Aquamarine Financial (Cayman) Ltd: investment adviser

Aquamarine PTC (“Aquamarine PTC”) is the sole trustee of the Star Trust. Eduardo D’Angelo P. Silva is the sole director of Aquamarine PTC and David Mungall is the sole supervisor of Aquamarine PTC. The primary purpose of the Star Trust is to hold the shares of Aquamarine so as to maintain the ownership and control of Aquamarine. Since Eduardo D’Angelo P. Silva and David Mungall also serve as the independent directors of Aquamarine as further described below, the present organizational structure of Aquamarine may give rise to certain potential and actual conflicts of interest. For further details regarding these conflicts, please see the Risks Relating to the Organizational Structure of Aquamarine under Item 8. Aquamarine has entered into a director services agreement with Zedra Trust Company (Cayman) Limited (“Zedra”) under which Zedra is providing the directors to Aquamarine. Zedra is not responsible for the day-to-day operations of Aquamarine, the commercial structuring of the business of Aquamarine or for the provision of investment, commercial, accounting, legal, tax or any other advice to Aquamarine. The directors, being independent directors, are not involved in the day-to-day operations of Aquamarine but retain ultimate responsibility for the governance of Aquamarine. If a director ceases to be employed by Zedra or resigns for whatever reason, Zedra shall nominate a suitable individual to replace that director. The directors of Aquamarine are currently David Mungall and Eduardo D'Angelo P. Silva. The directors are registered directors with CIMA. Registered directors are natural persons appointed as directors of fewer than 20 covered entities. In the Cayman Islands, the same directors may serve on several boards for multiple companies, and this does not indicate that the entities themselves are related, nor does it imply shared ownership, control or operational integration. The overlap is solely as a result of the directors’ independent roles and not due to any affiliation among the entities. As such, the directors of Aquamarine serve on boards for multiple companies, but there is no control or ownership link between Aquamarine and any such other company, and Aquamarine is in no way affiliated with any such other company.

Advisory Services Aquamarine offers a wealth of resources to assist and support clients so they can achieve their financial objectives. Aquamarine's investment objective is to provide suitable income returns and capital appreciation through investments in a combination of different fixed income securities, equity assets and real estate, with particular attention to European and Latin American markets. Risk factors will be considered and monitored on an individual basis. See Item 8 below. Aquamarine has experience in identifying undervalued opportunities across a broad range of asset categories and markets, and has developed, and intends to continue to develop, proprietary sourcing and servicing channels across these categories and markets. Separately Managed Accounts Aquamarine currently manages four separately managed accounts on behalf of institutional clients and may manage additional separately managed accounts in the future (each, a “Managed Account” and collectively, the “Managed Accounts”). Aquamarine tailors the advisory services it provides to meet the needs and objectives of its Managed Account clients and seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Aquamarine consults with clients on an initial and ongoing basis to determine various factors relevant to the management of their portfolios.

Pooled Investment Vehicles Aquamarine currently manages three pooled investment vehicles and may manage additional pooled investment vehicles in the future (each, a “Fund” and collectively, the “Funds”). Each Fund is organized and incorporated in a country other than the United States. Aquamarine Credit Fund Ltd., a Cayman Islands exempted company (the “Credit Fund”), is the only Fund that Aquamarine currently offers to investors domiciled in the United States. The Credit Fund was subsequently registered with CIMA as a Regulated Mutual Fund under the Mutual Funds Act (Revised) of the Cayman Islands on 7 June 2022. Wrap Fee Programs Aquamarine does not participate in wrap fee programs. Assets Under Management As of December 31, 2025, Aquamarine had $5,761,492,014 in assets under management on a discretionary basis. Aquamarine has sole investment discretion and is authorized to make all investment decisions and to direct the execution of all transactions for the client's account (subject to the investment objectives, guidelines and restrictions that a client may impose on an account) without consulting the client in connection with each transaction.

Credit Fund Aquamarine provides discretionary investment management services to the Credit Fund, which is not registered under the Investment Company Act of 1940, as amended (the “1940 Act”), and whose interests are not registered under the Securities Act of 1933, as amended (the “Securities Act”). The Credit Fund’s offering documents include information about the fees and expenses paid by the Credit Fund.

Management Fee: For discretionary investment management services to the Credit Fund, Aquamarine receives, from the Credit Fund’s assets, a fixed advisory fee payable monthly in arrears equal to 0.125% (1.5% on an annualized basis) of the net asset value of each series of shares of the class shares as of the last calendar day of each month before giving effect to any redemptions occurring as of such day. These management fees are negotiable and may vary for different Credit Fund investors. The management fee structures described herein may be modified from time to time and may vary by each class of shares of the Credit Fund. Fees may differ among investors in the Credit Fund. Performance Fee: Aquamarine also receives a performance fee from the Credit Fund as discussed in Item 6. Aquamarine, in its sole discretion, may waive or reduce all or any portion of the management fee and/or the performance fee for any reason. The management fee and/or the performance fee may also be shared by Aquamarine with any other person in the sole discretion of Aquamarine. Other Expenses: The Credit Fund bears all of the expenses incident to its operations and business, including, without limitation, (i) investment-related expenses (e.g., brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees, loan closing costs, and interest expenses) and other trading-related expenses; (ii) operating expenses (e.g., trade clearance and settlement, corporate action processing, trade confirmation, pricing services, portfolio management reporting software and reconciliation); (iii) directors’ and officers’ fees and expenses and related insurance costs; (iv) interest on balances due and any other fees and charges of prime brokers, financial counterparties, banks. and custodians; (v) any income taxes, withholding taxes, transfer taxes, and other governmental charges and duties imposed on or payable by the Credit Fund; (vi) the Credit Fund’s ongoing legal, accounting, regulatory, compliance and consultants fees and disbursements; (vii) fees and out-of-pocket expenses of the administrator and any custodian; (viii) any fees and expenses associated with the organization and conduct of the Board of Directors’ (as defined below) and shareholders’ meetings and the preparation and distribution of all of its shareholders’ reports and other communications with shareholders; (ix) any fees and expenses associated with maintaining the Credit Fund’s registered office in the Cayman Islands; (x) litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Credit Fund’s business; and (xi) management and performance fees payable to the Investment Manager and other expenses described in the investment management agreement. Expenses are allocated pro rata among each class of shares. A fixed organizational charge for the Credit Fund was amortized over a period of sixty (60) months from the date that the Credit Fund commenced operations.

Further details on organizational expenses and operating expenses are included in the Credit Fund’s offering documents, including the Amended and Restated Confidential Memorandum of the Credit Fund. Managed Accounts Management Fees: For discretionary investment management services to Managed Accounts, Aquamarine typically charges management fees generally ranging from 0.25% to 0.5%, which are typically based on the Managed Account’s net asset value of assets under management. These management fees are negotiable, accrue monthly in arrears, and are billed quarterly. Profits Allocation: Aquamarine also receives a profits allocation from certain Managed Accounts as discussed in Item 6. Different fees may be charged for Managed Accounts and Aquamarine may receive a different profit allocation for Managed Accounts, in each case, depending on the investment advisory services being provided by Aquamarine. Other Expenses: To the extent set forth and agreed to in an agreement, certain Managed Accounts will bear certain operating and other expenses associated with their Managed Account.

unrealized appreciation in the net asset value of a series of shares in excess of the average annualized CME Term SOFR 3-Month Index (the “3-Month SOFR”) on a risk-adjusted basis plus 250 basis points for the financial year in respect of which the performance fee is being calculated (source: CME Group website or another recognized source – it being noted that (a) CME Term SOFR Reference Rates provide an indication of the forward-looking measurement of overnight SOFR, based on market expectations implied from derivatives markets; and (b) the Secured Overnight Financing Rate (SOFR) is a broad measure of the cost of borrowing cash overnight collateralized by Treasury securities) (the “Benchmark”). If the 3-Month SOFR is no longer published or no longer deemed a representative cash index, Aquamarine, in consultation with the board of directors of the Credit Fund (the “Board of Directors”), shall use its best endeavours to determine, in

good faith, an alternative index against which to measure the Benchmark. If a shareholder of the Credit Fund redeems all or a part of its shares prior to the last calendar day of the fiscal year, the performance fee is calculated and then paid to Aquamarine at the time of such redemption with respect to shares that are redeemed. The “Prior High NAV” of a series of shares of the Credit Fund is the net asset value of that series immediately following the date as of which the last year-end performance fee was determined with respect to such series (or, if no performance fee has yet been determined with respect to such series, the net asset value of that series immediately following its initial offering). The Prior High NAV of a series of shares will be adjusted for redemptions from such series. The Credit Fund’s offering documents include information about the performance fee. In addition, as noted above, Aquamarine receives a profits allocation from certain Managed Accounts, generally up to 15% of realized and/or unrealized gains. Such performance-based fees and profit allocations may create potential conflicts of interest because Aquamarine manages, or may manage in the future, clients with such fee arrangements side-by-side with clients that Aquamarine charges a fixed fee only based on assets under management, including that Aquamarine (and its supervised persons) have an incentive to favor accounts where Aquamarine receives a performance-based fee. Please see Item 10, “Other Financial Industry Activities and Affiliations” and Item 11, “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” for a discussion of the conflicts and risks associated with side-by-side management and how Aquamarine addresses these matters.

Silva and Mungall would face a direct conflict between their duties at Aquamarine PTC and their board-level duties at Aquamarine. While the Star Trust, Aquamarine PTC, and Aquamarine are legally separate entities, there may be actual or potential conflicts of interest if Aquamarine PTC’s trustee decisions benefit the Star Trust or Aquamarine PTC at the expense of Aquamarine. These entities, including Aquamarine, believe that they have proper governance and clear separation of roles, which are designed to mitigate these risks. Trust Purpose vs. Aquamarine Interest. The Star Trust's primary purpose is to maintain ownership and control of Aquamarine. This mandate can conflict with business decisions that would benefit Aquamarine but require changes to the trust's ownership position. If Aquamarine needs to raise capital or otherwise dilute the Star Trust's 100% stake, or if a strategic merger would transfer control to another party, the directors of Aquamarine might favor the transaction on business grounds while Aquamarine PTC might not favor such a transaction for the Star Trust. Messrs. Silva and Mungall would be making decisions on behalf of Aquamarine PTC and as directors of Aquamarine, and there is no independent party positioned to weigh the Star Trust's interests separately from Aquamarine's interests. Risk in Director Replacement. Zedra provides the independent directors to Aquamarine and can nominate replacements. However, since Messrs. Silva and Mungall also hold positions at Aquamarine PTC, which is the trustee of the Star Trust, the sole shareholder of Aquamarine, Messrs. Silva and Mungall may influence who Zedra nominates as directors of Aquamarine. As such, Messrs. Silva and Mungall may have influence over their own replacement or continuation, which may create certain significant conflicts of interest. Zedra’s Limited Role. The director services agreement with Zedra provides a mechanism for providing directors and nominating replacement directors, if necessary. However, Zedra is expressly not responsible for operational management, commercial structuring, or advisory functions. Its role is limited to providing directors and nominating replacements, if necessary. Zedra does not in any way serve as an independent governance check on the substance of decisions made by Messrs. Silva and Mungall.

Use of Cayman Islands Independent Directors. Aquamarine utilizes the services of independent professional directors in the Cayman Islands. It is customary practice in the Cayman Islands for the same independent directors to serve simultaneously on the boards of directors (or equivalent governing bodies) of multiple unaffiliated entities. The fact that a director of Aquamarine also serves as a director of one or more other entities does not, in and of itself, indicate that Aquamarine is related to, affiliated with, or under common ownership or control with any such other entity. The overlap in directorships is solely a function of the directors’ independent professional roles and does not reflect any organizational, economic, or operational integration among the entities on whose boards such directors serve. The use of shared independent directors gives rise to potential and actual conflicts of interest. A director who serves on multiple boards may owe fiduciary or analogous duties to each entity on whose board that director sits, and situations may arise in which the interests of one entity conflict with or diverge from the interests of another entity sharing the same director. While Cayman Islands regulatory requirements and customary governance practice require disclosure, recusal, and management of such conflicts, there can be no assurance that all conflicts will be identified or satisfactorily resolved in every instance, or that the resolution of a conflict will be in the best interest of Aquamarine. Independent directors who serve on numerous boards may have limited time and attention to devote to the affairs of any single entity. Although Cayman Islands regulatory standards applicable to regulated entities require directors to devote sufficient time to their roles and to maintain adequate knowledge of each entity's business, the breadth of a director's commitments may, as a practical matter, limit the depth of oversight and engagement the director can provide to Aquamarine. Investors should be aware that the directors of Aquamarine are not exclusively dedicated to its affairs. Independent directors are not employees of Aquamarine and may resign or be removed at any time. The loss of one or more directors, or the inability to replace a director in a timely manner, could disrupt governance, or delay decision-making at Aquamarine. Methods of Analysis and Investment Strategies Aquamarine seeks to provide high income returns and capital appreciation to the Credit Fund and Managed Accounts through investments in a combination of different fixed income securities and equities, with particular attention to Latin American and European markets, although investment may also be made in or relation to other related markets, taking into account factors such as the credit quality of issuers, changes in and levels of interest rates, projected economic growth rates, volatility, capital flows, debt levels, liquidity, trends in inflation, anticipated movements in foreign currency and governmental initiatives. Aquamarine seeks to achieve the Credit Fund’s investment objective primarily through (a) purchases of corporate, sovereign and quasi sovereign debt securities; (b) investments in loans; and (c) assetbased investments, including portfolios of consumer and commercial receivables and assetbacked financial instruments of undervalued or financially troubled companies. Aquamarine may hold such positions directly or may indirectly hold such positions by entering into one or

more swaps, options, forward contracts or similar derivative transactions, including, among others, credit default swaps. Investment targets may include: (i) out-of-favor sectors where the Credit Fund or a Managed Account can acquire investments at a significant discount to the fundamental value of their underlying cash flow or assets; (ii) companies undergoing, or considered likely to undergo, reorganizations under local bankruptcy laws; (iii) companies initiating debt restructuring, reorganization and/or liquidation outside of bankruptcy; and (iv) companies facing a broad range of liquidity issues. Aquamarine has substantial experience in identifying undervalued situations across a broad range of asset categories and markets, and has developed, and intends to continue to develop, proprietary sourcing and servicing channels across these categories and markets. Risk of Loss AQUAMARINE’S INVESTMENT STRATEGIES INVOLVE A HIGH DEGREE OF BUSINESS AND FINANCIAL RISK THAT CAN RESULT IN SUBSTANTIAL LOSSES AND ARE SUITABLE ONLY FOR INVESTORS PREPARED TO BEAR SUCH RISK. THE RISKS FACTORS BELOW ARE NOT INTENDED TO BE EXHAUSTIVE FOR THE CREDIT FUND OR ANY SEPARATELY MANAGED ACCOUNT. PROSPECTIVE CLIENTS SHOULD ALSO CAREFULLY REVIEW THE RISKS DESCRIBED IN THE APPLICABLE CLIENT’S GOVERNING DOCUMENTS: There can be no assurance that the investment objective of the Credit Fund will be achieved or that the investment strategies of the Credit Fund or any Managed Account will be successful, and certain investment practices can, in some circumstances, potentially increase the adverse impact on the Credit Fund’s or a Managed Account’s investment portfolio. The nature of the Credit Fund’s or a Managed Account’s investments involves certain risks and the Credit Fund or a Managed Account will utilize investment techniques (such as leverage, short selling and the use of derivatives) that carry additional risks. An investment in the Credit Fund or a Managed Account’s investments carries substantial risk and is suitable only for persons that can assume the risk of losing their entire investment. The risk factors below for the Credit Fund may also be applicable to a Managed Account client and should be carefully considered by any Managed Account client before entering into a separately managed account with Aquamarine. The particular risks applicable to a Managed Account will depend on the nature of the account, its investment strategy or strategies and the types of securities the account holds. Any Managed Account client is responsible for appropriately diversifying its assets to help guard against the risk of loss. Note that diversification does not assure a profit or protect against loss in a declining market. Operating History. Any prior performance of the principals of the Investment Manager is not necessarily indicative of results that may be achieved with respect to the Credit Fund. As such,

there can be no assurances that the Credit Fund will be able to implement its investment strategy or achieve its investment objective. Dependence on the Investment Manager. The success of the Credit Fund is significantly dependent upon the ability of the Investment Manager to develop and effectively implement the Credit Fund’s investment objective. Investors will be relying entirely on the Investment Manager to conduct and manage the affairs of the Credit Fund. Subjective decisions made by the Investment Manager may cause the Credit Fund to incur losses or to miss profit opportunities on which it would otherwise have capitalized. Because specific investments of the Credit Fund have not yet been identified, the shareholders must rely on the ability of the Investment Manager to make appropriate investments and investment decisions for the Credit Fund. Limited Liquidity. An investment in the Credit Fund is suitable only for sophisticated investors who do not need liquidity with respect to their investment. An investment in the Credit Fund provides limited liquidity. Shares of the Credit Fund are not freely transferable, and a shareholder generally may only redeem its shares in accordance with the limitations described in the governing documents of the Credit Fund. Further, the Board of Directors, after consultation with the Investment Manager, may declare a suspension (generally or in respect of a specific class or classes of shares) of the determination of net asset value of the Credit Fund and/or the subscription and/or the redemption of shares and/or the payment of redemption proceeds in certain circumstances as set out in the governing documents of the Credit Fund. There is currently no market for shares of the Credit Fund, and it is not contemplated that one will develop. The Credit Fund’s shares offered have not been registered under the securities laws of any jurisdiction and, therefore, cannot be resold unless they are subsequently registered under applicable securities laws or an exemption from registration is available. It is not contemplated that registration of the Credit Fund’s shares under any jurisdiction’s securities laws will ever be effected. In-Kind Distributions. The Credit Fund expects to distribute cash to a shareholder upon a redemption. However, there can be no assurance that the Credit Fund will have sufficient cash to satisfy redemption requests, or that the Credit Fund will be able to liquidate investments at the time of such redemption requests at favorable prices. Under the foregoing circumstances, and in consultation with the Investment Manager, and under other circumstances deemed appropriate by the Credit Fund, a shareholder may receive inkind distributions from the Credit Fund. A Class or Series of Shares is not a Separate Legal Entity. As among the shareholders, the appreciation and depreciation attributable to a class or series of shares will be allocated only to such class or series. Similarly, expenses attributable solely to a particular class or series of Shares will be allocated solely to that class or series. However, a creditor of the Credit Fund will generally not be bound to satisfy its claims from a particular class or series of shares. Rather, such creditor generally may seek to satisfy its claims from the assets of the Credit Fund as a whole. Thus, if a creditor’s claims relating to a particular class or series of

shares exceed the net capital attributable to that class or series, the remaining capital of the Credit Fund may be subject to such claim. Thus, for example, if the assets attributable to a class or series of shares participating in a “new issue” were completely depleted by losses or liabilities, a creditor could enforce a claim against the assets of the Credit Fund which would be borne by the other classes or series of shares that did not participate in the investment or transaction. In addition, to facilitate investments or financing, the Credit Fund may guarantee certain obligations of one or more special purpose vehicles. In such circumstances, all of the assets of the guarantor generally will be available to satisfy the guaranty obligation. Such arrangements may expose the Credit Fund to an increased risk of loss. Increased Regulatory Oversight. The financial services industry generally, and the activities of hedge funds and their managers in particular, have been subject to intense and increasing global regulatory scrutiny. Such scrutiny may increase the Credit Fund’s and/or the Investment Manager’s exposure to potential liabilities and to legal, compliance, and other related costs. Increased regulatory oversight can also impose administrative burdens on the Investment Manager, including, without limitation, responding to investigations and implementing new policies and procedures. Such burdens may divert the Investment Manager’s time, attention, and resources from portfolio management activities. Business and Regulatory Risks of Hedge Funds. Legal, tax, and regulatory changes could occur during the term of the Credit Fund that may adversely affect the Credit Fund. The regulatory environment for hedge funds is evolving, and changes in the regulation of hedge funds may adversely affect the value of investments held by the Credit Fund or the Credit Fund’s ability to pursue certain trading strategies. In addition, the securities markets are subject to comprehensive statutes, regulations, and margin requirements. Regulators, selfregulatory organizations, and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivatives transactions and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial action. The effect of any future regulatory change on the Credit Fund could be substantial and adverse. Investment and Trading Risks. An investment in the Credit Fund involves risks, including the risk that the entire amount invested may be lost. The Credit Fund invests in and actively trades securities and other financial instruments using investment techniques with risk characteristics, including risks of the bond, convertible securities, and equity markets, the risks of borrowings and short sales, the potential illiquidity of securities and other financial instruments and the risk of loss from counterparty defaults. No guarantee or representation is made that the Credit Fund’s investment program will be successful or that its investment objectives will be met. The Credit Fund may utilize such investment techniques as option transactions, margin transactions, short sales, leverage, and derivatives trading, which may create or increase volatility and can increase the adverse impact to which the Credit Fund’s investment portfolio may be subject.

Counterparty Risk. Some of the markets in which the Credit Fund may affect transactions are not “exchanged-based,” including “over-the-counter” or “interdealer” markets. The participants in such markets are typically not subject to the credit evaluation and regulatory oversight to which members of “exchange-based” markets are subject. The lack of evaluation and oversight of overthe-counter markets exposes the Credit Fund 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 or not bona fide) or because of a credit or liquidity problem (“counterparty risk”), thus causing the Credit Fund to suffer a loss. Counterparty risk is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Credit Fund has concentrated its transactions with a single or small group of counterparties. The Credit Fund generally is not restricted from dealing with any particular counterparty or from concentrating any or all of its transactions with one counterparty. Moreover, the Credit Fund’s internal credit functions which evaluate the creditworthiness of its counterparties may not prove sufficient. The lack of a comprehensive evaluation of the creditworthiness of the Credit Fund’s counterparties and the absence of a regulated market to facilitate settlement may increase the potential for losses by the Credit Fund. Systemic Risk. Credit risk may arise through a default by one of several large institutions that are dependent on one another to meet their liquidity or operational needs, so that a default by one institution causes a series of defaults by the other institutions. This “systemic risk” may adversely affect financial intermediaries, such as clearing agencies, clearing houses, banks, securities firms, and exchanges, with which the Credit Fund interacts on a daily basis. Diverse Investor Group. The shareholders may have conflicting investment, tax, and other interests with respect to their investments in the Credit Fund. The conflicting interests of individual shareholders may relate to or arise from, among other things, the nature of investments made by the Credit Fund, the structuring or the acquisition of investments and the timing of disposition of investments. As a consequence, conflicts of interest may arise in connection with decisions made by the Investment Manager that may be more beneficial for one shareholder than for another shareholder, especially with respect to any shareholder’s individual tax situations. In selecting and structuring investments appropriate for the Credit Fund, the Investment Manager will consider the investment and tax objectives of the Credit Fund as a whole and not its shareholders individually. Long-Term Nature of Investment in the Credit Fund. An investment in the Credit Fund requires a long-term commitment with no certainty of return. Because of the nature of the Credit Fund’s investment programs, there can be no assurance that the Credit Fund will be able to realize returns on its investments in a timely manner or at all. It is uncertain as to when profits, if any, will be realized. Losses on unsuccessful investments may be realized before gains are realized on successful investments. The return of capital and realization of gains, if any, from an investment in the Credit Fund may not occur until a number of years after an investment is made, if at all.

Costs Related to Investing in the Fund. Shareholders will bear, through their investment in the Credit Fund, the fees and expenses charged to or indirectly borne by the Credit Fund, including the management fee, transaction-related, operating and other expenses of the Credit Fund, and the performance fee. In the aggregate, these fees and expenses can be substantial and adversely affect the value of any investment in the Credit Fund. Generally, any ancillary fees paid to, or related income earned by, the Investment Manager and its affiliates will not reduce the Management Fee or the Performance Fee. Performance Based Fee. The Credit Fund will pay to the Investment Manager a performance fee based upon net realized and unrealized appreciation in the net asset value of each series of shares. This compensation arrangement may create an incentive for the Investment Manager to make investments that are riskier or more speculative than would be the case if such compensation arrangement were not in effect. In addition, since the performance fee is calculated on a basis which includes unrealized appreciation of the Credit Fund’s assets, it may be greater than if such compensation were based solely on realized gains. Systems Risks. The Credit Fund depends on the Investment Manager to develop and implement appropriate systems for the Credit Fund’s activities. The Credit Fund and the Investment Manager rely extensively on computer programs and technology information and communications systems (and may rely on new systems and technology in the future) for various purposes including, without limitation, to trade, clear and settle securities transactions, to evaluate certain investments based on real-time information, to monitor its portfolio and net capital, and to generate risk management and other reports that are critical to oversight of the Credit Fund’s activities. In addition, certain of the Credit Fund’s and the Investment Manager’s operations interface will be dependent upon systems operated by third parties, including prime brokers, the administrator of the Credit Fund (the “Administrator”), market counterparties and their sub-custodians and other service providers, and the Investment Manager may not be able to verify the risks or reliability of such third-party systems. These programs or systems may be subject to certain limitations, including, but not limited to, those caused by computer “worms,” viruses, security breaches, cyber-attacks, and power failures. The Credit Fund’s operations are highly dependent on each of these systems and the successful operation of such systems is often out of the Credit Fund’s or the Investment Manager’s control. The failure of one or more systems or the inability of such systems to satisfy the Credit Fund’s new or growing businesses could have a material adverse effect on the Credit Fund. For example, systems failures could cause settlement of trades to fail, lead to inaccurate accounting, recording, or processing of trades, and cause inaccurate reports, which may affect the ability of the Credit Fund to monitor its investment portfolio and risks. Additionally, any system failure, security breach or cyber-attack on the Investment Manager or the Credit Fund, or any of their service providers, could cause the Investment Manager and/or the Credit Fund to suffer, among other things, financial loss, disruption to its business including its trading capabilities, and the ability of the Credit Fund to transmit payments, including to shareholders, increased operating costs, liability to third parties, regulatory intervention, and reputational damage and could have a material adverse

effect on the Credit Fund and shareholders’ investments in the Credit Fund. Studies have shown that the lack of adequate systems is often a significant contributing factor to failures of funds like the Credit Fund. Operational Risk. The Credit Fund depends on the Investment Manager to develop the appropriate systems and procedures to control operational risk. These systems and procedures may not account for every actual or potential disruption of the Credit Fund’s operations. The Credit Fund’s business is dynamic and complex. As a result, certain operational risks are intrinsic to the Credit Fund’s operations, especially given the volume, diversity, and complexity of transactions that the Credit Fund is expected to enter into daily. Operational risks arising from mistakes made in the confirmation or settlement of transactions, from transactions not being properly booked, evaluated or accounted for, or other similar disruption in the Credit Fund’s operations may cause the Credit Fund to suffer financial loss, the disruption of its business, liability to clients or third parties, regulatory intervention, or reputational damage. The Credit Fund’s business is highly dependent on its ability to process daily, many transactions across numerous and diverse markets. Consequently, the Credit Fund relies heavily on its financial, accounting, and other data processing systems. The ability of its systems to accommodate an increasing volume, diversity and complexity of transactions could also constrain the Credit Fund’s ability to properly manage its portfolio. Conflicts of Interest of the Investment Manager. The Investment Manager and its affiliates also act, and may in the future act, as investment advisers for other advisory clients that invest in securities at various levels of risk and return (including where such clients invest directly in the Credit Fund). In this capacity, the Investment Manager and its affiliates may make investment decisions for other persons during the same period they are acting as such with respect to the Credit Fund. The Credit Fund will not share in fees earned by the Investment Manager and its affiliates in connection with their respective advisory businesses. The investment objectives and investment strategies applicable to such advisory clients may differ from those applicable to the Credit Fund, and the Investment Manager and its affiliates may use the same or different information in advising such other advisory clients and entities as the Investment Manager utilizes in the management of the assets of the Credit Fund. Such advisory clients do not necessarily participate in the same transactions, and the Investment Manager and its affiliates may take positions with respect to such advisory clients that are the same as or different from the positions taken for the Credit Fund. Where similar objectives and strategies are applicable, transactions are allocated among all participating advisory clients, including the Credit Fund, as equitably as possible, but there can be no assurance that it is practicable for each advisory client or the Credit Fund to participate in every transaction or position. It is possible that some or all such advisory clients or the Credit Fund may be in competition for certain investment opportunities. The Investment Manager monitors all investment activities of such advisory clients to attempt to ensure that they do not receive more advantageous treatment than the Credit Fund.

There can be no assurance, however, that all such entities and accounts will participate in equivalent investments. The Investment Manager and its affiliates will be subject to a variety of conflicts of interest in making investments on behalf of the Credit Fund. For example, the Investment Manager may be subject to conflicts relating to its selection of brokers on behalf of the Credit Fund. In selecting brokers and dealers to effect portfolio transactions for the Credit Fund, the Investment Manager will consider such factors as the ability of the brokers or dealers to effect the transactions, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to the Investment Manager, and brokerage and research services provided to the Investment Manager (e.g., research ideas, analysis, investment strategies, special execution and block positioning capabilities, clearance, and settlement and custodial services). However, brokers may provide other services that are beneficial to the Investment Manager, but not necessarily beneficial to the Credit Fund, including, without limitation, capital introduction, marketing assistance, consulting with respect to technology, operations or equipment, and other services. Such services may influence the Investment Manager’s selection of brokers. Retention and Motivation of Key Employees. The performance of the Credit Fund is largely dependent on the talents and efforts of highly skilled individuals employed by the Investment Manager. The success of the Credit Fund depends on the Investment Manager’s ability to identify, and willingness to compensate, talented investment professionals and other employees. There can be no assurance that the Investment Manager’s investment professionals will continue to be associated with the Investment Manager throughout the life of the Credit Fund, and the failure to attract or retain such investment professionals could have a material adverse effect on the Credit Fund and the shareholders of the Credit Fund, including, for example, by limiting the Investment Manager’s ability to pursue particular investment strategies discussed herein. Competition in the financial services industry for qualified employees is intense and there is no guarantee that the talents of the Investment Manager’s investment professionals could be replaced. Misconduct of Personnel of the Investment Manager and of Third Party Service Providers. The Credit Fund relies on a substantial number of personnel of the Investment Manager, counterparties, and other service providers. Accordingly, risks associated with errors of such personnel are inherent in the business and operations of the Credit Fund. Misconduct by such personnel could cause significant losses to the Credit Fund and may include binding the Credit Fund to transactions that are not properly authorized, that present unacceptable risks, or that conceal unsuccessful trading activities (which may result in unknown and unmanaged risks or losses). Losses could also result from misconduct by such personnel, including, for example, failing to recognize trades and misappropriating assets. In addition, such personnel may improperly use or disclose confidential information. Any misconduct by such personnel could result in litigation or serious financial harm to the Credit Fund, including limiting the Credit Fund’s business prospects or future marketing activities. Although the Investment Manager will adopt measures to prevent and detect misconduct of its personnel and transact with reliable

counterparties and third-party service providers, such measures may not be effective in all cases. Competition; Availability of Investments. The Credit Fund may be unable to find sufficient attractive opportunities to meet its investment objectives or fully invest its committed capital. There can be no assurance that the Investment Manager will be able to identify or successfully pursue attractive investment opportunities in such environments. Among other factors, competition for suitable investments from other pooled investment vehicles, the public securities market, and other investors may reduce the availability of investment opportunities. There has been significant growth in the number of firms organized to make such investments, which may result in increased competition with the Credit Fund in obtaining suitable investments. Liquidation. Although it is expected that the Credit Fund will be able to dispose of its investments in an orderly fashion in the event of a liquidation, the Credit Fund may invest in investments which cannot be realized in an orderly fashion until after the date on which the Credit Fund terminates. Although it is the expectation of the Investment Manager that all investments will be disposed of prior to a liquidation, the Credit Fund may have to sell or otherwise dispose of investments on disadvantageous terms as a result of such liquidation or distribute such investments in-kind. Valuation of the Assets and Liabilities of the Credit Fund. The Administrator, in consultation with the Investment Manager and the Board of Directors, will value the assets and liabilities of the Credit Fund in accordance with the Credit Fund’s valuation policies and procedures as set out in the Credit Fund’s offering documentation. In calculating the net asset value of the Credit Fund, the Administrator shall, and shall be entitled to, rely on, and will not be responsible for the accuracy of, financial data furnished to it by the Credit Fund’s prime broker(s), market makers, and/or independent third party pricing services. The Administrator may also use and rely on industry standard financial models in pricing any of the Credit Fund’s securities or other assets. If and to the extent that the Board of Directors or the Investment Manager are responsible for or otherwise involved in the pricing of any of the Credit Fund’s portfolio securities or other assets, the Administrator may accept, use and rely on such prices in determining the net asset value of the Credit Fund and shall not be liable to the Credit Fund, any investor in the Credit Fund, the Board of Directors, the Investment Manager or any other person in so doing. To the extent that the Credit Fund invests in private securities or restricted securities, the valuation of such securities will be determined by the Board of Directors or the Investment Manager, and such valuation will be final and conclusive. There is no guarantee that the valuation determined by the Board of Directors or the Investment Manager will represent the value that will be realized by the Credit Fund on the eventual disposition of the investment or that would, in fact, be realized upon an immediate disposition of the investment. Thus, an investor redeeming its shares in the Credit Fund prior to realization of such an investment may not participate in gains or losses therefrom. Management fees and performance fees

will not be refunded or adjusted should the realized value differ from the valuation used to form the basis for management fees and performance fees previously paid. Inaccurate valuations may prevent the Credit Fund from effectively managing its investment portfolio and risks, may result in the Credit Fund exceeding certain investment guidelines, and may affect the diversification and risk management of the Credit Fund’s portfolio. Reliance on Valuation Information from Employees and Third Parties. To value the assets and liabilities of the Credit Fund, the Administrator will rely on information provided by outside parties or their personnel, and such persons may provide inaccurate, incomplete, out of date, or otherwise unreliable information. In the case of employees who receive compensation based on the performance of certain investments, such employees may be motivated to provide incorrect valuation information in order to receive increased compensation. The Credit Fund will implement procedures to safeguard against the use of inaccurate information but may be unable to detect every error contained in the valuation information. To the extent the information received by the Credit Fund is inaccurate or unreliable, the valuation of the Credit Fund’s assets and liabilities may be inaccurate. Dilution from Subsequent Closings. Shareholders subscribing for shares will participate in the existing investments of the Credit Fund, thereby diluting the interest of existing shareholders. Side Letters. The Credit Fund may enter into agreements (“Side Letters”) with certain prospective or existing shareholders whereby such shareholders may be subject to terms and conditions that are more advantageous than those set forth in the Credit Fund’s offering documentation and given to other shareholders. For example, such terms and conditions may provide for special rights to make future investments in the Credit Fund, other investment vehicles or managed accounts; special redemption rights, relating to frequency or notice; a reduction or rebate in fees or redemption charges to be paid by the shareholder; rights to receive reports from the Credit Fund on a more frequent basis or that include information not provided to other shareholders (including, without limitation, more detailed information regarding portfolio positions); and such other rights as may be negotiated by the Credit Fund and such shareholders. The modifications are solely at the discretion of the Credit Fund and may, among other things, be based on the size of the shareholder’s investment in the Credit Fund or affiliated investment entity, an agreement by a shareholder to maintain such investment in the Credit Fund for a significant period, or other similar commitment by a shareholder to the Credit Fund. Epidemics and Pandemics. Since the mid-1990s, the world has seen a number of outbreaks of new viral illnesses of varying severity, including avian flus, Severe Acute Respiratory Syndrome (SARS), Middle East Respiratory Syndrome (MERS), the H1N1 Flu (Swine Flu), and COVID-19 caused by the novel Coronavirus known as SARS–CoV-2. The responses to these outbreaks have varied as has their impact on human health, local economies, and the global economy, and it is impossible at the outset of any such outbreak to estimate accurately what the ultimate impact of any such outbreak will be. Protective measures may be taken by governments and

the private sector, including the Investment Manager, to mitigate the spread of any such illness generally, including travel restrictions and outright bans, quarantines, government-imposed shutdowns and work-from-home arrangements, and the spread of any such illness within the offices of the Investment Manager. An outbreak of any kind of epidemic, communicable disease, virus, or major public health issue could cause a slowdown in the levels of economic activity generally (or push the world or local economies into recession), which would be reasonably likely to adversely affect the business, financial condition, and operations of the Investment Manager and the Credit Fund. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to worsen), the Investment Manager and the Credit Fund could be adversely affected by more stringent travel restrictions (such as mandatory quarantines and social distancing), additional limitations on the Investment Manager’s (or the Credit Fund’s) operations and business activities, and governmental actions limiting the movement of people and goods between regions and other activities or operations. General Investment Risk Factors General Economic and Market Conditions. The success of the Credit Fund’s activities will be affected by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the Credit Fund’s investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of securities prices and the liquidity of the Credit Fund’s investments. Volatility or illiquidity could impair the Credit Fund’s profitability or result in losses. The Credit Fund may maintain substantial trading positions that can be adversely affected by the level of volatility in the financial markets; the larger the positions, the greater the potential for loss. Emerging and Developing Markets. The Credit Fund may invest a portion of its assets in financial instruments of issuers domiciled or operating in emerging and developing markets. Investing in these markets may involve heightened risks (some of which could be significant) and special considerations not typically associated with investing in other more established economies or securities markets. Such risks may include, but are not limited to: (i) increased risk of nationalization or expropriation of assets or confiscatory taxation; (ii) greater social, economic and political uncertainty including war, military coup or other attempted change in local or national government by force of action; (iii) higher dependence on exports and the corresponding importance of international trade; (iv) greater volatility, less liquidity and smaller capitalization of securities markets; (v) greater volatility in currency exchange rates; (vi) greater risk of inflation; (vii) greater controls on foreign investment and limitations on repatriation of invested capital and on the ability to exchange local currencies for U.S. dollars; (viii) increased likelihood of governmental involvement in and control over the economies; (ix) governmental decisions to cease support of economic reform programs or to impose centrally planned economies; (x) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers; (xi) less extensive regulation of the securities markets; (xii) less established tax laws and procedures; (xiii) longer settlement

periods for securities transactions and less reliable clearance and custody arrangements; (xiv) less developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors; (xv) certain considerations regarding the maintenance of fund securities and cash with non-U.S. brokers and securities depositories; and (xvi) increased risk of such financial instruments issuers being in default given they operate in emerging and developing markets, including a country declaring a debt moratorium over any financial instruments it has issued. Highly Volatile Markets. The prices of financial instruments in which the Credit Fund may invest can be highly volatile. Price movements of forwards, futures, derivative contracts, and other securities in which the Credit Fund’s assets may be invested are influenced by, among other things, interest rates, changing supply and demand relationships, and trade, fiscal, monetary and exchange control programs, policies of governments, and national and international political and economic events and policies. The Credit Fund is subject to the risk of failure of any of the exchanges on which their positions trade or of their clearinghouses. In addition, governments from time to time intervene in certain markets, directly and by regulation, particularly in currencies, futures, and options. Such intervention is often intended to directly influence prices and may, together with other factors, cause some or all of these markets to move rapidly in the same direction. The effect of such intervention is often heightened by a group of governments acting in concert. The Credit Fund may make certain speculative investments in currencies which the Investment Manager believes to be undervalued; however, there are no assurances that the currencies purchased will in fact be undervalued. In addition, the Credit Fund may be required to hold such currencies for a substantial period before realizing their anticipated value. During this period, a portion of the Credit Fund’s assets will be committed to the currencies purchased, thus possibly preventing the Credit Fund from investing in other opportunities. General Investment Technique Risk Factors Limited Diversification and Risk Management Failures. Except for any investment restrictions described in the Credit Fund’s offering documentation, the Credit Fund has no formal guidelines for diversification. As a result, the Credit Fund’s portfolio could become concentrated in a limited number of issues, types of securities, industries, sectors, strategies, or countries, and will be concentrated in a limited geographic region, and any such concentration of risk may increase losses suffered by the Credit Fund. At any given time, it is possible that the Credit Fund’s investments or portfolio risks could be concentrated in only a few industries, companies, geographic regions, asset types, strategies, or other areas of risk. This limited diversity could expose the Credit Fund to losses disproportionate to market movements in general. Even when the Investment Manager attempts to control risks and diversify the portfolio, risks associated with different assets may be correlated in unexpected ways, with the result that the Credit Fund faces concentrated exposure to certain risks. In addition, many hedge funds pursue similar strategies, which creates the risk that many funds would be forced to liquidate positions at the same time, reducing liquidity, increasing volatility, and exacerbating losses. Although the Investment Manager attempts to identify, monitor, and manage significant risks, these efforts can not take all risks into

account and there can be no assurance that these efforts will be effective. Many risk management techniques are based on observed historical market behavior, but future market behavior may be entirely different. Any inadequacy or failure in the Investment Manager’s risk management efforts could result in material losses for the Credit Fund. Leverage. The Credit Fund expects to employ leverage up to a ratio of 2 to 1 in its investment program when deemed appropriate by the Investment Manager and subject to applicable regulations. Leverage creates an opportunity for greater yield and total return, but at the same time increases exposure to capital risk and higher current expenses. If the Credit Fund purchases securities on margin and the value of those securities falls, the Credit Fund may be obligated to pay down the margin loans to avoid liquidation of the securities. If loans to the Credit Fund are collateralized with portfolio securities that decrease in value, the Credit Fund may be obligated to provide additional collateral to the lender in the form of cash or securities to avoid liquidation of the pledged securities. Any such liquidation could result in substantial losses. Moreover, counterparties of the Credit Fund, in their sole discretion, may change the leverage limits that they extend to the Credit Fund. Short Selling. Short selling involves selling securities which are not owned by the short seller and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. Short selling allows the seller to profit from a decline in market price to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. The extent to which the Credit Fund engages in short sales will depend upon the Investment Manager’s investment strategy and opportunities. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying security could theoretically increase without limit, thus increasing the cost to the Credit Fund of buying those securities to cover the short position. There can be no assurance that the Credit Fund will be able to maintain the ability to borrow securities sold short. In such cases, the Credit Fund can be “bought in” (i.e., forced to repurchase securities in the open market to return to the lender). There also can be no assurance that the securities necessary to cover a short position will be available for purchase at or near prices quoted in the market. Purchasing securities to close out a short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. Hedging Transactions. The Credit Fund may utilize financial instruments, both for investment purposes and for risk management purposes in order to: (i) protect against possible changes in the market value of the Credit Fund’s investment portfolio resulting from fluctuations in the securities markets and changes in interest rates; (ii) protect the Credit Fund’s unrealized gains in the value of its investment portfolio; (iii) facilitate the sale of any such investments; (iv) enhance or preserve returns, spreads or gains on any investment in the Credit Fund’s portfolio; (v) hedge against a directional trade; (vi) hedge the interest rate, credit or currency exchange rate on any of the Credit Fund’s liabilities or assets; (vii) protect against any increase in the price of any securities the Credit Fund anticipates purchasing at a later date; or (viii) act for any other reason that the Investment Manager deems appropriate. The Credit Fund will not be required to hedge any particular risk in connection with a particular

transaction or its portfolio generally. While the Credit Fund may enter into hedging transactions to seek to reduce risk, such transactions may result in a poorer overall performance for the Credit Fund than if it had not engaged in any such hedging transaction. Moreover, it should be noted that the portfolio will always be exposed to certain risks that cannot be hedged. Investment Strategy and Investment Instrument Risks Risks of Investments in Securities Generally. All securities investments risk the loss of capital. No guarantee or representation is made that the Credit Fund’s investment program will be successful. The investment program will involve, without limitation, risks associated with possible limited diversification, leverage, volatility, tracking risks in hedged positions, security borrowing risks in short sales, credit deterioration or default risks, systems risks, and other risks inherent in the Credit Fund’s activities. Certain investment techniques of the Credit Fund can, in certain circumstances, magnify the impact of adverse market moves to which the Credit Fund may be subject. In addition, the Credit Fund’s investment in securities may be materially affected by conditions in the financial markets and overall economic conditions occurring globally and in countries or markets where the Credit Fund may invest its assets. The Credit Fund’s methods of minimizing such risks may not accurately predict future risk exposures. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that are larger than historical indicators. Also, information used to manage risks may not be accurate, complete, or current, and such information may be misinterpreted. Illiquid Portfolio Investments. The Credit Fund may make investments in securities or other assets, such as bank loans, that are subject to legal or other restrictions on transfer or for which no liquid market exists. The market prices, if any, for such investments tend to be volatile and may not be readily ascertainable, and the Credit Fund may not be able to sell them when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. The sale of restricted securities and illiquid investments often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the overthe-counter markets. The Credit Fund may not be able to readily dispose of such illiquid investments and, in some cases, may be contractually prohibited from disposing of such investments for a specified period. Restricted securities and other types of illiquid assets may sell at a price lower than similar investments that are not subject to restrictions on resale. Assets and liabilities for which no such market prices are available will generally be carried on the books of the Credit Fund at fair value (which may be cost) as reasonably determined by the Investment Manager. There is no guarantee that fair value will represent the value that will be realized by the Credit Fund on the eventual disposition of the investment or that would, in fact, be realized upon an immediate disposition of the investment.

Volatility Risk. The Credit Fund’s investment program may involve the purchase and sale of relatively volatile instruments such as derivatives, which are frequently valued based on the implied volatility of such derivatives compared to the historical volatility of underlying financial instruments. Fluctuations or prolonged changes in the volatility of such instruments can adversely affect the value of investments held by the Credit Fund. Liquidity Risks. Liquidity may be important to the Credit Fund’s business. In addition to financial instruments and assets for which no markets exist or that are illiquid, the Credit Fund’s portfolio may include other relatively illiquid investments (e.g., investments in bank loans, thinly-traded issuers, or high yield bonds). Under certain market conditions, such as during volatile markets or when trading in an instrument or market is otherwise impaired, the liquidity of the Credit Fund’s relatively liquid portfolio positions may be reduced. During such times, the Credit Fund may be unable to dispose of certain assets, which would adversely affect the Credit Fund’s ability to rebalance its portfolio or to meet redemption requests. In addition, such circumstances may force the Credit Fund to dispose of assets at reduced prices, thereby adversely affecting the Credit Fund’s performance. If there are other market participants seeking to dispose of similar assets at the same time, the Credit Fund may be unable to sell such assets or prevent losses relating to such assets. Furthermore, if the Credit Fund incurs substantial trading losses, the need for liquidity could rise sharply while their access to liquidity could be impaired. In addition, in conjunction with a market downturn, the Credit Fund’s counterparties could incur losses of their own, thereby weakening their financial condition and increasing the Credit Fund’s credit risks to them. Exchange Rate Exposure. The Credit Fund will invest the majority of its assets in the securities of non-U.S. issuers listed on foreign exchanges and denominated in non-U.S. currencies. The Fund, however, values its securities and other assets in U.S. dollars. The Credit Fund has the authority to hedge its non-U.S. dollar positions through currency hedging transactions. There can be no guarantee that financial instruments suitable for hedging currency or market shifts will be available at the time when the Credit Fund wishes to use them, or that hedging techniques employed by the Credit Fund will be effective. Furthermore, certain currency market risks may not be fully hedged or hedged at all. To the extent unhedged, the value of the Credit Fund’s positions in non-U.S. investments will fluctuate with the U.S. dollar exchange rate. In such cases, an increase in the value of the U.S. dollar compared to the other currencies in which the Credit Fund holds investments will reduce the value of these foreign investments, which may result in a loss to the Fund. Debt Securities Generally. The Credit Fund expects to invest, directly or indirectly, in private and government debt securities and instruments. It is possible that some of the debt instruments in which the Credit Fund invests may be unrated, and, whether or not rated, the debt instruments may have speculative characteristics. The issuers of such instruments (including sovereign issuers) may face significant ongoing uncertainties and exposure to adverse conditions that may undermine the issuer’s ability to make timely payment of interest and principal in accordance with the terms of the obligations. In addition, an economic recession could severely disrupt the market for most of these securities and may

have an adverse impact on the value of such instruments. It is also likely that any such economic downturn could adversely affect the ability of the issuers of such securities to repay principal and pay interest thereon and increase the incidence of default for such securities. Investments in Unsecured and Subordinated Debt. Subordinated debt is subject to certain additional risks to the extent that such obligations may be unsecured and/or subordinated to substantial amounts of senior indebtedness, all or a significant portion of which may be secured. Moreover, such obligations may not be protected by financial covenants or limitations upon additional indebtedness. Non-Performing Nature of Debt. It is possible that certain debt instruments purchased by the Investment Manager for the Credit Fund could become non-performing and possibly default. Furthermore, the obligor or relevant guarantor may also become bankrupt or liquidated. There can be no assurance as to the amount and timing of payments, if any, with respect to the loans. Derivative Investments. The prices of derivative instruments, including futures and options, are highly volatile. Payments made pursuant to swap agreements may also be highly volatile. Price movements of futures and options contracts and payments pursuant to swap agreements are influenced by, among other things, interest rates, changing supply and demand relationships, and trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. The value of futures, options and swap agreements also depends upon the price of the securities underlying them. In addition, the Credit Fund’s assets are also subject to the risk of the failure of any of the exchanges on which their positions trade or of their clearinghouses or counterparties. The Credit Fund may buy or sell (write) both call options and put options, and when they write options, they may do so on a “covered” or an “uncovered” basis. A call option is “covered” when the writer owns securities of the same class and amount as those to which the call option applies. A put option is covered when the writer has an open short position in securities of the relevant class and amount. The Credit Fund’s option transactions are anticipated to be part of a hedging strategy (i.e., offsetting the risk involved in another securities position); however, these activities involve risks that can be substantial, depending on the circumstances. In general, without taking into account other positions or transactions the Credit Fund may enter into, the principal risks involved in options trading can be described as follows: When the Credit Fund buys an option, a decrease (or inadequate increase) in the price of the underlying security in the case of a call, or an increase (or inadequate decrease) in the price of the underlying security in the case of a put, could result in a total loss of the Credit Fund’s investments in the option (including commissions). The Credit Fund could mitigate those losses by selling short, or buying puts on, the securities for which they hold call options, or

by taking a long position (e.g., by buying the securities or buying calls on them) in securities underlying put options. When the Credit Fund sells (writes) an option, the risk can be substantially greater than when it buys an option. The seller of an uncovered call option bears the risk of an increase in the market price of the underlying security above the exercise price. The risk is theoretically unlimited unless the option is “covered.” If it is covered, the Credit Fund would forego the opportunity for profit on the underlying security should the market price of the security rise above the exercise price. If the price of the underlying security were to drop below the exercise price, the premium received on the option (after transaction costs) would provide profit that would reduce or offset any loss the Credit Fund might suffer as a result of owning the security. Swaps and certain options and other custom instruments are subject to the risk of nonperformance by the swap counterparty, including risks relating to the swap counterparty, credit risk, market risk, liquidity risk and operations risk. Other Derivative Instruments. The Credit Fund may enter into swaps and other derivative instruments, such as credit derivatives. The Investment Manager may take advantage of opportunities with respect to certain other derivative instruments that are not presently contemplated for use or that are currently not available, but that may be developed, to the extent such opportunities are both consistent with the investment objective of the Credit Fund and legally permissible. Special risks may apply to instruments that are invested in by the Credit Fund in the future that cannot be determined at this time or until such instruments are developed or invested in by the Fund. Certain swaps, opinions and other derivative instruments may be subject to various types of risks, including market risk liquidity risk, the risk of non-performance by the counterparty, including risks relating to counterparty credit risk, legal risk, and operations risk. Forward Trading. Forward contracts and options thereon, unlike futures contracts, are not traded on exchanges and are not standardized; rather, banks and dealers act as principals in these markets, negotiating each transaction on an individual basis. Forward and “cash” trading is substantially unregulated; there is no limitation on daily price movements and speculative position limits are not applicable. The principals who deal in the forward markets are not required to continue to make markets in the currencies or commodities they trade, and these markets can experience periods of illiquidity, sometimes of significant duration. There have been periods during which certain participants in these markets have refused to quote prices for certain currencies or commodities or have quoted prices with an unusually wide spread between the price at which they were prepared to buy and that at which they were prepared to sell. Disruptions can occur in forward markets due to unusually high trading volume, political intervention or other factors. Bank Loans. The Credit Fund’s investment program may include significant investments in bank loans and participations. These obligations are subject to unique risks, including: (i) the possible invalidation of an investment transaction as a fraudulent conveyance under

relevant creditors’ rights laws; (ii) so-called lender-liability claims by the issuer of the obligations; (iii) environmental liabilities that may arise with respect to collateral securing the obligations; and (iv) limitations on the ability of the Credit Fund to directly enforce its rights with respect to participations. In analyzing each bank loan or participation, the Investment Manager compares the relative significance of the risks against the expected benefits of the investment. Successful claims by third parties arising from these and other risks will be borne by the Credit Fund. As secondary market trading volumes increase, new loans are frequently adopting standardized documentation to facilitate loan trading which may improve market liquidity. There can be no assurance, however, that future levels of supply and demand in loan trading will provide an adequate degree of liquidity or that the current level of liquidity will continue. Because of the provision to holders of such loans of confidential information relating to the borrower, the unique and customized nature of the loan agreement, and the private syndication of the loan, loans are not as easily purchased or sold as a publicly traded security, and historically the trading volume in the loan market has been small relative to the high yield debt market. Fixed Income Securities. The Credit Fund may invest in bonds or other fixed income securities, including, without limitation, bonds, notes and debentures issued by corporations, municipal bonds, debt securities issued or guaranteed by government entities or their agencies or instrumentalities and commercial paper. Fixed income securities pay fixed, variable or floating rates of interest. The value of fixed income securities in which the Credit Fund invests will change in response to fluctuations in interest rates. In addition, the value of certain fixed-income securities can fluctuate in response to perceptions of creditworthiness, political stability or soundness of economic policies. Fixed income securities are subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). Credit Default Swaps. Like short sales, credit default swaps involve the risk of an unlimited increase in the market price of a security. Also, like short sales, an investment in a credit default swap involves the posting of collateral that will be returned to the Credit Fund upon the termination of the credit default swap. Amounts posted as collateral may be invested in cash or cash equivalent investments and may not generate the same level of return as the Credit Fund’s other investments. Repurchase and Reverse Repurchase Agreements. The Credit Fund may enter into repurchase and reverse repurchase agreements. When the Credit Fund enters into a repurchase agreement, it “sells” securities to a broker-dealer or financial institution and agrees to repurchase such securities on a mutually agreed date for the price paid by the broker-dealer or financial institution, plus interest at a negotiated rate. In a reverse repurchase transaction, the Credit Fund “buys” securities issued from a broker-dealer or financial

institution, subject to the obligation of the broker-dealer or financial institution to repurchase such securities at the price paid by the Credit Fund, plus interest at a negotiated rate. The use of repurchase and reverse repurchase agreements by the Credit Fund involves certain risks. For example, if the seller of securities to the Credit Fund under a reverse repurchase agreement defaults on its obligation to repurchase the underlying securities, as a result of its bankruptcy or otherwise, the Credit Fund will seek to dispose of such securities, which action could involve costs or delays. If the seller becomes insolvent and subject to liquidation or reorganization under applicable bankruptcy or other laws, the Credit Fund’s ability to dispose of the underlying securities may be restricted. It is possible, in a bankruptcy or liquidation scenario, that the Credit Fund may not be able to substantiate its interest in the underlying securities. Finally, if a seller defaults on its obligation to repurchase securities under a reverse repurchase agreement, the Credit Fund may suffer a loss to the extent that it is forced to liquidate its position in the market, and proceeds from the sale of the underlying securities are less than the repurchase price agreed to by the defaulting seller. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. Ability to Lend on Advantageous Terms: Competition and Supply. The Credit Fund may purchase loans. The Credit Fund’s success in this area will depend, in part, on its ability to obtain loans on advantageous terms. In purchasing loans, the Credit Fund will compete with a broad spectrum of lenders, many of which have substantially greater financial resources and are better known than the Fund. Increased competition for, or a diminution in the available supply of, qualifying loans could result in lower yields on such loans, which could reduce returns to investors. Fraud. Loans are subject to the risk of material misrepresentation or omission on the part of a borrower. Such inaccuracy or incompleteness may adversely affect the valuation of the collateral underlying a loan or may adversely affect the ability of the Credit Fund to perfect or effectuate a lien on the collateral securing the loan. The Investment Manager will rely upon the accuracy and completeness of representations made by borrowers to the extent reasonable, but cannot guarantee such accuracy or completeness. Under certain circumstances, payments to the Credit Fund may be reclaimed if any such payment or distribution is later determined to have been a fraudulent conveyance or a preferential payment. Anti-Money Laundering Risks. The governing Cayman Anti-Money Laundering regime includes the Proceeds of Crime Act (Revised), the Terrorism Act (Revised) and the Anti-Money Laundering Regulations (Revised) promulgated pursuant thereto. It is possible that additional legislation or regulations could be promulgated that would require Aquamarine or other service providers to the Credit Fund, in connection with the establishment of anti-money laundering procedures, to share information with other governmental authorities with respect to shareholders. Such legislation and/or regulations could require the Credit Fund to implement additional restrictions on the transfer of the shares. Additional anti-money laundering risks may be present depending on Aquamarine’s client base.

Redemption of Shares Optional Redemption. The shares of the Credit Fund generally may be redeemed, upon thirty (30) calendar days’ prior notice via email or facsimile to the Administrator, on the last calendar day of each month or on other days designated by the Board of Directors in its sole discretion (each a “Redemption Date”). The minimum value of a redemption is $1,000,000, subject to the discretion of the Board of Directors to allow otherwise. Except with the consent of the Credit Fund, partial redemptions will not be permitted if the remaining Shares held by such shareholder would have a value of less than $1,000,000. The Credit Fund, in its discretion, may also delay the redemption of any shares in the event of adverse market or other conditions, natural or man-made catastrophes or force majeure. In addition, the Credit Fund may extend the duration of the redemption notice period beyond thirty (30) days if the Credit Fund deems such extension to be in the best interests of the Credit Fund and nonredeeming shareholders. Cayman Islands law imposes certain restrictions on the redemption of shares, particularly where the Credit Fund is not funding such redemption out of profits or the proceeds of fresh issues of shares made for the purposes of redemption. Thus, any redemption payment out of capital will only be possible if the Credit Fund remains able to pay its debts as they fall due in the ordinary course of business after such redemption payment is made. The Credit Fund, or the Administrator on its behalf, also reserves the right to refuse to make any redemption payment or distribution to a shareholder if any members of the Board of Directors or the Administrator suspects or is advised that the payment of any redemption or distribution moneys to such shareholder might result in a breach or violation of any applicable anti-money laundering or other laws or regulations by any person in any relevant jurisdiction, or such refusal is considered necessary or appropriate to ensure the compliance by the Credit Fund, its Board of Directors or the Administrator with any such laws or regulations in any relevant jurisdiction. Where a redemption request is accepted, the shares will be treated as having been redeemed with effect from the relevant redemption date irrespective of whether or not such redeeming shareholder has been removed from the Credit Fund’s register of members or the redemption price in respect of such redeemed shares has been determined or remitted. Accordingly, on and from the relevant redemption date, shareholders in their capacity as such will not be entitled to or be capable of exercising any rights with respect to the shares being redeemed (including any right to receive notice of, attend or vote at any meeting of the Credit Fund) save the right to receive the redemption price and any dividend which has been declared prior to the relevant redemption day but not yet paid (in each case with respect to the shares being redeemed). Such redeemed shareholders will be creditors of the Credit Fund with respect to the redemption price. In an insolvent liquidation, redeemed shareholders will generally rank behind ordinary creditors but ahead of shareholders.

Lock Up Period. Shareholders in the Credit Fund will be permitted to redeem all or part of their shares, as applicable, only on or after the six (6) month-anniversary of the purchase of such Shares (the “Lock-Up Period”). The Credit Fund may, however, permit a shareholder to redeem its Shares from the Credit Fund prior to the expiration of the Lock-up Period under certain extraordinary circumstances as designated by the Board of Directors in its sole discretion. Shares are redeemed at a price per share based on the net asset value per share of the series as of the close of business on the Redemption Date, including adjustment for the performance fee payable to the Investment Manager. Redemption proceeds generally are paid within thirty (30) calendar days following the Redemption Date except that where a shareholder redeems 90% or more of such shareholder’s shares, in the Board of Director’s discretion, such shareholder may be paid in an amount equal to at least 95% of the redemption price within thirty (30) calendar days following the Redemption Date, with the balance settled within thirty (30) calendar days after completion of the next audit of the Credit Fund’s annual financial statements. Redemption proceeds generally are paid in U.S. dollars but may be paid in-kind (see below). If shares are redeemed as of a date other than the last calendar day of a month, the net asset value of each series of shares will be valued as of such Redemption Date. Mandatory Redemption. The Credit Fund reserves the right to require the mandatory redemption of all or any portion of the shares held by a shareholder, upon 30 calendar days’ prior notice, if the Credit Fund determines that (i) any of the representations or warranties of the shareholder were not true when made or the shareholder has breached an agreement with the Credit Fund; (ii) the shares have been transferred without the permission of the Credit Fund and such transfer may result in regulatory, pecuniary, legal, taxation or material administrative disadvantage for the Credit Fund or its shareholders as a whole; (iii) the ownership of the shares by the shareholder may result in regulatory, pecuniary, legal, taxation or material administrative disadvantage for the Credit Fund or the shareholders as a whole; (iv) the shares are beneficially owned by a U.S. person not authorized by the Board of Directors, either alone or in conjunction with any other person; (v) a shareholder has refused to consent to the appointment of a sub-advisor; (vi) a redemption would cause the aggregate value of the shares held by a shareholder to fall below the required minimum investment then in effect; or (vii) for any other reason in the sole discretion of the Board of Directors. In such event, shares will be redeemed in accordance with the redemption procedures described above and will be valued on the date of the redemption. Delay in Payments. If on any Redemption Date, assets of the Credit Fund are invested in investments which the Credit Fund is unable to realize, or if realized would be at a value determined by the Board of Directors to be a discount to their true value or the Credit Fund is unable (or it is not practicable) to distribute any such investment to the redeeming shareholder, then, in the discretion of the Board of Directors, in consultation with the Investment Manager, payment to the shareholder of the portion of his requested redemption may be delayed until such time as such investment may be realized or may be realized at a

value which is not, in the determination of the Board of Directors, a discounted value or the Credit Fund is able to distribute such Investment to the shareholder and the amount otherwise due to the shareholder will be increased or decreased to reflect the performance of such investment through the date on which such investment is realized by the Credit Fund or to reflect the increase or decrease in the value of the investment through the date on which it is distributed to the shareholder or otherwise disposed of by the Credit Fund. Redemption in-Kind. Payment of the redemption price to a shareholder on redemption will be made in cash or, in the discretion of the Board of Directors (following consultation with the Investment Manager), in securities (which may include short positions, as well as long positions) selected by the Board of Directors (following consultation with the Investment Manager), or partly in cash and partly in securities (which may include short positions, as well as long positions) selected by the Board of Directors (following consultation with the Investment Manager). In-kind distributions may be made directly to the redeeming shareholder or, alternatively: (a) may comprise interests in special purpose vehicles established by the Credit Fund for the purpose of liquidating the securities which are being transferred (either outright or by a participation interest) by the Credit Fund; or (b) may be distributed into a liquidating trust or account and sold for the benefit of such redeeming shareholder, in either such case (i) payment to such shareholder of that portion of his redemption attributable to such securities will be delayed until such securities can be liquidated and (ii) the amount otherwise due such shareholder will be increased or decreased to reflect the performance of such securities through the date on which the liquidation of such securities is effected, and any applicable fees and expenses. Payment of Redemption Proceeds Based on Unaudited Data. Shares are redeemed at a price per share based on the net asset value per share of the series as of the close of business on the applicable Redemption Date, including adjustment for the performance fee payable to the Investment Manager. Redemption proceeds generally are paid within thirty (30) calendar days following the Redemption Date, except that where a shareholder redeems 90% or more of such shareholder’s shares, in the Credit Fund’s sole discretion, such shareholder may be paid an amount equal to at least 95% of the redemption price within thirty (30) calendar days following the Redemption Date, with the balance settled within thirty (30) calendar days after completion of the next audit of the Credit Fund’s annual financial statements to, among other things, confirm the accuracy of the payment or comply with applicable regulatory requirements. Until distribution, such balance will be maintained in a holdback account, which will not participate in the profits and losses of the Credit Fund from the Redemption Date onwards. Accordingly, adjustments and revisions may be made to the Credit Fund’s net asset value following the year-end audit of the Credit Fund. Such adjustments and revisions may either increase or decrease the net asset value of the Credit

Fund, which will affect the existing holders of the shares at the time of such adjustment or revision. Effect of Substantial Redemptions. A significant redemption of shares, necessitating a liquidation of portfolio investments, may cause an imbalance in the Credit Fund’s portfolio which may adversely affect the remaining shareholders. Several factors make substantial redemptions a risk factor for shareholders. The Credit Fund will pursue a variety of investment strategies that will take time to develop and implement. A portion of the Credit Fund’s portfolio is expected to be comprised of securities that are not publicly traded, are illiquid and/or are subject to long-term commitments. The Credit Fund may not be able to readily dispose of such securities and, in some cases, may be contractually prohibited from disposing of such securities for a period of time. Substantial redemptions could be triggered by a number of events, including, for example, unsatisfactory performance, a significant change in personnel or management of the Investment Manager, removal or replacement of the Investment Manager, a decision by the Credit Fund and/or the Credit Fund’s investors to liquidate the Credit Fund, investor reaction to redemptions from other clients of Aquamarine, legal or regulatory issues that investors perceive to have a bearing on the Credit Fund or the Investment Manager, or other factors. Actions taken to meet substantial redemption requests from the Credit Fund (as well as similar actions taken simultaneously by other clients of Aquamarine) could result in prices of securities held by the Credit Fund decreasing and in Credit Fund expenses increasing (e.g., transaction costs and the costs of terminating agreements). The overall value of the Credit Fund also may decrease because the liquidation value of certain assets may be materially less than their marked-to-market value. The Credit Fund may be forced to sell its more liquid positions which may cause an imbalance in its portfolio that could adversely affect the remaining shareholders. Substantial redemptions could also significantly restrict the Credit Fund’s ability to obtain financing or derivatives counterparties needed for its investment and trading strategies, which would have a further material adverse effect on the Credit Fund’s performance.

The Code sets out standards of conduct and covers personal investment transactions of all supervised persons and their immediate family members, which includes most persons sharing the same household as the employee. Although the Code permits supervised persons to trade in securities for their own accounts, the Code contains preclearance procedures, reporting requirements and other provisions that restrict trading by supervised persons. Supervised persons are required to disclose their personal securities accounts upon commencing employment at Aquamarine and must submit duplicate securities account statements and confirmations. Supervised persons may buy or sell for their own accounts securities that are also held by clients. Conversely, supervised persons may buy and sell securities for client accounts which they themselves own. Such transactions are permitted as long as in compliance with the Code. Reports of personal transactions in securities are reviewed by Aquamarine’s Chief Compliance Officer at least quarterly. Any supervised person who violates the Code may be subject to remedial actions including, but not limited to, censure, demotion, suspension or dismissal. Supervised persons are also required to promptly report any violation of the Code of which they become aware and complete a certification regarding their compliance with the Code at least annually. Potential Conflicts Relating to Advisory Activities Aquamarine provides investment management to the Funds and Managed Accounts. Any Managed Account or Fund may have investment objectives, programs, strategies and positions that are similar or dissimilar to or may conflict with those of any other Managed Account or Fund, as applicable. Also, a Fund or Managed Account may invest in businesses that compete with, have interests adverse to, or are affiliated with the issuers of securities held by any other Fund or Managed Account, which could adversely affect the performance of that Fund or Managed Account. In addition, the fees payable to Aquamarine and the terms of any Managed Account or Fund may differ from those of any other Managed Account or Fund. There is no assurance that a Managed Account or Fund with investment objectives, programs or strategies similar to those of any other Managed Account or Fund will hold the same positions or perform

in a substantially similar manner as that Managed Account or Fund. Aquamarine may give advice or take action with respect to the investments of a Fund or Managed Account, which may differ from the advice given or the timing or nature of any action taken with respect to investments of any other Fund or Managed Account. As a result of such advice or actions, the prices and availability of securities and other financial instruments in which a Fund or Managed Account invests or may seek to invest, and the performance of a Fund or Managed Account may be adversely affected. A Fund or Managed Account may acquire securities or other financial instruments of an issuer that are senior or junior to securities or financial instruments of the same issuer that are held by another Fund or Managed Account (e.g., a Managed Account may acquire senior debt while a Fund may acquire subordinated debt). Aquamarine recognizes that conflicts may arise under such circumstances and will endeavor to treat the Funds and the Managed Accounts fairly and equitably. Aquamarine may have ongoing relationships with companies whose securities are held by or are being or may be considered for a Fund or a Managed Account. Further, Aquamarine’s supervised persons may from time to time invest their own assets in securities or instruments in which Aquamarine may invest a Fund’s or a Managed Account’s assets. Aquamarine or its supervised persons may buy, sell or hold securities or other instruments for their own accounts while making different investment decisions, where applicable for a Fund or a Managed Account. In addition, Aquamarine may invest in certain eligible investment funds managed by Aquamarine of their choosing and are not required to invest in any such funds. It is expected that, if such investments are made, the size and the nature of these investments will change over time. Furthermore, other clients of the Investment Manager or its advisory affiliates may invest directly in the Credit Fund (for instance pursuant to the terms of discretionary mandates between such other clients and the Investment Manager). The Investment Manager or its advisory affiliates, or key principals or employees of any of them, may invest directly in the Credit Fund. Transactions described in this paragraph are permissible as long as in compliance with the Code. It is the policy of Aquamarine to allocate investment opportunities to the Funds and Managed Accounts fairly and equitably, to the extent practicable, over a period. Aquamarine will have no obligation to purchase, sell or exchange any security or financial instrument for a Fund or Managed Account which Aquamarine may purchase, sell or exchange for any other Fund or Managed Account if Aquamarine believes in good faith at the time the investment decision is made that such transaction or investment would be unsuitable, impractical or undesirable for that Fund or Managed Account. Due to the nature of the fixed income markets, as well as specific a Fund’s and a Managed Account’s guidelines and objectives, pro rata allocation of investment opportunities will not always be feasible. Accordingly, Aquamarine will not prescribe one specific manner in which the securities or financial instruments will be allocated among the Funds and Managed Accounts, and Aquamarine may use pro rata, rotational, percentage or other reasonable allocation methods. An allocated transaction may be modified if strict adherence to an anticipated

allocation may lead to impractical or undesirable results such as odd lots or de minimis allocations. The factors that Aquamarine may consider in allocating investments among clients include, but are not limited to, each client’s investment guidelines or restrictions and investment strategies, concentrations and diversification within a client, tax and regulatory issues, the nature and size of existing portfolio holdings and cash positions, risk/return objectives, anticipated redemptions and subscriptions (liquidity). In certain circumstances Aquamarine may give special consideration to certain Funds or Managed Accounts such as a new Fund or Managed Account (including those in which the Aquamarine may have an interest) with a substantial amount of available cash. With respect to initial public offerings of equity securities (“new issues”), Aquamarine will determine which Funds or Managed Accounts are suitable and eligible to receive such issues, taking into consideration the factors described above. Whenever practicable, new issues will be allocated pro rata among all suitable and eligible Funds or Managed Accounts in proportion to their relative capital balances, as determined by Aquamarine in its sole discretion. If Aquamarine determines that the purchase or sale of the same security is in the best interest of more than one Fund or Managed Account, Aquamarine may, but is not obligated to, aggregate orders placed simultaneously to obtain best execution and reduce transaction costs to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating Fund or Managed Account will receive the average price with transaction costs allocated pro rata based on the size of each Fund’s or Managed Account's participation in the order (or allocation in the event of a partial fill) as determined by Aquamarine. In the event of a partial fill, allocations may be modified on a basis that Aquamarine deems to be appropriate, including, for example, to avoid odd lots or de minimis allocations. Aquamarine may elect not to aggregate trades, and, in such cases, trades are processed in the order they are placed with the broker or counterparty selected by Aquamarine. As a result, certain trades in the same security or instrument for one Fund or Managed Account (including a Fund or Managed Account in which the Aquamarine and it personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another Fund or Managed 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. Aquamarine and its personnel may not trade for the Funds, Managed Accounts, or for their own benefit or recommend trading in securities of a company while they are in possession of material, non-public information (“Inside Information”) concerning such company, or disclose such Inside Information to any person not entitled to receive it. Aquamarine may gain access to Inside Information, and accordingly, there may be certain cases where Aquamarine may be restricted from effecting purchases and/or sales of assets on behalf of the Funds or Managed Accounts. Aquamarine seeks to minimize those cases whenever practicable, consistent with applicable law and its policies, and in consultation with Aquamarine’s Chief Compliance Officer and its outside legal counsel, but there can be no assurance that it will not receive Inside

Information and that such restrictions will not occur. At times, Aquamarine, in an effort to avoid restriction for the Funds or Managed Accounts, may elect not to receive Inside Information that other market participants are eligible to receive or have received. Cross Trades Aquamarine may effect cross transactions between client accounts when Aquamarine determines that such transactions are appropriate and in the best interests of both participating clients. A cross transaction occurs when Aquamarine causes a transaction to be effected between two client accounts advised by Aquamarine. Cross trades may be used to facilitate portfolio rebalancing, manage liquidity, or transition positions between client accounts without incurring brokerage commissions that might otherwise be associated with executing transactions in the open market. Cross transactions create a conflict of interest because Aquamarine represents both the buying and selling accounts and therefore has an incentive to complete the transaction in a manner that may benefit one client over another. To address this conflict, Aquamarine has adopted policies and procedures designed to ensure that cross transactions are effected in a manner consistent with its fiduciary obligations. Such procedures generally require that (i) the transaction be effected at an independently determined market price consistent with applicable regulatory requirements; (ii) the transaction be executed in a manner that is fair and equitable to both participating client accounts; and (iii) Aquamarine maintain records of cross transactions in accordance with applicable regulatory requirements. Where required, Aquamarine will comply with the applicable provisions of the Advisers Act, including Section 206(3), and obtain appropriate client consent prior to effecting such transactions. Aquamarine does not currently expect cross trades to occur frequently but retains the ability to engage in such transactions when appropriate. Soft Dollar Arrangements The Adviser may receive research products and services from broker-dealers that execute securities transactions on behalf of clients, including the private funds advised by the Adviser. These research products and services may include, among other things, economic and market analyses, industry and company research, financial publications, portfolio valuation services, market data, pricing services, and other information or services that assist the Adviser in the investment decision-making process. Such research products and services may be provided by broker-dealers without a separate fee, but in consideration for the Adviser directing client brokerage transactions to those brokerdealers. These arrangements are commonly referred to as “soft dollar” arrangements. The Adviser may rely on the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934 (as amended and the rules and regulations promulgated thereunder, the “Exchange Act”), which permits an investment adviser to cause a client to pay a broker-dealer a commission for effecting a securities transaction in excess of the amount another broker-dealer

might have charged, if the Adviser determines in good faith that the commission paid is reasonable in relation to the value of the brokerage and research services provided. Research products and services obtained through soft dollar arrangements may benefit the Adviser and all of its clients collectively and may not be used exclusively for the accounts that generated the brokerage commissions used to obtain the research. As a result, a client may pay brokerage commissions that are used to obtain research services that benefit other client accounts or the Adviser’s overall investment process. The receipt of research products or services from broker-dealers creates a conflict of interest because the Adviser may have an incentive to select or recommend broker-dealers based on the Adviser’s interest in receiving these research benefits rather than solely on the basis of obtaining the most favorable execution for client transactions. The Adviser addresses this conflict by seeking to obtain best execution for client transactions and by periodically evaluating the reasonableness of brokerage commissions and the value of brokerage and research services received. Performance-Based Fees and Side-by-Side Management As discussed under Item 6, Aquamarine manages different types of Funds and Managed Accounts with different fee arrangements. Side-by-side management of different types of Funds and Managed Accounts raises potential conflicts of interest. Managed Accounts and Funds have varied fee structures, including a combination of asset- and performance-based compensation. Where (i) the actions taken on behalf of one client may affect other similar or different clients (e.g., because such client has the same or similar investment styles or otherwise competes for investment opportunities) and (ii) Aquamarine and its supervised persons have different interests in such clients (e.g., Aquamarine or its supervised persons are exposed to differing potential for gain or loss through different compensation structures, including circumstances where one client pays only asset-based fees while others are subject to performance-based or incentive fees or allocations), Aquamarine has an incentive to favor certain clients over others that are less lucrative to Aquamarine or its affiliates, or to favor clients in which it or its affiliates have a significant proprietary interest. In addition, when Aquamarine receives performance-based fees or allocations or Aquamarine portfolio management personnel have a financial incentive to achieve gains in excess of the disincentive to suffer losses, Aquamarine and/or such personnel have an incentive to choose investments that are riskier or more speculative than might otherwise be chosen. Aquamarine may also be incentivized to hold on to investments that have poor prospects for improvement in order to receive ongoing fees in the interim and, potentially, additional compensation if such asset’s value appreciates in the future. Depending on the structure of the arrangement, performance-based fees and allocations may provide for compensation to Aquamarine on unrealized gains and provide a financial disincentive to the client to terminate the advisory arrangement. To mitigate these conflicts, Aquamarine’s policies and procedures seek to provide that investment and valuation decisions are made based on the best interests of clients, in

accordance with applicable law, and without consideration of Aquamarine’s (or such personnel’s) pecuniary, investment or other financial interests.

Aquamarine’s decisions with respect to the market in which the transaction is to be competed, the form of transaction, and the allocation of orders among broker/dealers are made in accordance with this policy. With respect to any brokerage commissions charged by executing broker/dealers, Aquamarine will regularly review such charges and such comparative standards that it regards as pertinent for purposes of evaluating the reasonableness of such commissions. It is Aquamarine’s policy to seek to obtain best execution on client transactions and to execute client trades on the most advantageous terms reasonably available under the circumstances. Best execution is not limited solely to the consideration of the lowest available price or commission rate. For example, complicated high-volume transactions in securities, derivatives, or other investments require a broker-dealer with a higher level of competence and infrastructure to help ensure client transactions are executed without error, delay or needless expense. As a result, in seeking to obtain best execution, Aquamarine takes into account a number of factors and criteria, based on information available at the time, including but not limited to price of the security; any markup or mark-down on the security; and any commission paid to the broker-dealer. As permitted by law, Aquamarine can cause its clients to pay broker/dealers an amount of commission for executing a portfolio transaction order on behalf of its clients which is in excess of commissions other broker/dealers would have charged for effecting such a transaction. In order to do so, Aquamarine must determine in good faith that the higher commission is reasonable in relationship to the value of the services provided by the executing broker/dealer viewed in terms of either a particular transaction or Aquamarine’s overall responsibilities to the clients.

When considering client proxies, Aquamarine may determine not to vote a proxy in certain circumstances in accordance with its fiduciary duties or its agreement with a client. The Proxy Policy requires that Aquamarine identify and address conflicts of interest. If a material conflict of interest is identified, Aquamarine will determine whether voting in accordance with the guidelines set forth in the procedures is in the best interests of its client or whether taking some other action may be more appropriate. If a conflict is identified, Aquamarine will then make a determination (which may be in consultation with outside legal counsel or compliance consultants) as to whether or not the conflict is material. If a conflict is material, Aquamarine will determine what course of action is in the best interests of the client (which may include utilizing an independent third party to vote such proxies).