain convertible securities issued in these privately negotiated transactions, however, may provide for registration at a date several months in the future. Often, the issuers of PIPEs will have unstable, fluid, or weak financial positions. As a result, PIPE investments made by the Client Accounts may lose some or all their value, which could cause losses to the Client Accounts. PIPE strategies have historically been significantly more likely to be successful during periods of rising equity prices. In such conditions, not only is it easier to liquidate the equity acquired upon conversion of the Client Accounts’ illiquid and restricted securities, but also the equity price may increase from the date of the conversion, increasing the profit of conversion. PIPE investing also involves making capital commitments to issuers without access to traditional capital markets in situations in which the bankruptcy of the issuer could result in a total loss of the investment and thereby result in losses to the Client Accounts. Analysis of the financial condition of each issuer is an important component of determining whether to make any such investment. Investments in Private Companies. In advising the Client Accounts, Seven Fleet may from time to time invest in private companies (i.e., companies without any publicly traded securities). Investments in private companies are subject to various risks, including the illiquidity of the investment being made. The Client Accounts may be unable to sell their interests in a private company because there may be no market for such interests. In addition, when investing in a private company, there is no market efficiency or testing to determine the correct price for interests in the company; therefore, the Client Accounts could pay more for interests in a private company than their intrinsic value. Typically, private companies will have very limited reporting obligations, so there may be limited or no information available to investors regarding, among other things, a private company’s business prospects and results of operations. Private companies frequently have less oversight from independent directors and regulatory agencies and have less seasoned management teams. Convertible Securities. Seven Fleet does not currently intend to invest in convertible securities as part of the investment program but may elect to do so in the future. The market value of convertible securities,

as with all fixed income securities, tends to decline as interest rates increase and, conversely, tends to increase as interest rates decline; however, when the market price of the common stock underlying a convertible security exceeds the conversion price, the convertible security tends to reflect the market price of the underlying common stock. As the market price of the underlying common stock declines, the convertible security tends to trade increasingly on a yield basis and thus, may not decline in price to the same extent as the underlying common stock. If a convertible security held by the Client Accounts is called for redemption, the Client Accounts will be required to permit the issuer to redeem the security, convert it into the underlying stock, or sell it to a third party. Any of these actions could have an adverse effect on the Client Accounts’ ability to achieve their objectives. Leverage. Seven Fleet does not currently intend to use leverage as part of the investment program for the Funds but may elect to do so in the future. Leverage may be obtained by borrowing funds to make trades or by purchasing or entering into derivative instruments that are inherently leveraged, such as swaps, options, futures and forward contracts. With respect to any Client Account that uses leverage, if the interest expense on borrowings were to exceed the net return on the positions acquired with borrowed funds, such Client Account’s use of leverage would result in a lower rate of return than if the Client Account were not leveraged. If the amount of borrowings which a Client Account may have outstanding at any one time is large in relation to its capital, fluctuations in the market value of such Client Account’s portfolio will have a disproportionately large effect in relation to its capital and the possibilities for profit and the risk of loss will therefore be increased. Any gains made with the additional monies borrowed will generally cause the value of such Client Account’s assets to rise more rapidly than would otherwise be the case. Conversely, if the investment performance of the additional monies fails to cover their cost to such Client Account, the value of such Client Account’s assets will generally decline faster than would otherwise be the case. The amount of any borrowing may also be limited by regulations imposed by the Federal Reserve Board or by the availability and cost of credit, as well as due to overall market conditions. If, due to market fluctuations or other reasons, the value of A client Account’s assets should fall below required regulatory or counterparty imposed levels, such Client Account will be required to reduce its debt by selling securities in its long portfolio. Such Client Account may also be unable to carry-out its investment program if it is not able to obtain leverage on reasonable terms. In the case of derivative instruments, because many derivatives are “leveraged,” such instruments provide significantly more market exposure than the money paid or deposited when the transaction is entered into and, thus, a relatively small adverse market movement in the underlying asset can not only result in the loss of the entire investment, but may also expose a Client Account to the possibility of a loss exceeding the original amount invested. In addition, in transactions involving derivative instruments, counterparties and lenders will likely require a Client Account to post collateral to support its obligations. Should the securities and other assets pledged as collateral decline in value, or should brokers increase their maintenance margin requirements (i.e., reduce the percentage of a position that can be financed), such Client Account could be subject to a “margin call” pursuant to which it must either deposit additional funds with the broker or suffer mandatory liquidation of the pledged assets to compensate for the decline in value. In the event of a precipitous drop in the value of pledged securities, such Client Account might not be able to liquidate assets quickly enough to pay off the margin debt or provide additional collateral and may suffer mandatory liquidation of positions in a declining market at relatively low prices, thereby incurring substantial losses. Furthermore, secured counterparties and lenders will generally have the right to sell, pledge, rehypothecate, assign, use or otherwise dispose of collateral posted by such Client Account. This could increase exposure to the risk of a counterparty default since, under such circumstances, such Client Account may be unable to recover the posted collateral promptly or may be unable to recover all of the posted collateral.

Seven Fleet may engage in the trading of options on futures for the account of the Client Accounts, typically for hedging purposes. If Seven Fleet, on behalf of the Client Accounts, buys an option (either to sell or buy a futures contract or commodity), the Client Accounts will be required to pay a “premium” representing the market value of the option. Unless the price of the futures contract or commodity underlying the option changes and it becomes profitable to exercise or offset the option before it expires, the Client Accounts may lose the entire amount of the premium. Hedging Transactions. In advising the Client Accounts, Seven Fleet may use financial instruments, both for investment purposes and for risk management purposes (i) to protect against possible changes in the market value of the Client Accounts’ portfolio resulting from fluctuations in the securities markets and changes in interest rates, (ii) to protect the Client Accounts’ unrealized gains in the value of the Client Accounts’ portfolio, (iii) to facilitate the sale of any such investments, (iv) to enhance or preserve returns, spreads or gains on any investment in the Client Accounts’ portfolio, (v) to hedge the interest rate or currency exchange rate on any of the Client Accounts’ liabilities or assets, (vi) to protect against any increase in the price of any securities the Client Accounts anticipate purchasing at a later date, or (vii) for any other reason that Seven Fleet deems appropriate. The success of Seven Fleet’s hedging strategy in advising the Client Accounts will depend, in part, upon Seven Fleet’s ability to correctly assess the degree of correlation between the performance of the instruments used in the hedging strategy and the performance of the portfolio investments being hedged. Since the characteristics of many securities change as markets change or time passes, the success of the Client Accounts’ hedging strategy will also be subject to Seven Fleet’s ability to continually recalculate, readjust and execute hedges in an efficient and timely manner. While the Client Accounts may enter into hedging transactions to reduce risk, such transactions may result in a poorer overall performance for the Client Accounts than if they had not engaged in such hedging transactions. For a variety of reasons, Seven Fleet may not seek to establish a perfect correlation between the hedging instruments utilized and the portfolio holdings being hedged. Such an imperfect correlation may prevent the Client Accounts from achieving the intended hedge or expose the Client Accounts to risk of loss. Seven Fleet may not hedge against a particular risk because it does not regard the probability of the risk occurring to be sufficiently high as to justify the cost of the hedge, or because it does not foresee the occurrence of the risk. The successful utilization of hedging and risk management transactions requires skills complementary to those needed in the selection of the Client Accounts’ portfolio holdings. Short Sales. A short sale involves the sale of a security that the Client Accounts do not own in the expectation of purchasing the same security (or a security exchangeable therefor) later at a lower price. To make delivery to the buyer, the Client Accounts must borrow the security and the Client Accounts are obligated to return the security to the lender, which is accomplished by a later purchase of the security. When the Client Accounts make a short sale in the United States, they must leave the proceeds thereof with the broker and it must also deposit with the broker an amount of cash or U.S. government or other securities sufficient under current margin regulations to collateralize their obligation to replace the borrowed securities that have been sold. If short sales are effected on a foreign exchange, such transactions will be governed by local law. A short sale involves the risk of a theoretically unlimited increase in the market price of the security that would result in a theoretically unlimited loss to the Client Accounts. The extent to which the Client Accounts will engage in short sales will depend upon the investment strategy and perception of market direction and the value of individual securities. Seven Fleet may engage in short sales on behalf of the Client Accounts as a hedge against potential market declines and/or based on its fundamental analysis of the subject issuers. Call Options. There are risks associated with the sale and purchase of call options. The seller (writer) of a call option which is covered (e.g., the writer holds the underlying security) assumes the risk of a decline in the market price of the underlying security below the purchase price of the underlying security less the premium received, and gives up the opportunity for gain on the underlying security above the exercise

price of the option. If the seller of the call option owns a call option covering an equivalent number of shares with an exercise price equal to or less than the exercise price of the call written, the position is “fully hedged” if the option owned expires at the same time or later than the option written. The seller of an uncovered call option assumes the risk of a theoretically unlimited increase in the market price of the underlying security above the exercise price of the option. The buyer of a call option assumes the risk of losing its entire investment in the call option. Put Options. There are risks associated with the sale and purchase of put options. The seller (writer) of a put option which is covered (e.g., the writer has a short position in the underlying security) assumes the risk of an increase in the market price of the underlying security above the sales price (in establishing the short position) of the underlying security plus the premium received, and gives up the opportunity for gain on the underlying security below the exercise price of the option. If the seller of the put option owns a put option covering an equivalent number of shares with an exercise price equal to or greater than the exercise price of the put written, the position is “fully hedged” if the option owned expires at the same time or later than the option written. The seller of an uncovered put option assumes the risk of a decline in the market price of the underlying security below the exercise price of the option. The buyer of a put option assumes the risk of losing its entire investment in the put option. Foreign Investments. In advising the Client Accounts, Seven Fleet may trade non-U.S. securities and other instruments denominated in non-U.S. currencies and/or traded outside of the U.S., as well as securities and other instruments of companies having substantial profits and/or revenues generated in non-U.S. currencies. Such transactions require consideration of certain risks not typically associated with trading in U.S. securities or other instruments. Such risks include unfavorable currency exchange rate developments, restrictions on repatriation of investment income and capital, imposition of exchange control regulation by the U.S. or foreign governments, 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 U.S., 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. Transaction costs of investing in non-U.S. securities markets are generally higher than in the United States. There is generally less government supervision and regulation of exchanges, brokers and issuers outside the United States than there is in the United States. The Client Accounts might have greater difficulty taking appropriate legal action in non-U.S. courts. Non-U.S. markets also have different clearance and settlement procedures which, in some markets, could at times fail to keep pace with the volume of transactions, thereby creating substantial delays and settlement failures that could adversely affect the Client Accounts’ performance. Derivatives Generally. Derivative instruments, or “derivatives,” include options, futures, swaps, structured securities and other instruments and contracts that are derived from, or the value of which is related to, one or more underlying securities, financial benchmarks, financial assets, currencies or indices. Derivatives allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark, financial asset, currency or index at a fraction of the cost of investing in the underlying asset. The Client Accounts may seek to acquire derivatives for these or other reasons, however, there is no assurance that derivatives that the Client Accounts wish to acquire will be available at any particular times upon satisfactory terms or at all. The value of a derivative is frequently difficult to determine and depends largely upon price movements in the underlying asset; therefore, many of the risks applicable to trading the underlying asset are also applicable to derivatives of such asset. There are a number of other risks associated with derivatives trading. For example, because many derivatives are “leveraged,” and thus provide significantly more market exposure than the money paid or deposited when the transaction is entered into, a relatively small adverse market movement in the underlying asset can not only result in the loss of the entire investment,

but may also expose the Client Account to the possibility of a loss exceeding the original amount invested. Over-the-counter (“OTC”) derivatives generally are not assignable except by agreement between the parties concerned, and no party or purchaser has any obligation to permit such assignments. The OTC market for derivatives is relatively illiquid. In the case of OTC derivatives contracts, the Client Accounts are subject to the credit risk of the counterparty. Seven Fleet 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 the trading objective of the Client Accounts and legally permissible. Special risks may apply to instruments that are invested in by the Client Accounts in the future that cannot be determined at this time. Risk of Default or Bankruptcy of Third Parties. In advising the Client Accounts, Seven Fleet may engage in transactions in securities and financial instruments that involve counterparties. Under certain conditions, the Client Accounts could suffer losses if a counterparty to a transaction were to default or if the market for certain securities and/or financial instruments were to become illiquid. In addition, the Client Accounts could suffer losses if there were a default or bankruptcy by certain other third parties, including brokerage firms and banks with which the Client Accounts do business, or to which securities have been entrusted for custodial purposes. Counterparty Risk. Some of the markets in which the Client Accounts effect transactions are “over-thecounter” or “interdealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange based” markets. This exposes the Client Accounts to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether bona fide) or because of a credit or liquidity problem, thus causing the Client Accounts to suffer a loss. Such “counterparty risk” is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Client Accounts have concentrated their transactions with a single or small group of counterparties. Seven Fleet is not restricted from dealing with any particular counterparty or from concentrating any or all its transactions with one counterparty. Seven Fleet’s ability to transact business with any one or number of counterparties, the lack of any meaningful and independent evaluation of such counterparties’ financial capabilities and the absence of a regulated market to facilitate settlement may increase the potential for losses by the Client Accounts. The investment strategy requires use of transactions that expose the Client Accounts to the credit of its counterparties, and vice versa. For example, the Client Accounts will seek to borrow securities intending to sell them short and may enter into long and short derivative positions. All these transactions, and transactions similar to them, are governed by documents, industry standards, market customs and practices, the parties’ prior course of dealing and by the covenant of good faith and fair dealing. At times, and especially in times of market stress, these credit exposures may come under stress, normal business conduct may be interrupted, and normal legal protections may prove inadequate or may fail to provide timely relief. Should it become necessary to remove or reduce exposure to a particular counterparty, there can be no guarantee that a satisfactory alternative will be available, or even if one is available, that the Client Accounts will be able to avail themselves of that alternative. Consequently, it is possible that any unwinding of the credit exposure may prove costly and thereby damage the Client Accounts. Currency Risks. In advising the Client Accounts, Seven Fleet may invest in securities and other instruments denominated or quoted in currencies other than the U.S. Dollar, as well as securities and other instruments of companies having substantial profits and/or revenues generated in non-U.S. currencies. In connection therewith, Seven Fleet may hedge against the resulting currency exposure wherever economically prudent; however, changes in currency exchange rates and/or erosion of non-U.S. currencies will affect the value of the Client Accounts’ portfolio and the unrealized appreciation or depreciation of investments. Additionally, such hedging transactions may include a credit component

pursuant to which the Client Accounts may be required to grant to their hedging counterparty(ies) a security interest in certain of its assets. Accordingly, in such a case, if the Client Accounts default with respect to a currency hedging transaction, then the hedging counterparty could lay claim to an interest in such assets. Further, the Client Accounts may incur costs in connection with conversions between various currencies. Foreign 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 Client Accounts at one rate, while offering a lesser rate of exchange should the Client Accounts desire immediately to resell that currency to the dealer. The Client Accounts will conduct their currency exchange transactions on a spot (i.e., cash) basis at the spot rate prevailing in the currency exchange market. The Client Accounts may also take speculative positions in currencies, which will be subject to the same risks discussed above. Purchasing Securities of Initial Public Offerings. In advising the Client Accounts, Seven Fleet may purchase securities of companies during their initial public offerings or shortly thereafter. Special risks associated with these securities may include a limited number of shares available for trading, unseasoned trading, lack of investor knowledge of the companies and limited operating histories. These factors may contribute to substantial price volatility for the shares of these companies. The limited number of shares available for trading in some initial public offerings may make it more difficult for the Client Accounts to buy or sell significant amounts of shares without an unfavorable impact on prevailing market prices. In addition, some companies engaged in initial public offerings are involved in relatively new lines of business, which may not be widely understood by investors. Some of these companies may be undercapitalized or regarded as developmental stage companies, without revenue or operating income, or the near-term prospects of achieving them. Price Risk. For reasons not necessarily attributable to any of the risks set forth herein (for example, supply/demand imbalances or other market forces), the prices of the securities in which the Client Accounts invest may decline or rise substantially. Purchasing assets at prices that may appear to be “undervalued” is no guarantee that such assets will not be trading at even more “undervalued” levels at the time of valuation or at the time of sale. Similarly, shorting assets at prices that may appear to be “overvalued” is no guarantee that such assets will not be trading at even more “overvalued” levels at the time of valuation or at the time of sale. Inflation Risk. Due to a convergence of different economic factors, including scarcity of workers, pentup demand and insufficient supply, inflation has recently hit a 30-year high. High inflation may undermine the performance of the Client Accounts’ investments by reducing the value of such investments and/or the income received from such investments, especially with respect to fixed income instruments and growth stocks. Rising inflation is also expected to lead to general market uncertainty and therefore could impact all types of investments made by the Client Accounts. Further, there is no guarantee that the Client Accounts will have positive performance even in, or especially in, environments of sharply rising inflation, and there is no guarantee that the Client Accounts will be able to successfully mitigate inflation risk or that interest rates will match changes in inflation rates. Purchase of Distressed Securities. In advising the Client Accounts, Seven Fleet may purchase securities and other obligations of companies that are experiencing significant financial or business distress, including companies involved in bankruptcy, reorganization or other liquidation proceedings. Although such investments may produce significant returns to the Client Accounts, they involve a high degree of risk over a potentially lengthy time period and may provide less liquidity than many other investments. There can be no assurance that Seven Fleet will accurately predict various factors that could affect the prospects of a successful restructuring, and many of these investments ordinarily remain stagnant until the applicable

company reorganizes and/or emerges from bankruptcy proceedings, so they may have to be held for an extended period of time. Special Situations. In advising the Client Accounts, Seven Fleet 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 such special situations, there exists the risk that the contemplated transaction either will be unsuccessful, take considerable time or result in a distribution of cash or a new security the value of which will be less than the purchase price to the Client Accounts 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, the Client Accounts may be required to sell their investment at a loss. Because there is substantial uncertainty in investments involving financially troubled companies, there is a potential risk of loss of the Client Accounts’ entire investment in such companies. Event and Risk Arbitrage. An event and risk arbitrage position is generally taken after a merger, tender offer, exchange offer or other transaction is announced, at which point the security has generally risen to a significant premium over the market price that prevailed prior to the announcement. The difference between the price paid by the Client Accounts for securities of a company involved in an announced deal and the anticipated value to be received for such securities upon consummation of the proposed transaction will often be small. If the proposed transaction appears likely not to be consummated or, in fact, is not consummated or is delayed, the market price of the securities will usually decline sharply, usually to a level comparable to or below that which existed prior to the announcement and generally by more than the Client Accounts’ anticipated profit. Further, the Client Accounts may invest and trade in securities of companies which, although they are not the subject of an announced proposed merger or acquisition, are viewed as potential candidates for such a transaction. Either of these scenarios (nonconsummation of an announced deal or non-consummation of an anticipated unannounced deal) can cause the Client Accounts to suffer a significant loss with respect to any long positions that it has established in the relevant security. Similarly, with respect to any short positions, to the extent such positions have to be covered, the Client Accounts could be adversely affected. Various events may occur which may result in a transaction not being consummated which could adversely affect the Client Accounts’ position. Exchange Traded Funds (“ETFs”). In advising the Client Accounts, Seven Fleet may trade in ETFs. ETFs are generally structured to invest in all or a representative sample of the securities that generally replicate the price and yield performance of an underlying market index or sector such as a broad stock market, industry sector, domestic or international equity or fixed income, or U.S. or foreign government bond. ETF shares are traded on stock exchanges and markets at open market prices that generally track the net asset value per share of the ETF. Direct issuances and redemption of ETF shares at the ETF’s net asset value per share only occur in large blocks (or creation units) transacted between the ETF and authorized institutional purchasers on an in-kind basis. An exchange traded sector fund may be adversely affected by the performance of that specific sector or group of industries on which it is based. International investments may involve risk of capital loss from unfavorable fluctuations in currency values, differences in generally accepted accounting principles, or economic and/or political instability in other nations and/or other factors. Although index-based ETFs are designed to provide investment results that generally correspond to the price and yield performance of their respective underlying indices, ETFs may not be able to replicate exactly the performance of the indices because of their expenses and other factors. ETF shares may trade at either a discount or premium to their underlying net asset value. The purchase or sale of ETF shares on the secondary market involves the payment of brokerage commissions, and the purchase and redemption of creation units involves other transaction costs and brokerage commissions. Investors in ETFs also directly bear the ETF’s costs associated with its payment of investment management fees and fees for administrative, custodial or other services and thus the Investors will indirectly incur an additional layer of fees and expenses.

Loans of Securities; Pledge of Assets. Pursuant to master securities lending agreements or similar agreements, the Client Accounts may lend securities from their portfolios to brokers, dealers and financial institutions and receive collateral in the form of cash and securities in an amount equal to or greater than the current market value of the loaned securities, including any accrued interest or dividend receivable. During the term of such loan, the Client Accounts will not retain all incidents of beneficial ownership as to the loaned portfolio securities, including voting rights. They will, however, generally retain the rights to interest or other distributions, and will have the right to regain record ownership of the loaned securities to exercise such beneficial rights. Such loans will be terminable at any time upon sufficient notice to the other party. It should be noted that, pursuant to the account agreement with prime brokers, the prime brokers may, under certain circumstances, lend the Client Accounts’ securities to third parties without notice and without providing any collateral to the Client Accounts. If a prime broker were to become insolvent in the United States, the Client Accounts would not have a claim against any specific assets of such prime broker but would have a claim against the pool of assets held for the benefit of such prime broker’s customers. Jurisdictions outside of the United States may not provide any similar rights to the Client Accounts. Herding Risk. The substantial growth of the hedge fund industry and funds trading large highly leveraged positions of the same nature as those held by other funds have augmented herding risks. While Seven Fleet typically strives not to invest, on behalf of the Client Accounts, in securities and/or other instruments that are broadly followed by other funds, such funds may later discover opportunities in the same securities and/or other instruments in which the Client Accounts have already invested. Whatever the “fair price” of a security, instrument or a relationship, its trading price is sometimes radically altered or influenced by the market activity of traders executing parallel trading programs. This factor may cause surprising and sudden losses at unpredictable times, even after long periods of calm. The negative impact of herding is greatest when markets are under stress and traders holding large leveraged positions seek to liquidate or cover positions simultaneously. Alternative Data Risk. Seven Fleet employs so-called “alternative data,” which generally refers to data that is not the traditional exchange or accounting data that has been widely used by the mainstream investment industry. Risks associated with alternative data include the possibility of new legal and regulatory frameworks targeting the collection and use of the data or technological changes that may make the data less useful or available. There is also the possibility that the organizations providing alternative data may cease operations, change business models, or suffer temporary outages due to technical issues. Insider trading and “fair practice” laws are generally untested in this area. Investment decisions based on alternative data may be flawed for various reasons, such as incomplete, “dirty” or misunderstood data, or problems with the technology used to collect and analyze it. Inside Information. From time to time, Seven Fleet and its affiliates may come into possession of inside information concerning specific companies. In particular, the Principal could come into possession of inside information in their capacities as board members of several companies in the biotechnology space, or through their continued employment with Longitude Capital Management Co., LLC. Under applicable securities laws, this may limit the Client Accounts’ ability to buy or sell securities of a particular company if Seven Fleet has inside information regarding such company. If the Client Accounts hold the securities of a company with respect to which Seven Fleet is in possession of inside information, the Client Accounts may be restricted from trading the securities of such company for an indefinite period of time, which could result in losses to the Client Accounts. Significant Positions; Shareholder Activism. In advising the Client Accounts, Seven Fleet may take significant positions in portfolio companies that result in the Client Accounts acquiring (i) five percent (5%) or more of a class of securities of a single issuer which would require the filing of a Schedule 13D or 13G statement with the SEC, or (ii) ten percent (10%) or more of a class of securities of a single issuer

(which would impose certain limitations on the Client Accounts’ ability to trade in such securities, including the restrictions of Section 16 of the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”)). At times Seven Fleet may engage in proxy contests on behalf of the Client Accounts, takeover bids, shareholder class actions or other litigation, or other activity which may place the Client Accounts in a high-profile position which is adverse to issuer management and/or other security holders. The Client Accounts may, because of such techniques or otherwise, obtain a controlling or other substantial position in any public or private company. The Client Accounts may become subject to regulatory proceedings or other litigation. At various times, Seven Fleet may agree with unrelated third parties to coordinate investments in activist positions. If any such third parties suffer damage to their reputation, the Client Accounts may also incur damage to their reputation because of the group association. Seven Fleet may agree with such parties not to purchase and/or sell the applicable securities or related securities without the consent of such parties and may agree with such parties to vote or not to vote such securities in a certain manner. This may result in the Client Accounts being unable to engage in certain transactions when Seven Fleet would otherwise deem it desirable to do so. Under U.S. law, the formation of a “group” may result in the Client Accounts being deemed to own in excess of ten percent (10%) of an issuer’s securities even when each Client Account’s position itself is less than ten percent (10%), thereby resulting in “short swing” transaction reporting and potential forfeiture obligations. The Client Accounts’ ability to realize value from certain of its positions may depend upon the ability of Seven Fleet to influence the management of a portfolio company to take certain actions, including, for example, recapitalization, restructuring, spin-off, sale of the business or change in management. If Seven Fleet is incorrect in its assessment of the impact such action will have on the value of the portfolio company, or if it is unsuccessful in persuading the portfolio company’s management to take the desired action, the Client Accounts may sustain a loss. Litigation Risk. Seven Fleet may seek to participate substantially in, and to influence substantially, the conduct of the management of companies in which the Client Accounts invest. Seven Fleet may designate directors (and non-executive chairmen) to serve on the boards of directors of issuers. In some cases, the trading program may result in the Client Accounts taking an activist position with respect to an issuer. For example, Seven Fleet may challenge issuer actions that Seven Fleet believes will have an adverse impact upon the value of a class of such issuer’s securities. In such a case, either the issuer itself, or other market participants with positions adverse to that of the Client Accounts, may institute litigation against the Client Accounts challenging their activist conduct. Alternatively, Seven Fleet may initiate litigation as a tool to further activist goals, and such litigation may precipitate counterclaims. Litigation, even if successful, is often expensive. Unsuccessful litigation could result in losses to the Client Accounts. Changes and Uncertainty in U.S. and International Regulation. Seven Fleet and the Client Accounts may be adversely affected by uncertainties such as international and domestic political developments, changes in government policies, taxation, restrictions on foreign investment and currency repatriation, currency fluctuations and other developments in the laws and regulations of the countries to which the Client Accounts’ assets are exposed through their investments or investor base. During this period of uncertainty, market participants may react quickly to unconfirmed reports or information and as a result there may be increased market volatility. This unpredictability could cause Seven Fleet to alter investment and trading plans, including the holding period of positions and the nature of instruments used to achieve the Client Accounts’ investment objectives. Market Disruption Events and Geopolitical Risks. In advising the Client Accounts, Seven Fleet may trade in different markets and different instrument types. It is possible that because of war, terrorist act, natural disaster, outbreak of infectious disease, epidemic, pandemic, or other serious public health

concern, or geopolitical or other extraordinary or unforeseen circumstance or event (a “Market Disruption Event”), one or more of these markets may cease operating for a limited or indeterminable time period. In that event, it may be difficult for Seven Fleet to value the positions that trade in the affected markets, and Seven Fleet and the Client Accounts may be exposed to significant movements in the perceived value of instruments without having the ability to trade those instruments. Additionally, Market Disruption Events may have a substantial effect on economies and securities markets in the U.S. or worldwide and could materially adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of the Client Accounts’ investments. Market Disruption Events could also affect the principal prime brokers and custodians that carry and clear the Client Accounts’ trades and positions. The inability of key marketplace intermediaries to function could have an adverse impact upon liquidity as well as the ability of the Client Accounts to trade its positions. Market Disruption Events could also have a direct physical impact upon Seven Fleet’s and/or the Client Accounts’ operations, including the destruction of their facilities and/or incapacity or loss of life to key personnel. While Seven Fleet has taken steps intended to mitigate the adverse consequences that could arise from the occurrence of a Market Disruption Event, the inability to predict the timing, location, source and severity of such event or events make it difficult to provide assurances that Seven Fleet and/or the Client Accounts would not suffer material adverse consequences should a Market Disruption Event occur. Regulatory Uncertainty. It is expected that the current U.S. administration will seek to enact changes to numerous areas of law and regulations currently in effect. Any such changes could significantly impact the Client Accounts and their investments. Specific legislative and regulatory proposals discussed during election campaigns and recent public statements that might have a material impact include, without limitation, changes to trade agreements, immigration policy, import and export regulations, tariffs and customs duties, energy regulations, income tax regulations and the federal tax code, and antitrust enforcement. Changes in federal policy are subject to further uncertainty, as changes could be implemented at regulatory agencies over time through policy and personnel changes, which lead to changes involving the level of oversight and focus on the financial services industry or the tax rates paid by corporate entities. The nature, timing and economic effects of potential changes to the current legal and regulatory framework affecting financial institutions under the current presidential administration remain highly uncertain. It is possible that future changes will adversely affect Seven Fleet and the Client Accounts and their investments. Trade Policy. The U.S. government has announced tariffs on imports from Mexico, Canada and China, as well as the implementation of reciprocal tariffs with respect to countries around the globe. Such tariffs have the potential to gravely impact markets, global supply and demand, import/export policies, and the availability of labor in certain markets, and there is no guarantee that additional tariffs or similar measures will not be implemented. This could seriously impact Seven Fleet’s and the Client Accounts’ operations. Artificial Intelligence (AI). Seven Fleet may use AI in its business operations, including facilitating investment research, trading decisions and portfolio constructions, and the challenges with properly managing its use could result in reputational harm, competitive harm, and legal liability, and/or an adverse effect on Seven Fleet’s business operations. If the content, analyses, or recommendations that AI applications assist Seven Fleet in producing are or are alleged to be deficient, inaccurate, or biased, the Client Accounts may be adversely affected. Additionally, AI tools Seven Fleet uses may produce inaccurate, misleading or incomplete responses that could lead to errors in Seven Fleet’s decision-making, portfolio management or other business activities, which could have a negative impact on the performance of the Client Accounts. Such AI tools could also be used against Seven Fleet or the Client Accounts and its investments in criminal or negligent ways. Seven Fleet’s competitors or other third parties could incorporate AI into their products more quickly or more successfully, which could impair Seven Fleet’s ability to compete effectively. Legal and regulatory changes, particularly those related to information

privacy and data protection, may have an impact on AI, and may additionally impact Seven Fleet and the Client Accounts. Reliance on Seven Fleet’s Investment Professionals. The success of Seven Fleet and the Client Accounts will depend in large part upon the skill and expertise of Seven Fleet’s investment professionals. Although Seven Fleet believes that the success of Seven Fleet and the Client Accounts is not dependent upon any one investment professional at Seven Fleet, there can be no assurance that any of the investment professionals will continue to be associated with Seven Fleet. Systems Risk. The Client Accounts depend on Seven Fleet to develop and implement appropriate systems for their activities. Seven Fleet relies heavily on computer programs and systems (and may rely on new systems and technology in the future) for various purposes in connection with its activities on behalf of its investors, including, without limitation, to trade, clear and settle transactions, to evaluate certain financial instruments, to monitor its portfolio and net capital, and to generate risk management and other reports that are critical to oversight of such investors’ activities. Certain of Seven Fleet’s and the Client Accounts’ activities will be dependent upon systems operated by third party service providers, and Seven Fleet may not be in a position to verify the risks or reliability of such third-party systems. The failure, corruption or breach of one or more systems (including as a result of the occurrence of a disaster such as a cyberattack, a natural catastrophe, an industrial accident, a terrorist attack or war, events unanticipated in Seven Fleet’s disaster recovery systems, or a support failure from external providers) or the inability of such systems to satisfy investor’s needs may have a material adverse effect on Seven Fleet’s ability to conduct business and thus, the Client Accounts, particularly if those events affect Seven Fleet’s computer-based data processing, transmission, storage and retrieval systems or destroy Seven Fleet’s data. Operational and Information Security Risk from Cyberattacks; Cyber-Fraud; Disaster Recovery. The Client Accounts and their service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cyberattacks affecting the Client Accounts, the General Partner, Seven Fleet, the Funds’ administrator, the Client Accounts’ prime brokers, custodians and other third-party service providers may adversely impact the Client Accounts. Similar types of cybersecurity risks are also present for other market participants, which may have material adverse consequences for the Client Accounts, and may cause the Client Accounts’ investments to lose value. The Client Accounts may also be the targets of cyber-fraud that could result in the theft of assets, especially as computer malware, viruses and computer hacking, fraudulent use attempts and phishing and spoofing attacks have become more prevalent. In the hedge fund industry, these attacks have included third party actors submitting fraudulent withdrawal and transfer requests, resulting in the theft of the rightful investor’s assets. The Client Accounts and their service providers may incur additional costs relating to cybersecurity preparations, and such preparations, though taken in good faith, may be inadequate. Cyberattacks are viewed as an emerging risk and the scope of the risk and related mitigation techniques are not yet fully understood and are subject to continuing change. While Seven Fleet has put in place certain safeguards in case of disruption of information technology, including transmission failures, there can be no guarantee that such measures will be effective against all situations or will be implemented in time, and the Client Accounts may therefore be adversely affected.

Any such conflict of interest could have a material adverse effect on the Client Accounts (and on Investors in the Funds). However, the existence of an actual or potential conflict of interest does not mean that it will be acted upon to the detriment of any Client Account. When a conflict of interest arises, Seven Fleet will endeavor to ensure that the conflict is resolved fairly and in an equitable manner that is consistent with its fiduciary duties to the relevant Client Account(s). Seven Fleet has in place policies and procedures that it believes are reasonably designed to identify and resolve actual and potential conflicts of interest. However, there can be no assurance that these policies and procedures will be successful in identifying or mitigating all actual or potential conflicts of interest. Affiliated Funds and Other Clients Seven Fleet’s management of its Client Accounts may result in conflicts of interests when Seven Fleet and its related persons allocate time and investment opportunities among its Client Accounts (including Client Accounts in which Seven Fleet or its related persons may be invested). In addition, terms regarding fees and performance-based compensation may differ among Client Accounts. This may result in a conflict of interest when Seven Fleet allocates opportunities among its Client Accounts because Seven Fleet has an incentive to favor Client Accounts that have higher fee and/or performance-based compensation arrangements as well as Client Accounts in which Seven Fleet or its related persons have invested. To avoid such conflicts of interest Seven Fleet generally follows documented procedures in allocating opportunities among such Client Accounts, which do not take into account the fees or performancebased compensation to which such Client Accounts are subject or the investment in such Client Accounts by Seven Fleet or its related persons. Seven Fleet, the General Partner, the Principal and their affiliates may determine, in their sole discretion, to participate in investments with persons not affiliated with the Client Accounts. In addition, Seven Fleet may offer to certain Client Accounts, or to any third party, the opportunity to co-invest in opportunities in which a Client Account has invested or that become available to a Client Account. Seven Fleet may offer such opportunities to investors that Seven Fleet selects in its sole discretion without notice to or the consent of any other Client Account or investor. The economic and other terms of any co-investment will be determined by Seven Fleet in its discretion on a case-by-case basis, and Seven Fleet may receive fees and/or allocations from co-investors, which may differ among co-investors and also may differ from the fees and/or allocations borne by the Client Accounts (or investors in the Funds).

Employment with Another Firm The Principal and Rod Lim are employed by Longitude Capital Management Co., LLC (“Longitude”), a registered investment adviser, and will continue to perform services for Longitude as employees. They will allocate their time, and investment opportunities, among Longitude, and the Client Accounts. Additionally, in connection therewith, the Principal expects to continue to hold board seats with certain private and public companies on behalf of Longitude. Since the Principal and Rod Lim will be Longitude access persons and subject to the Longitude restricted list, there may be investment opportunities that Seven Fleet cannot pursue on behalf of the Client Accounts because such securities are on the restricted list and the Client Accounts may hold securities that Seven Fleet is unable to dispose of if such securities are on the restricted list. In particular, the inability to sell a position as a result of such restricted list could have an adverse effect on the Client Accounts as the Client Accounts may be unable to avoid losses in a position that Seven Fleet believes will depreciate in value or realize gains in a position that Seven Fleet believes will appreciate in value until the position is removed from the restricted list. The Principal’s and Rod Lim’s continued employment with Longitude creates a conflict of interest to the extent Client Account investment opportunities being pursued by the Principal and Rod Lim via Seven Fleet are also investment opportunities for Longitude funds. Seven Fleet may be unable to pursue an investment opportunity as a result of such conflicts and an investment opportunity that is appropriate for the Client Accounts, may be instead offered to one or more Longitude funds; however, the Principal’s services to Longitude will relate to both private and public company investments, including participation in certain transactions involving public companies in the healthcare sector. Potential and actual conflicts of interest are created to the extent that the Principal’s services to Longitude involve public companies that are also within the investment mandate of the Client Accounts. Additionally, while Rod Lim will advise Longitude regarding public and private securities in the healthcare space, his services to Longitude have been and are expected to be more advisory in nature unless Longitude launches a public securities fund structure. If the overlap between Longitude’s and Seven Fleet’s investment activities increases materially in the future, Seven Fleet and Longitude will either adopt additional policies to address applicable conflicts of interest or restructure the dual-employment arrangement. Service Providers Certain advisors and other service providers, or their affiliates, to Seven Fleet and its Client Accounts may also provide services to or have business, personal, familial, political, financial or other relationships with Seven Fleet or its affiliates. Such advisors and service providers may be Seven Fleet’s clients or Investors, sources of investment opportunities for Seven Fleet or Client Accounts, prime brokers and placement agents to Client Accounts, or co-investors with or counterparties to transactions involving the foregoing. These relationships may influence Seven Fleet in deciding whether to select or recommend any such advisor or service provider to perform services for the Client Accounts (the cost of which will generally be borne directly or indirectly by the Client Accounts), and may influence such advisors or service providers to do business with Seven Fleet. Notwithstanding the foregoing, Seven Fleet will generally seek to engage advisors and service providers for Client Accounts on the basis of, without limitation, the overall quality of advice and other services provided. In addition, Seven Fleet has a conflict of interest where a service provider (e.g., legal counsel or accountants) provides services directly to Seven Fleet or one of its affiliates, and separately provides services to one or more Client Accounts, in that Seven Fleet or its affiliates may potentially obtain services at a lower cost (or obtain other terms that are more beneficial) than Seven Fleet or its affiliates otherwise could have as a result of the service provider’s work performed on behalf of, and the compensation paid to the service provider by, such Client Accounts. In particular, unless inconsistent with the applicable written agreement with respect to the Client Account, costs associated with services rendered to the

benefit of a Client Account may be borne by such Client Account. Seven Fleet or its affiliates may use some of the same service providers as are retained on behalf of one or more Client Accounts and, in some cases, fee rates, amounts or discounts may be offered to Seven Fleet or its affiliates by a third-party service provider which differ from those offered to a Client Account as a result of scheduled or ad hoc rate changes, differences in the scope, type or nature of the service or transaction, alternative fee arrangements and negotiation.

Personal Trading The Code permits access persons (generally employees and their immediate family members), upon prior approval from the CCO, to purchase or sell publicly traded securities for their own accounts or accounts that the access person controls or which the access person may be deemed to have beneficial ownership (such as an account of a spouse or minor child). Seven Fleet generally prohibits access persons from trading in securities that largely comprise the investable universe of the Client Accounts. Access persons are permitted to buy and sell private securities (such as investments in hedge fund, private equity funds and private companies) with prior approval. Access persons are also permitted to invest in mutual funds and U.S. and non-U.S. government issued obligations without prior approval. In addition, Seven Fleet may permit access persons to maintain accounts that are managed on a discretionary basis by a third party if the access person has no direct or indirect influence or control over the investments for the account. Seven Fleet employees are required to disclose their personal securities holdings on an initial and annual basis, and their personal securities transactions quarterly, which requirements are designed to address potential conflicts of interest that might interfere or appear to interfere with making decisions in the best interest of the Client Accounts. Gifts and Entertainment, Political Activities and Outside Activities

The Code provides that gifts and entertainment must be reasonable considering industry practices and should never be given or received if the purpose is to influence the recipient. Seven Fleet 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 for the selection of Seven Fleet as an investment adviser for a governmental equity. 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. Participation or Interest in Client Account Transactions Seven Fleet, the Principal and employees do not purchase or sell any securities for their own accounts to or from the Client Accounts. However, subject to the investment guidelines and restrictions of the Client Accounts, Seven Fleet may effect rebalancing or internal cross transactions. In such cases, Seven Fleet may determine that it would be in the best interests of a Client Account and one or more other Client Accounts to transfer a security from one Client Account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including tax purposes, liquidity purposes, to rebalance the portfolios of the Client Accounts, or to reduce transaction costs that may arise in an open market transaction. If Seven Fleet decides to engage in a Cross Trade, Seven Fleet will determine that the trade is in the best interests of both Client Accounts involved and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those accounts. If Seven Fleet were to execute Cross Trades, it might be with the assistance of a broker-dealer that executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a cross transaction between two Client Accounts may occur as an “internal cross,” where Seven Fleet instructs the custodian for the accounts to book the transaction at the price determined in accordance with Seven Fleet’s valuation policy. If Seven Fleet effects an internal cross, Seven Fleet will not receive any fee in connection with the completion of the transaction. In the event that Seven Fleet effects a Cross Trade between an account in which it or its controlling persons own more than twenty five percent (25%) and another Client Account, such transaction may be deemed to be a principal transaction under the Advisers Act. Such transactions may create a conflict of interest for Seven Fleet because Seven Fleet may put its or its control persons’ interests in such accounts before the interests of its clients in the other account. In order to mitigate this conflict of interest, Seven Fleet monitors the interests of its principals, their immediate family members and their affiliates in Client Accounts, and will not effect any cross trades between accounts if Seven Fleet believes that such trade would result in a principal transaction unless: 1) Seven Fleet believes that such transaction is in the best interest of the clients participating in the transaction; and 2) Seven Fleet obtains the consent of the applicable Client Account as required by the Advisers Act. 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 Account transactions. Seven Fleet 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. Investors may also contact Seven Fleet via email or telephone to request information about Seven Fleet’s Code.

Subject to best execution, in selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services, Seven Fleet may consider, among other factors that are deemed appropriate to consider under the circumstances, the following: the ability of the brokers and dealers to effect the transaction; the brokers’ or dealers’ facilities, reliability and financial responsibility; and the provision by the brokers of capital introduction, talent introduction, marketing assistance, consulting with respect to technology, operations and equipment, commitment of capital, access to company management and access to deal flow. Accordingly, the prices and commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Client Accounts by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Seven Fleet need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Seven Fleet nor the Client Accounts separately compensate any broker or dealer for any of these other services. Seven Fleet maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Soft Dollar Usage From time to time, Seven Fleet pays a broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transactions) for effecting Client Account transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. Seven Fleet will effect such transactions, and receive such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). Seven Fleet believes it is important to its investment decision-making processes to have access to independent research. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by a Client Account may be used by Seven Fleet to service one or more other Client Accounts, including accounts that may not have paid for the soft dollar benefits. Seven Fleet will not seek to allocate soft dollar benefits to Client Account(s) in proportion to the soft dollar credits the Client Account(s) generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to Seven Fleet (i.e., a “mixed use” item), Seven Fleet will make a good faith allocation of the cost which

may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest may exist because of Seven Fleet’s allocation of the costs of such benefits and services between those that primarily benefit Seven Fleet and those that primarily benefit the Client Account(s). When Seven Fleet uses brokerage commissions (or markups or markdowns) generated by any Client Account to obtain research or other products or services, Seven Fleet receives a benefit because it does not have to produce or pay for such products or services. While Seven Fleet is obligated to seek best execution for each Client Account, the fact that Seven Fleet can obtain or receive such products or services may create an incentive for it to select or recommend a particular broker-dealer based on Seven Fleet’s interests, to the exclusion of another broker-dealer that offers business terms that are also favorable to one or more Client Accounts. At least annually, Seven Fleet considers the amount and nature of research and research services provided by broker-dealers, as well as the extent to which such services are relied upon and attempts to allocate a portion of the brokerage business of its Client Accounts on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation but can (and often does) exceed the suggested level, because total brokerage is allocated on the basis of all the considerations described above. In no case will Seven Fleet make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. Additionally, brokers may provide Seven Fleet and the Client Accounts with capital introduction services, talent recruitment, and front and back office services, including trading, securities lending, clearing, reporting, and settlement for equities, fixed income, foreign currency and options, among others. Brokerage for Client Referrals Subject to applicable law, Seven Fleet may direct some client brokerage business to brokers who refer prospective investors to the Funds, consistent with best execution. Because such referrals, if any, are likely to benefit Seven Fleet but will provide an insignificant (if any) benefit to Investors and Other Accounts, Seven Fleet has a conflict of interest when allocating client brokerage business to a broker who has referred Investors to Seven Fleet. To prevent client brokerage commissions from being used to pay investor referral fees, Seven Fleet will not allocate client brokerage business to a referring broker unless Seven Fleets determines in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to the Client Account. Trade Aggregation and Allocation Policies and Procedures and Aggregation of Orders Seven Fleet intends to execute trades and investments in the Client Accounts. It is Seven Fleet’s policy to allocate investment opportunities to the Client Accounts on a fair and equitable basis, to the extent practical and in accordance with the Client Accounts’ applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those accounts for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: whether the risk-return profile of the proposed investment is consistent with an account’s objectives, the potential for the proposed investment to create an imbalance in an account’s portfolio, the liquidity requirements of an account, potentially adverse tax consequences, regulatory

restrictions that would or could limit an account’s ability to participate in a proposed investment, and the need to re-size risk in an account’s portfolio. Seven Fleet will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, a Client Account solely because Seven Fleet purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another Client Account if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for the other Client Account(s). When a Client Account is ramping up its investment or trading strategies, it may receive larger allocations of certain securities than the other Client Accounts to obtain its desired risk and portfolio size and the other Client Accounts may receive less. Seven Fleet will generally aggregate client trades, subject to best execution. Aggregation, or “bunching,” describes a procedure whereby an investment adviser combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. Aggregation opportunities for Seven Fleet generally arise when more than one Client Account is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. In such event, securities purchased or sold will generally be allocated among Client Accounts on an average price basis. If an aggregated order is only partially filled, securities will be allocated among the Client Accounts as described in the paragraphs above. When orders are not aggregated, trades generally will be processed in the order that they are placed with the broker or counterparty selected by Seven Fleet. As a result, certain trades in the same security for one Client Account (including a Client Account in which Seven Fleet and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another Client Account, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved. Trade Errors Trade errors involving transactions in any account directly or indirectly held by the Client Accounts or any derivatives contract or other similar agreement of the Client Accounts and/or any trading vehicle (each, a “Trade Error”) may occur. Trade Errors include the placement of orders (either purchases or sales) in excess of, or less than, the amount of securities the account intended to trade; the sale of a security when it should have been purchased; the purchase of a security when it should have been sold; the purchase or sale of the wrong security; and the purchase or sale of a security for the wrong account and the post-settlement discovery of such purchase or sale. Trades implemented because of faulty data, systems, coding, modeling or analysis, trades that are properly executed but result in losses, errors committed by other persons (including brokers and custodians), or that are otherwise caused by human error other than those specifically described above, are not considered Trade Errors. The loss of an investment opportunity is not considered a Trade Error. Such errors may result in losses or gains. Seven Fleet will use reasonable efforts to detect such errors prior to settlement and promptly correct them. To the extent that an error is caused by a counterparty, such as a broker-dealer, Seven Fleet will use reasonable efforts to recover any losses associated with such error from the counterparty. Pursuant to the exculpation and indemnification provided by the Client Accounts to Seven Fleet and its affiliates and personnel, Seven Fleet and its affiliates and personnel will generally not be liable to the Client Accounts for any act or omission, absent willful misconduct or gross negligence (and absent a violation of law with respect to a particular Other Account) of such person (the “carve outs”), and the Client

Accounts will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Client Accounts, subject to such carve outs. As a result of these provisions, the Client Accounts (and not Seven Fleet) will benefit from any gains resulting from Trade Errors and other errors and will be responsible for any losses (including additional trading costs) resulting from Trade Errors and other errors, subject to the carve outs. Seven Fleet will reimburse the Client Accounts for losses for which Seven Fleet is responsible under the exculpation provisions. Seven Fleet faces a potential conflict of interest because, should a trade error occur, generally Seven Fleet (and not an independent third party) would be the party that determines whether such trade error resulted from Seven Fleet’s willful misconduct or gross negligence (or violation of law if applicable). However, notwithstanding this potential conflict of interest, in all cases, Seven Fleet would make such determination in good faith. Given the potentially large volume of transactions executed by Seven Fleet on behalf of the Client Accounts, Investors should assume that Trade Errors and other errors will occur and that, to the extent permitted by applicable law and under each Client Account’s respective governing documents, the Client Accounts will be responsible for any resulting losses, even if such losses result from the negligence (but not gross negligence, willful misconduct or, in certain cases, a violation of law) of Seven Fleet’s personnel. Third Party Trading Seven Fleet uses a third-party trader to execute certain trades. When using a third-party trader, Seven Fleet may select a specific broker that the third party-trader must use to execute the trade in question. Seven Fleet’s decision to instruct the third-party trader to use a specific broker (or otherwise) is subject to the broker selection criteria described above.

Seven Fleet may enter into agreements (“side letters”) with one or more Investors in the Feeder Funds that result in investment terms that differ from the terms applicable to other Investors, including, without limitation, with respect to fees, performance-based fees or allocations, and/or withdrawal terms. In addition, pursuant to side letters, Seven Fleet may provide particular Investors with more frequent and/or more detailed information regarding a Fund’s positions, performance, finances, and management and/or other information about such Fund or Seven Fleet (including, notification of senior employee departures, the commencement of disciplinary actions, legal proceedings, investigations or similar matters, or redemptions from the Funds by Seven Fleet, its affiliates and/or its respective personnel), possibly enabling such Investors to better assess the prospects and performance of the Funds. As a result of such side letters, certain Investors may receive additional rights and/or information that other investors will not necessarily receive. Subject to applicable law and contractual arrangements, Seven Fleet does not intend to disclose the terms of side letter agreements or other arrangements and does not intend to disclose the identities of the Investors that have entered into such agreements with the Funds or Seven Fleet.

Seven Fleet will not be required to offer such additional or different rights and terms to any or all other Investors. Seven Fleet may provide certain additional information to any Investor, or prospective investor, in a Fund (or to any of Other Accounts clients) who requests such information. This information may be provided in response to questions and requests and in connection with due diligence meetings and other communications, but will not distributed to other Investors and prospective investors (or Other Account clients) who do not request such information. Such information may affect a decision to invest, and Investors (which may include Seven Fleet personnel, affiliates and/or related persons) and Other Account clients who receive such additional information may be able to act on such additional information and redeem their investments potentially at higher values than other Investors (or Other Account clients). Each Investor and Other Account client is responsible for asking such questions that it believes are necessary in order to make its own investment decisions and must decide for itself whether the limited information provided by Seven Fleet is sufficient for its needs. Seven Fleet may provide Investors/Other Accounts with reports in such forms and at such times as such Investors/Other Accounts and Seven Fleet may agree. The custodians of the Other Accounts send account statements to the owners of the accounts no less frequently than quarterly. In addition, since a client that is an Other Account directly owns the positions in the Other Account, such client has full, real-time transparency as to all transactions and holdings in its account, and may be better able to assess the future prospects of a portfolio that may have significant overlap with the portfolios of the Funds, especially with respect to long positions. The Other Account clients generally have the right to withdraw all or a portion of their capital from their accounts on shorter notice and/or with more frequency than the terms applicable to an investment in the Funds.

The referral arrangements described above involve potential conflicts of interest because the placement agent may have an incentive to favor sales of interests/shares in the Funds (or setting up a separately managed account) over recommendations of other investment products for which the agent will receive no or lower fees. Prospective and existing investors should consider this potential conflict of interest when evaluating any recommendation or referral by an agent regarding an investing with Seven Fleet.

In accordance with Rule 206(4)-2, the Funds’ cash and securities are maintained with one or more qualified custodians. Seven Fleet may change the custodians at any time and from time to time without the consent of, or notice to, investors. Qualified custodians do not provide statements directly to investors in the Funds. Seven Fleet does not have custody over the Other Accounts. The qualified custodian selected by the Other Accounts will typically provide these clients with at least quarterly account statements relating to the assets held within the Other Accounts. These clients should carefully review the qualified custodian’s statement upon receipt to determine that it completely and accurately states all holdings in the Other Account and all account activity over the relevant period. Any discrepancies identified by an Other Account should be immediately reported to Seven Fleet and the qualified custodian.

Specifically, Seven Fleet monitors the potential for conflicts of interest that might arise from personal relationships that Seven Fleet or its employees may have with parties involved in the vote, significant Investor or the Client Account relationships with those parties, and other unusual circumstances. Seven Fleet will vote proxies as it deems necessary or appropriate, on a case-by-case basis. Prior to voting, the CCO will determine whether the conflict is material to the vote and will either resolve the conflict or refer the proxy vote to an outside service for its independent consideration.

There may be times (which may be frequent) when Seven Fleet is authorized to vote proxies for a Client Account and determines that refraining from voting is in the best interest of that Client Account. For example, Seven Fleet may refrain from voting a Client Account proxy when (without limitation): (i) the economic effect on shareholder’s interests or the value of the portfolio holding is indeterminable or insignificant; (ii) voting the proxy would unduly impair the investment management process; or (iii) the cost of voting the proxies outweighs the benefits or is otherwise impractical. In addition, Seven Fleet may abstain from voting a proxy on behalf of a Client Account due to (1) de minimis holdings; (2) de minimis impact on the portfolio; (3) contractual arrangements with Client Accounts; (4) their authorized delegates or the failure of a proxy to provide sufficient information to allow for informed decision making; and/or (5) items relating to non-U.S. issuers. To the extent that Seven Fleet has discretion to participate in class action lawsuits filed against companies or issuers in which the Client Accounts are invested, Seven Fleet will generally participate in such class action lawsuits unless it believes that such participation is not in the best interest of the Client Accounts. Note that the Principal currently votes proxies for certain positions held by Longitude Capital’s funds; however, Seven Fleet has determined that this does not currently pose a material conflict of interest with its own Client Accounts, given differences in the investment mandates of Seven Fleet’s Client Accounts and Longitude’s funds. Should such a conflict arise in the future, Seven Fleet will determine, with the assistance of counsel and its compliance consultant, as necessary, the appropriate course of action to resolve such conflict. Investors may also contact Seven Fleet via e-mail or telephone to request a copy of Seven Fleet’s proxy voting policy.