Trails Edge Capital Partners, LP: investment adviser

Trails Edge provides investment advisory services to private funds via a master feeder structure, whereby Trails Edge Biotechnology USA Fund, LP (the “Domestic Fund”), a Delaware limited partnership, and Trails Edge Biotechnology Offshore Fund, Ltd (the “Offshore Fund”) a Cayman Islands exempted limited partnership, together with the Onshore Fund, the “Feeder Funds”, invest substantially all of their assets in Trails Edge Biotechnology Master Fund, LP (the “Master Fund”), a Cayman Islands exempted limited partnership. Unless otherwise specified, the Domestic Fund, the Offshore Fund, and the Master Fund are each referred to as a “Fund” and collectively, as the “Funds”. The general partner of the Funds is Trails Edge Biotechnology Fund GP, LP (the “General Partner”), a Delaware limited partnership that is registered as a foreign limited partnership in the Cayman Islands. The General Partner has ultimate responsibility for decisions relating to management and operations made on behalf of the Domestic Fund, the Offshore Fund, and the Master Fund, and has ultimate responsibility for the investment decisions made on behalf of the Master Fund but has delegated certain responsibilities to Trails Edge via an investment management agreement. Trails Edge GP, LLC serves as the general partner of the General Partner (the “GP LLC”). Mr. Yehudai is the Sole Member of the GP LLC and controls the GP LLC. Additional detailed information about Trails Edge is provided below, including information about Trails Edge’s advisory services, investment approach, personnel, affiliations and brokerage practices. Trails Edge’s principal place of business is in Atlanta, GA. Trails Edge provides discretionary investment management services to the Funds pursuant to investment guidelines set forth in the relevant governing and offering documents of the Funds, including any limited partnership agreement, investment management agreement, private placement memorandum and/or subscription agreement, as the case may be (each an “Offering Document”, and collectively, the “Offering Documents”). Trails Edge does not tailor its advisory services to the individual investors (each an "Investor" and collectively the “Investors”), or provide Investors with the right to specify, or restrict the Funds’ investment objectives or any investment or trading decisions. Each Investor is strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant Offering Documents and the additional details about Trails Edge’s investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and each Fund’s Offering Documents) in considering whether Trails Edge’s advisory services, or an investment in the Funds are appropriate to its own circumstances, based on all relevant factors including, but not limited to, the Investor’s own investment objectives, liquidity requirements, tax situation and risk tolerance before making an investment decision. Trails Edge’s investment objective in advising the Funds is to achieve attractive investment returns over the long term on an absolute basis, regardless of overall market conditions or direction. Trails Edge intends to achieve this objective primarily through investments in long and short positions in the securities of biotechnology and pharmaceutical companies, with a concentration on mid- and smallcapitalization companies. Trails Edge deploys deep fundamental analyses of the underlying assets of such companies that are in preclinical stages or clinical development, that have products undergoing

regulatory review, or that have products that have been approved for commercial use, to uncover certain market inefficiencies that Trails Edge believes cause either market over-valuations or undervaluations of the companies’ securities. Trails Edge may also make certain investments that, in Trails Edge’s sole and absolute discretion, it deems at the time of such investment to be illiquid or without a readily ascertainable market value, including investments in private securities (each such investment, a “Designated Investment” and collectively, the “Designated Investments”). Such Designated Investments may include, but will not be limited to, investments in late-stage private companies in the biopharmaceutical industry. If an Investor desires to participate in Designated Investments, the Investor must indicate such in the Subscription Agreement of the Fund, at the time of such Investor’s initial subscription. Trails Edge does not participate in wrap fee programs. As of December 31, 2025, Trails Edge managed approximately $933,350,499 in regulatory assets under management attributable to the Funds, all on a discretionary basis.

The amount of such Management Fee will be calculated by considering the lower of the fair value or the cost basis of such Designated Investment. Management Fees are generally pro-rated for partial periods. Trails Edge may reduce, waive or calculate differently the Management Fee for certain Investors in the Feeder Funds. It is anticipated that no Management Fee will be paid with respect to interests held (directly or indirectly) by or for the benefit of the Principal, employees of Trails Edge or its affiliates, or immediate family members of such parties. Other Fees and Expenses Organizational and Offering Expenses of the Funds The Funds will bear all of their Organizational and Offering Expenses on a pro rata basis and will reimburse the Trails Edge, the General Partner, and/or the Principal, as applicable, to the extent that any of them bears organizational or offering expenses on behalf of the Funds. Such organizational and offering expenses will include, without limitation, all costs and expenses incurred in connection with the Funds’ formations and the marketing, offering, and sale of the Interests, including, but not limited to, legal and accounting fees and expenses, registration fees, filing fees, and all costs and expenses incurred in connection with the preparation of offering and organizational documents, marketing and similar materials, and drafting and negotiating contracts with service providers in connection with the

launch of the Funds. Operating Expenses

In general, the Funds will bear all of their operating expenses on a pro rata basis (collectively, the “Fund Expenses”), which expenses will include, without limitation: (a) Organizational and Offering Expenses; (b) expenses associated with all investments and transactions considered, evaluated, and/or consummated by the Funds, as well as overall consideration and evaluation of the Funds’ portfolio, including, without limitation, those expenses incurred before the initial closing of the Funds, including, without limitation, expenses associated with sourcing, negotiating, investigating, researching, financing, and structuring of investments and potential investments, whether or not consummated, analysis, thirdparty research, data (including, without limitation, market data, risk data, factor data, big data, and alternative data), analytics, modeling, risk, structuring, pricing, execution, and other third-party information systems, including, without limitation, installation and maintenance, information technology hardware, software, or other technology and service fees (including, without limitation, the expenses with respect to data, data feeds, subscriptions, expert networks, political intelligence providers, and reports); (c) the costs of research-related computer hardware and software, including, without limitation, Bloomberg terminals and subscriptions and other market information systems, as well as the costs of research management systems and corporate access tracking systems; (d) the costs of Trails Edge’s portfolio management system and any other software used for accounting and/or monitoring of the portfolio, including, without limitation, subscriptions relating to, among other things, trading and order management systems and services; (e) expenses associated with holding, financing, monitoring, hedging, maintaining, and disposing of all investments of the Funds and all transaction and other costs associated therewith, including, without limitation, expenses associated with proxy research and voting services; (f) travel and entertainment and related expenses for research and investment purposes; (g) professional fees associated with investments and potential investments, including, without limitation, consulting, due diligence, accounting, valuation, financial, legal, and other advisory fees and expenses; (h) transaction fees, brokerage commissions, custodial fees, clearing and settlement charges, bank service fees, and similar fees and expenses associated with the acquisition, disposition, and settling of investments and potential investments, including, without limitation, in connection with outsourced trading; (i) expenses associated with legal and regulatory filings of the Funds in the United States, the Cayman Islands, or in any other jurisdiction (including, without limitation, pursuant to Sections 13 and 16 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”); (j) administrative, custodial, appraisal, valuation, legal, regulatory, compliance, consulting, advisory, and similar fees and expenses associated with the Funds’ operations, investments, and transactions, including, without limitation, fees and expenses of the fund administrator, and fees of any service provider engaged to verify the work of the fund administrator, which include, but are not limited to, valuation agents, the costs of client relationship management systems, or regulatory matters with respect to the Funds and any anti-money laundering officer fees with respect thereto; (k) costs and expenses of leverage or any other borrowings, if used, of the Funds, including, without limitation, financing costs, bank service fees, and interest charges and fees; (l) expenses incurred in the collection of monies owed to the Funds, as applicable; (m) auditing and accounting expenses of the Funds, including, without limitation, expenses associated with the preparation of financial statements, tax returns, and Schedules K-1, and the fees and expenses of the auditor; (n) the Funds’ proportional share of broken-deal, failed transaction, break- up, and similar fees, costs, and expenses (if any) applicable to the Funds; (o) any entity-level taxes, fees, or other governmental charges to the Funds, including, without limitation, any withholding taxes not due to the status or noncompliance of a particular Investor; (p) costs and expenses associated with investor communications and reports and the delivery thereof to Investors, as well as costs and expenses associated with preparing and updating investor disclosures related thereto; (q) the costs of service providers or software to measure or monitor risk metrics, to aggregate positions, and/or to provide reporting with respect to risk metrics and/or positions; (r) costs and expenses associated with materials for and meetings with the Investors, including, without limitation, the reasonable costs of Trails Edge’s travel to such meetings; (s) insurance expenses, including, without limitation, general partner liability insurance and other policies, if any, as

well as the Funds’ share of expenses with respect to directors’ and officers’ liability insurance and errors and omissions insurance, casualty and property, cyber liability, and/or other risk-specific insurance, and “key-man” life insurance on certain personnel; (t) costs and expenses (including, without limitation, entity-level taxes, fees, or other governmental charges) associated with the formation, organization, and operation of any subsidiary, special purpose vehicle, alternative investment vehicle, holding company, or similar entity formed with respect to investments, credit facilities, or other transactions entered into for the benefit of the Funds; (u) wind-up, liquidation, termination, strike off, and dissolution expenses; (v) costs, fees, and expenses related to the Funds’ registration, qualification, and/or exemption under, or compliance with, any applicable U.S. federal, state, local, or non-U.S. laws, rules, or regulations, including, without limitation, blue sky fees, Form D, Form 8.3, filings with the National Futures Association and the Commodity Futures Trading Commission, if applicable, FATCA compliance, costs and expenses relating to accepting subscriptions from Investors in certain non-U.S. jurisdictions, and notices and other securities and/or investment-related filing expenses applicable to the Funds; (w) costs related to any transfer of interests, unless otherwise charged to or borne by the applicable transferor and/or transferee; (x) expenses incurred in connection with the preparation of any amendment to the Offering Documents, including the preparation or amendment of any Side Letter; (y) expenses incurred in connection with pursuing, defending, or participating in any litigation, arbitration, mediation, or similar proceeding by the Funds; (z) any extraordinary expenses (including, without limitation, all litigation- related and indemnification and contribution expenses, including, without limitation, the amount of any judgment or settlement paid in connection therewith); (aa) the Management Fee; and (bb) all other fees, costs, charges, and expenses associated with the business, affairs, and/or operations of the Funds, including, without limitation, any other cost that may otherwise be paid by the Master Fund with soft dollars, as applicable, pursuant to Section 28(e) of the Exchange Act. In general, each Investor will bear its proportionate share of the Fund Expenses on a pro rata basis with respect to the size of the Investor’s investment(s). The General Partner may, however, allocate expenses on another basis, including by allocating certain expenses to certain (but not all) Investors, if the General Partner determines that such an allocation is more equitable. In addition, any Fund Expenses attributable solely to investments in “new issues” or solely to Designated Investments will be paid pro rata by only those Investors participating in such investments with respect to their relative interest in such investments. Further, the General Partner will have the right to charge any Investor, and not treat as a Fund Expense, any expense attributable to a single Investor or a small group of Investors, including, without limitation, additional accounting expenses incurred in providing a calculation of “unrelated business taxable income,” if any, to particular Investors. From time to time, Trails Edge, the General Partner, and/or their affiliates may elect to bear certain expenses on behalf of the Funds that would otherwise be Fund Expenses. Trails Edge, the General Partner, and/or their affiliates will not have any obligation to bear such expenses and may elect at any time (in whole or in part) to cease bearing such expenses on behalf of the Funds. Trails Edge, the General Partner, and/or the Principal may advance funds on behalf of the Funds, and Trails Edge, the General Partner, and the Principal, as the case may be, will be reimbursed by the Funds for such advanced amounts.

That is, if an Investor’s capital account has a net loss in any fiscal year (or other relevant period, as applicable), this loss will be recorded and carried forward as to such capital account to future fiscal years (or other relevant periods) (such amount is referred to as the “Loss Carryforward”). The General Partner will not receive the Incentive allocation with respect to an Investor’s capital account in any future fiscal year (or other relevant period) until the Loss Carryforward amount for such capital account has been recovered. Once the Loss Carryforward has been recovered, the Incentive Allocation will be based on the excess profits (over the Loss Carryforward amount) as to such capital account, rather than on all profits. When an Investor withdraws capital, any Loss Carryforward will be adjusted downward in proportion to the withdrawal. With respect to any Investor (including any affiliates and/or employees of Trails Edge or the General Partner), the General Partner will have the right to reduce, waive, assign, grant participation in, or otherwise share the Incentive Allocation, without the consent of, or notice to, any other Investor. It is anticipated that no Incentive Allocation will be allocated with respect to its interests held (directly or indirectly) by or for the benefit of the Principal, employees of Trails Edge or its affiliates, or immediate family members of such parties. No Incentive Allocation will be made with respect to any Designated Investment until such Designated Investment is sold, liquidated, or no longer deemed to be a Designated Investment by Trails Edge. Fund assets are expected to be managed in the Master Fund, therefore Trails Edge does not expect to face any side-by-side conflict of interest issues, such as allocation decisions which may be impacted by performance-based fee differentials. Trails Edge has developed and implemented procedures that are designed to ensure that all clients are treated fairly and equally, and to prevent conflicts from influencing the allocation of investment opportunities among clients. The terms of the performance-based fees and Incentive Allocations may differ in the future among the Funds or other accounts managed by Trails Edge. This may result in a conflict of interest when Trails Edge allocates opportunities among such clients because there will be an incentive to favor allocations to clients that have higher performance-based fees and Incentive Allocations. To avoid such conflict of interest, Trails Edge would generally follow documented procedures in allocating opportunities among its clients which would not take into account the performance-based fees and Incentive Allocations to which such clients are subject.

defined under Rule 3c-5 of the Company Act and must meet other suitability requirements. Interests may not be purchased by non-resident aliens, foreign corporations, foreign partnerships, foreign trusts or foreign estates, all as defined in the Internal Revenue Code. The Subscription Agreement contains representations and questionnaires relating to these qualifications. Offshore Fund Each Investor generally must be either (i) a non-U.S. Person or (ii) a Permitted U.S. Person that qualifies as an “accredited investor,” as defined in Regulation D under the Securities Act, and either a “qualified purchaser,” as defined in the Company Act, or a “knowledgeable employee,” as defined under Rule 3c-5 of the Company Act, and must meet other suitability requirements. The Subscription Agreement contains representations and questionnaires relating to these qualifications.

Trails Edge deploys deep fundamental analyses of the underlying assets of such companies that are in preclinical stages or clinical development, that have products undergoing regulatory review, or that have products that have been approved for commercial use, to uncover certain market inefficiencies that Trails Edge believes cause either market over-valuations or under-valuations of the companies’ securities. Such fundamental analyses include, but are not limited to, identifying and analyzing scientific, medical, clinical, regulatory, financial, managerial, commercial, patent, and/or other factors that may affect the companies. Furthermore, Trails Edge continually assesses a company’s valuation relative to both its future prospects on a risk/reward basis and any new analyses, each of which separately or together could impact Trails Edge’s investment decisions. Trails Edge expects that the Master Fund’s portfolio will consist of between twenty (20) to thirty-five (35) long positions, and fifteen (15) to twenty-five (25) short positions, at any given time. Trails Edge may very selectively use derivative instruments such as options to enhance a risk/return profile. Trails Edge has broad discretion to employ any trading, investment, or hedging technique that it deems appropriate in relation to the investment objective without obtaining the consent of, or providing notice to, the Investors. The investment strategy is not limited with respect to non-U.S. investments, though non-U.S. investments would generally occur in developed markets. In addition, from time to time, Trails Edge, on behalf of the Funds, may evaluate and make certain Designated Investments, as further described in this Memorandum. The Funds do not expect to employ leverage in connection with its investment strategies or for any other purpose. Investment Process The investment process is driven by Trails Edge’s investment team working closely with the Principal to uncover opportunities based on deep fundamental research and analysis. Proprietary tools and databases are typically used to assist in the decision-making process. Given the focus on mid- and small-capitalization biotechnology and pharmaceutical companies, Trails Edge’s investment team spends a substantial amount of time vetting opportunities based on medical and scientific information and developments, in addition to, among other considerations, intellectual property, financial,

managerial, and competitive factors. The Principal further evaluates liquidity, industry, and market dynamics as part of its investment consideration. Though Trails Edge will endeavor to construct the portfolio in such a manner that balances the benefits of both concentration and diversification, Trails Edge is not restricted as to the percentage of the Funds’ assets that may be invested in any particular issuer, instrument, market, or strategy. In advising the Funds, Trails Edge is not and will not maintain any fixed requirements for diversifying its portfolio. In attempting to maximize the Funds’ returns, Trails Edge may concentrate the holdings of the Funds in those issuers, instruments, markets, or strategies which in the sole judgment of Trails Edge provide the best profit opportunities consistent with the Funds’ investment objective. Consequently, a loss in any such concentrated position could ultimately result in significant losses to the Funds and a proportionately higher reduction in the net asset value of the Funds than if its capital had been spread over a wide number of positions. Flexibility In advising the Funds, Trails Edge has complete flexibility to create or organize (alone or in conjunction with others including Trails Edge’s affiliates) or otherwise utilize special purpose subsidiaries, affiliates, feeders, or other special purpose investment or financing vehicles, swaps or other derivatives or structured products to access investments, particularly in instances where Trails Edge, in its sole discretion, determines that there is a potential tax, regulatory, financial, confidentiality, or other advantage to such structured product, instrument, or entity. Trails Edge has broad discretion to employ any trading, investment, or hedging technique that it deems appropriate in relation to the investment objective without obtaining the consent of, or providing notice to, the Investors. Designated Investments As discussed, up to a certain limit, Trails Edge may cause the Master Fund (for those Investors who elect to participate in Designated Investments) to make certain investments that, in Trails Edge’s sole and absolute discretion, Trails Edge deems at the time of such investment to be illiquid or without a readily ascertainable market value, including investments in private securities. Such Designated Investments may include, but will not be limited to, investments in late-stage private companies in the biopharmaceutical industry. Risk of Loss Factors Investing in securities involves risk of loss that investors should be prepared to bear. The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Funds. Each Fund’s Offering Documents provides a detailed description of the risks of investing in the Funds. Limited Operating History. The Funds, Trails Edge and the General Partner are newly formed entities and do not have any operating history upon which prospective Investors can evaluate their anticipated performance. There can be no assurances that the Funds, the General Partner or Trails Edge will be successful. The success of the Fund depends on the ability of Trails Edge to manage the Funds and effectively implement their investment programs. The Funds’ Offering Documents do not permit the Investors to participate in the management and affairs of the Funds. If Trails Edge were to lose the services of its Principal, or the Funds were to incur substantial losses, Trails Edge might not be able to provide the same level of service to the Funds as it has in the past or continue operations. The loss of the services of Trails Edge could have a material adverse effect on the Funds and the investments therein.

No Control by Investors. Investors will have no authority to make decisions or to participate in the day-to-day management of, or exercise business discretion with respect to, the Funds. The sole authority to make investment decisions is vested in Trails Edge and the General Partner. Accordingly, no Investor should invest in the Funds unless it is willing to entrust all aspects of the management of the Funds to such parties. In addition, Investors do not have an opportunity to evaluate the specific investments made by the Master Fund or to evaluate the terms of any investments made by the Master Fund. The operations of the Funds are substantially dependent upon the skill, judgment, and expertise of Trails Edge and the General Partner. Lack of Transferability of the Interests. The Funds are intended for long-term Investors who can accept the risks associated with investing primarily in securities that involve a high degree of financial risk. There is no public market for the interests, and no such market is expected to develop in the future. The interests in the Funds generally may not be, directly or indirectly, transferred, sold, assigned, pledged, or otherwise encumbered or disposed of without the prior written consent of the General Partner, which consent may be granted or withheld in the General Partner’s sole and absolute discretion. Prospective Investors are required to represent that they will be acquiring their interests for investment purposes only and not with a view to resale or distribution. The interests have not been registered under the Securities Act or any state securities laws. Therefore, they are subject to restrictions on transfer under the Securities Act and under certain states’ securities laws. Accordingly, the General Partner may require an opinion of counsel satisfactory to the General Partner that, among other things, a proposed transfer of interests is exempt from registration prior to consenting to any such transfer. No trading market for the Interests exists or is expected to develop. Master-Feeder Structure. Both the Onshore Fund and the Offshore Fund will invest all of their investable assets through a “master-feeder” structure in the Master Fund. Although a common investment fund structure, the “master-feeder” fund structure presents certain unique risks to investors. For example, a smaller feeder fund investing in the Master Fund may be materially affected by the actions of a larger feeder fund (or larger direct investor) investing in the Master Fund. If a larger feeder fund (or larger direct Investor) withdraws from the Master Fund, the remaining feeder fund may experience higher pro rata operating expenses, thereby producing lower returns. The Master Fund may become less diverse due to a withdrawal by a feeder fund or direct Investor, resulting in increased portfolio risk. Expenses or liabilities of the Master Fund arising from any legal proceedings by or against the Master Fund would be borne by the Master Fund, and creditors of the Master Fund may enforce claims against all assets of the Master Fund. Trails Edge cannot enter into separate transactions or make different investment decisions with respect to the Onshore Fund and the Offshore Fund, respectively. Accordingly, all transactions entered into, and investment decisions made by, Trails Edge on behalf of the Master Fund will affect both the Onshore Fund and the Offshore Fund, notwithstanding that the Investors of the Onshore Fund and the Offshore Fund may have different tax concerns. The “master-feeder” structure may therefore result in transactions and investment decisions that are less tax-efficient for the Investors than they would be if the Onshore Fund and the Offshore Fund were “parallel funds” that directly engaged in transactions and made investment decisions. Business and Regulatory Risks of Alternative Investment Funds. The financial services industry generally, and the activities of alternative investment funds and their managers in particular, have been subject to intense and increasing regulatory scrutiny. Such scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance, and other related costs. Increased regulatory oversight may also impose additional administrative burdens on Trails Edge and the General Partner, including, without limitation, responding to examinations, investigations, and document requests, implementing new policies and procedures, and complying with recordkeeping and reporting obligations. Such burdens may divert such parties’ time, attention, and resources from portfolio management activities. The regulatory environment for alternative investment funds is evolving, and changes in the regulation

of private funds and their investing activities may adversely affect the ability of the Master Fund to pursue its investment program and the value of the investments held by the Master Fund. There has been an increase in governmental, as well as self-regulatory, scrutiny of the alternative investment industry in general. It is impossible to predict whether changes in regulations may occur, but any regulations that restrict the Funds’ activities could have a material adverse effect on the Master Fund’s investments. In addition, such regulatory scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance, and other related costs. The Offering Documents of the Funds cannot address or anticipate every possible current or future regulation that may affect Trails Edge, the General Partner, the Funds, or their businesses. Such regulations may have a significant impact on the Funds, including, without limitation, restricting the types of investments the Master Fund may make, preventing the Master Fund from exercising its voting rights with respect to certain financial instruments, requiring the Funds to disclose the identity of their Investors, or otherwise. The General Partner may, in its sole and absolute discretion, cause one or more of the Funds to be subject to such regulations if it believes that an investment or business activity is in the Funds’ interest, even if such regulations may have a detrimental effect on one or more Investors. Prospective Investors are encouraged to consult their own advisors regarding an investment in the Funds. Lack of Liquidity; Limitations on Withdrawals. Voluntary withdrawals by the Investors are limited and may be made only at specified times described elsewhere herein. The General Partner may find it necessary to establish one or more reserves for contingent liabilities, such as in connection with pending litigation, by withholding a certain portion of the amount payable in connection with the withdrawal until resolution of such contingencies. There can be no assurances that an Investor will be able to sell the securities received for the amount at which the securities were valued for purposes of the withdrawal. The risk of a decline in the value of such securities in the period from the relevant withdrawal date to the date upon which such securities are distributed to the withdrawing Investor, and the risk of any loss or delay in liquidating such securities, will be borne by the withdrawing Investor. The General Partner also may require that any Investor withdraw all or a portion of its capital account. Distributions, other than permitted withdrawals, are solely at the discretion of the General Partner. It is the intention of the General Partner to accumulate capital in the Funds and not to make any discretionary distributions (including dividends) to Investors other than with respect to withdrawals. The General Partner will have the right to make withdrawals from time to time, including, without limitation, withdrawals to pay taxes on gains or income generated by Master Fund results. Where a withdrawal request is accepted, the interests will be treated as having been withdrawn with effect from the relevant withdrawal date irrespective of whether or not such withdrawing Investor has been removed from the register of Investors of the applicable Feeder Fund, the withdrawal has been reflected in the record of contributions, or the withdrawal proceeds remitted. General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If Trails Edge’s evaluation of an investment opportunity should prove incorrect, the Master Fund could experience losses as a result of a decline in the market value of securities in which the Master Fund holds a long position, or an increase in the value of securities in which the Master Fund holds a short position. The Master Fund’s investment program will include short sales, which can involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Funds may be subject. The risk management techniques that may be used by Trails Edge do not provide any assurance that the Funds will not be exposed to a risk of significant investment losses. No guarantee or representation is made that the Master Fund’s investment program will be successful, that the Master Fund will achieve its targeted returns, or that there will be any return of capital to Investors. In addition, investment results may vary substantially over time. General Economic and Market Conditions. The success of the Funds’ activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates,

economic uncertainty, changes in laws (including laws relating to taxation of the Master Fund’s investments), tax considerations and tax treatment, trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts, and security operations). These factors may affect the level and volatility of the prices and liquidity of the Master Fund’s investments and could impair the Funds’ profitability or result in losses. Trails Edge may consider some or all of these factors when making trading decisions. The Funds could incur material losses even if Trails Edge reacts quickly to difficult market conditions, and there can be no assurance that the Funds will not suffer material losses and other adverse effects from broad and rapid changes in market conditions in the future. Investors should realize that markets for the financial instruments in which the Master Fund will seek to invest can correlate strongly with each other at times or in ways that are difficult for Trails Edge to predict. Even a well-analyzed approach may not protect the Funds from significant losses under certain market conditions. Availability of Suitable Investments. The success of the Master Fund’s investment and trading activities depend on the ability of Trails Edge to identify overvalued and undervalued investment opportunities and to manage market risk. Identification and exploitation of the investment strategies to be pursued by the Master Fund involves a high degree of uncertainty. No assurance can be given that Trails Edge will be able to identify suitable investment opportunities in which to deploy all of the Master Fund’s capital. A reduction in overall market volatility and liquidity, as well as other market factors, may reduce the pool of profitable investments for the Master Fund. Certain of the investment strategies employed by the Master Fund may be based on historical relationships among securities prices, exchange rates, interest rates, and bond prices. There can be no assurance that these historical relationships will continue. No representation is made by Trails Edge as to what results the Funds will or are likely to achieve based on these trends and relationships. Inside Information. From time to time, Trails Edge or its affiliates may come into possession of material, non-public information concerning a company, and the possession of such information may limit the ability of Trails Edge to cause the Master Fund to buy or sell the securities issued by such company at times when Trails Edge might otherwise wish to cause the Master Fund to buy or sell such securities. Concentration of Investments; Limited Diversification. The Master Fund may hold a limited amount of positions at any given time and the Master Fund may hold relatively large positions in few securities. As a result of the Master Fund’s possible lack of diversification, a significant loss in any one position may have a material adverse effect on the net asset value of the Funds and their rate of return. Likewise, any fluctuation in the overall value of securities in specific industries or sectors likely will have a material effect on the performance of the Funds. Uncertain Exit Strategies. Trails Edge may not be able to predict the ultimate exit strategy for certain investments of the Master Fund, including the Designated Investments and other illiquid investments, or that an exit strategy that preserves or realizes the value of an investment will definitely be available within a reasonable time or at a time consistent with Trails Edge’s investment thesis in respect of such investment. Exit strategies that appear to be viable when an investment is initiated may be precluded by the time the investment is ready to be realized due to economic, legal, political, regulatory, or other factors. As a result, the Master Fund may be unable to dispose of certain illiquid investments in any particular timeframe or at a price that Trails Edge deems advantageous. Trade Error Risk. Trade errors include, for example, keystroke errors that occur when entering trades into an electronic trading system, or typographical or drafting errors related to derivatives contracts or similar agreements. Trade errors may occur, notwithstanding the execution of due care and special procedures designed to prevent such errors. If trading errors do occur, Trails Edge will not be responsible for gains or losses resulting from trade errors, except where such trade error is the result of Trails Edge’s gross negligence, willful misconduct, or fraud.

Competition. The securities industry is extremely competitive. Trails Edge will compete for investment opportunities against various other investors, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs. Competitive investment activity by other firms may reduce the Master Fund’s opportunity for profit by reducing the availability of or increasing the price of what the Master Fund believes to be, based on its investment criteria, exceptional investment opportunities. In addition, the success of the Funds is dependent, in part, upon the talents and efforts of highly skilled individuals. Trails Edge faces intense competition in attracting and retaining successful personnel. Trails Edge’s ability to continue to compete effectively will depend upon its ability to identify and attract new successful personnel, and retain and motivate existing successful personnel, and the failure to do so may have a material adverse effect on the Funds. The investment management field is highly competitive and there are few barriers to entry. As a result, the personnel are constantly facing new competition for profitable transactions, and successful portfolio managers from existing firms may form new firms engaged in strategies similar to those employed by Trails Edge. To the extent any such competitors are successful, the opportunities available to the Funds, and their potential profitability, may be reduced. Risk of Operations/Liquidity Risks. Although the securities that the Master Fund may acquire generally will be traded on public exchanges, each exchange typically has the right to suspend or limit trading in all securities that it lists. Such a suspension could render it difficult or impossible for the Master Fund to liquidate its positions and would thereby expose it to losses. In addition, some of the securities in which the Master Fund may invest may be thinly traded, potentially making it difficult for the Master Fund to dispose of a position at the time or price desired. Moreover, in periods of extreme market volatility, the bid/ask spreads for some securities that ordinarily are liquid may widen, making it difficult or undesirable to sell the securities. There can be no assurance that the trading markets will remain liquid enough for management to close out existing positions at any time there is a need to do so. There may be a variety of other reasons why a security in which the Master Fund may invest may be illiquid, and, in such event, the Master Fund may have similar issues with realizing such security. Counterparty Risk. Brokers may trade with an exchange as principals on behalf of the Master Fund, in a “debtor-creditor” relationship, unlike other clearing broker relationships where the broker is merely a facilitator of the transaction. Such broker could, therefore, have title to all of the assets of the Master Fund (for example, the transactions that the broker has entered into on behalf of the Master Fund as principal, as well as the margin payments that the Master Fund provides). In the event of such broker’s insolvency, the transactions into which the broker has entered as principal could default, and the Master Fund’s assets could become part of the insolvent broker’s estate, to the detriment of the Funds. The Master Fund’s assets may be held in “street name,” in which case, a default by the broker could cause the Master Fund’s rights to be limited to that of an unsecured creditor. To the extent that the Master Fund invests in swaps, derivative, or synthetic instruments, or other over-the-counter transactions, including forward contracts, or non-U.S. securities, the Master Fund may also take a credit risk with respect to the parties with whom it trades and may bear the risk of settlement default. These risks may differ materially from those entailed in exchange-traded transactions, which generally are backed by clearing organization guarantees, daily marking-to-market and settlement, and segregation and minimum capital requirements applicable to intermediaries. Transactions entered into directly between two counterparties generally do not benefit from such protections and expose the parties to the risk of counterparty default. In addition, no restrictions have been imposed by Trails Edge or the General Partner on the collateral and asset reuse or re-hypothecation arrangements to which the Master Fund may agree with its brokers and custodians, and the Master Fund’s prime broker and trading agreements may contain certain provisions that allow a counterparty to either terminate the relevant agreement or require additional levels of collateral, as applicable, for various reasons. The termination of the relevant

agreement may result in immediate payment by the Master Fund of the mark-to-market amount, or net liability, due under the agreement, and, if not immediately replaced, a loss of the previously held investment and/or hedging exposure. Discretion and Changes in Investment Strategy. Trails Edge has considerable discretion in choosing the securities that may be acquired and the terms of the transactions to be entered into, and, subject to its fiduciary duties, it has the right to modify the investment strategy, selection criteria, or hedging techniques used by the Master Fund without the consent of the Investors. New investment strategies and techniques may not be thoroughly tested in the market before being employed and may have operational or theoretical shortcomings which could result in unsuccessful trades and, ultimately, losses to the Funds. In addition, any new investment strategy or technique developed by Trails Edge may be more speculative than earlier investment strategies and techniques and may involve material and as-yet-unanticipated risks that could increase the risk of an investment in the Funds. Investment Judgment. The profitability of a significant portion of the Master Fund’s investment program depends to a great extent upon correctly assessing the future prospects of companies and future price movements of securities and other investments. There can be no assurance that Trails Edge will be able to predict accurately the long-term results of any security or other investment. Equity Securities Generally. The Master Fund may invest in equity and equity-related securities, including, without limitation, equity investments acquired in connection with restructured debt securities or instruments, or in connection with reorganizations and/or restructurings of debt securities, equity securities, or other obligations and assets of undervalued, operationally challenged, and/or financially troubled companies or institutions. A risk of investing in the Funds is that equity securities held by the Master Fund may decline in value. Equity securities fluctuate in value in response to many factors, including the activities and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates, general economic environments, and/or certain geopolitical events. In addition, equity securities that the Trails Edge believes are undervalued or incorrectly valued may not ultimately be valued by the markets in the manner that Trails Edge anticipates. Small- to Medium-Capitalization Companies. The Master Fund expects to invest primarily in small- and mid-capitalization investments. Investments in securities of small- and mid-capitalization companies involve higher risks in some respects than do investments in securities of larger companies. The prices of securities of small- and even mid-capitalization companies are often more volatile than prices of securities of larger capitalization companies and the risk of bankruptcy or insolvency of many smaller companies (with the attendant losses to investors) may be higher than for larger capitalization companies. Due to lower trading volume in the securities of some small and mid-capitalization companies, an investment in those companies may be less liquid. Finally, small- and mid-capitalization securities may, at times, significantly underperform large capitalization securities and may do so in the future. Value-Driven Equities. Investing in value-driven equities entails several risk factors that investors should consider. First, these stocks may face prolonged periods of undervaluation, leading to potential underperformance compared to growth stocks in bull markets. Second, there is the risk of value traps, where stocks appear cheap based on traditional valuation metrics, but continue to decline in value due to fundamental weaknesses. Third, economic downturns or industry-specific challenges can disproportionately affect value stocks, as they often operate in cyclical or troubled sectors. Fourth, regulatory changes or shifts in consumer preferences can erode the perceived value of certain equities, impacting their market prices. Finally, liquidity risk is also a concern, especially with smaller or less liquid value stocks, which may face difficulties in buying or selling large positions without significantly impacting prices.

Distressed Securities. The Master Fund may invest in securities issued by companies in weak and/or deteriorating financial condition, experiencing poor operating results, needing substantial capital investment, facing special competitive or product obsolescence problems, or involved in bankruptcy or reorganization proceedings. Securities of this type may involve substantial financial and business risks, which are often heightened by an inability to obtain reliable information about the issuers. Among the risks inherent in investments in troubled companies is the fact that it frequently may be difficult to obtain information as to the true condition of such companies. Such investments may also be adversely affected by laws relating to, among other things, fraudulent transfers and other voidable transfers or payments, lender liability, and the bankruptcy court’s power to disallow, reduce, subordinate, or disenfranchise particular claims. Such companies’ securities may be considered speculative, and the ability of such companies to pay their debts on schedule could be affected by adverse interest rate movements, changes in the general economic climate, economic factors affecting a particular industry, or specific developments within such companies. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial difficulties is unusually high. There is no assurance that the Master Fund will correctly evaluate the value of the assets underlying distressed securities or the prospects for a successful reorganization or similar action. Investments of this type are complex in their analysis, require significant resources, and may involve substantial financial and business risk, and can result in significant or even total losses to the Funds. The market for distressed securities is expected to be less liquid than the market for securities of companies that are not distressed. A substantial length of time may be required to liquidate such securities. Furthermore, at times, a major portion of an issue of distressed securities may be held by relatively few investors, and the market may be limited to a narrow range of potential counterparties, such as institutions and investment banks. Under adverse market or economic conditions, or in the event of adverse changes in the financial condition of the issuer, the Master Fund may find it more difficult to sell such securities when Trails Edge believes it advisable to do so or may only be able to sell such securities at a loss. The Master Fund may also find it more difficult to determine the fair market value of distressed securities for purposes of computing the Funds’ net asset value. In some cases, the Master Fund may be prohibited by contract from selling distressed securities for a period of time. There is, therefore, a significant risk that the investment by Trails Edge in advising the Master Fund in companies involved in distressed securities could expose the Funds to significant losses. Special Situations Investments. The Master Fund may invest in the securities of issuers involved in, or the target of, acquisition attempts or tender offers, or in companies involved in or undergoing workouts, liquidations, spin-offs, reorganizations, bankruptcies, or other catalytic changes or similar transactions. In any investment opportunity involving any such type of special situation, there exists the risk that the contemplated transaction either will be unsuccessful, take considerable time, or will result in a distribution of cash or a new security, the value of which will be less than the purchase price to the Master Fund of the security or other financial instrument in respect of which such distribution is received. Similarly, if an anticipated transaction does not in fact occur, the Master Fund may be required to sell its investment at a loss. Because there is substantial uncertainty concerning the outcome of the transactions involving financially troubled companies in which the Master Fund may invest, there is a potential risk of loss by the Master Fund of its entire investment in such companies. Possible Illiquidity of Investments; Investments in Restricted Securities; Designated Investments. Trails Edge may cause the Master Fund to make certain investments in Designated Investments that, in Trails Edge’s sole and absolute discretion, Trails Edge deems at the time of such investment to be illiquid or without a readily ascertainable market value, including investments in private securities. Such investments may include, but will not be limited to, investments in late-stage private companies in the biopharmaceutical industry. Such Designated Investments may not be readily disposable and, in some cases, may be subject to contractual, statutory, or regulatory prohibitions on disposition for a specified period of time. For example, the Master Fund generally cannot sell certain restricted securities publicly in the United States without the expense and time required to register the securities under the

Securities Act and may not otherwise sell such securities in the United States unless such sale is exempt from registration under the applicable provisions of the Securities Act. Any such market or legal restrictions, or any contractual transfer limitations, on the Master Fund may result in the relative illiquidity of certain of the Master Fund’s investments, preventing or delaying any sale thereof, or reducing the amount of proceeds that might otherwise be realized from their sale. The market value of Designated Investments may fluctuate with, among other things, changes in prevailing interest rates, general economic conditions, the condition of financial markets, developments or trends in any particular industry, the financial condition of the issuers of the securities or other financial instruments in which the Master Fund invests, and certain geopolitical events. Short Sales. Trails Edge may engage in short selling on behalf of the Master Fund. Short selling involves selling securities that are not owned by the Master Fund. A short position is established when the Master Fund borrows securities from securities brokers or other institutions and sells them in an open market transaction with an obligation to return the borrowed securities at a later date. Short selling allows the Master Fund to profit from the decline in the price of the securities by purchasing the securities at a price that is lower than the price at which they were initially sold, in each case, to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. In addition, short sales may act as a hedge against long positions in the same or related securities in the Master Fund’s portfolio in the event that the price of securities decline. However, a short sale creates the risk of unlimited loss because in order to close out a short position, the Master Fund would need to return the borrowed securities by purchasing such securities at prevailing market prices. Specifically, the price of the subject security could rise without limit, thus increasing the cost to the Master Fund of buying those securities in order to close out the short position. There can be no assurance that the security necessary to close out a short position will be available for purchase. Purchasing securities to close out the short position can itself cause the price of the securities to rise further if the demand to buy such securities outpaces the available supply, thereby exacerbating the loss. For instance, a so-called “short squeeze” can occur when the price of securities in which the Master Fund has an open short position rise sharply in a short time frame. The rapid rise may be a result of (i) multiple short sellers seek to cover their short positions in the same time frame by purchasing the security, resulting in a rapid price increase, (ii) market participants collectively purchase a significant amount of shares, thereby causing a substantial increase in the price of such securities, and/or (iii) one or more lenders of a security that was used to facilitate a short position suddenly demand the return of the security that has been loaned. A “short squeeze” may result in the Master Fund having to prematurely close out short positions at unattractively high prices, resulting in a substantial loss. Further, the risk of a “short squeeze” likely will increase if other short sellers, market participants, and/or lenders become aware of the Master Fund’s short positions, including, without limitation, as a result of legally required reporting with respect to the Master Fund’s ownership of options to purchase the underlying security being shorted. In the instance where securities lenders demand a return of securities in respect of an open short position, the Master Fund will need to either find another source of supply of such security or purchase the subject securities in open market transactions at then-prevailing market prices. If the Master Fund is unable to source another securities lender and is forced to close out its short position, the Master Fund could incur significant losses if the securities sold short had increased beyond the price at which the Master Fund initially established its short position. In addition to the risks of securities loan recalls or “short squeezes,” the Master Fund may be required to provide additional margin to its counterparties, including its prime brokers, on short notice if the price of a security underlying a short position suddenly rises. If the Master Fund is unable to deliver the additional margin required, the Master Fund may need to prematurely close out the short position at unattractive prices, thereby resulting in a substantial loss. In addition, depending on the timing and

magnitude of a price increase in respect of an open short position, the Master Fund may be required to liquidate long positions in order to meet margin requirements, thereby further increasing the losses (or decreasing the gains) of the Master Fund. In addition, stock loan fees charged to the Master Fund for borrowing securities may be substantial and will decrease any gains (or increase losses) associated with the short position. Certain jurisdictions have enacted restrictions on short selling (including wholesale bans, at times), as well as public disclosure requirements. If additional short-selling restrictions and disclosure requirements are enacted, the prices of the instruments in which the Master Fund invests may be materially affected and the ability of Trails Edge to take advantage of opportunities for short-selling may be significantly reduced. General Risks of Non-U.S. Investments. In advising the Master Fund, Trails Edge may invest in securities of foreign companies. Investing in such securities, which are generally denominated in foreign currencies, and the use of forward foreign currency exchange contracts, involves unusual risk not typically associated with investing in securities issued by U.S. companies. Investing in emerging markets (“EMs”) poses greater risks and a greater potential for returns than investing in developed countries. Securities of companies in these EMs are generally more volatile and may be much more volatile than securities issued by companies located in developed countries. The Master Fund may be affected favorably or unfavorably by exchange control regulations or changes in the exchange rate between such currencies and the U.S. dollar. Moreover, individual foreign economies may compare unfavorably with the U.S. economy in growth of gross national product, rate of inflation, rate of savings and capital reinvestment, resource self-sufficiency, balance-of-payment positions, and in other respects. Some of the countries in which the Master Fund may invest have laws and regulations that currently preclude or severely restrict direct foreign investment in securities of their companies. Securities of some foreign companies are less liquid, and their prices are more volatile than securities of comparable U.S. companies. Investing in foreign securities creates a greater risk of securities clearance and settlement problems. Further, some of the securities in which the Master Fund may invest may be thinly traded and relatively illiquid or may cease to be traded after the Master Fund invests in them. In addition to being illiquid, such securities may be issued by unseasoned companies and may be highly speculative. In addition, the Master Fund occasionally may acquire relatively large positions in a few securities. In such cases, and in the event of extreme market activity, the Master Fund may not be able to liquidate investments promptly, if the need should arise, which could materially and adversely affect the results of such investments. Risks Related to Investments in Companies in the Healthcare Industry. While investments in companies in the healthcare industry offer the opportunity for significant capital gains, such investments also involve a high degree of business, financial, technological, and regulatory risks, which can result in substantial losses. The healthcare industry is subject to regulatory controls at the national, local, and, in some instances, international levels. In addition, the nature and scope of healthcare industry regulations are subject to political forces and market considerations. As a result, the operations of such companies may be subject to compliance with multiple applicable healthcare industry regulations. Thus, the performance of such companies has been historically uncertain, subject to periods of increased regulations, during which regulators may introduce new requirements and reregulate previously de-regulated markets. In particular, the U.S. government and other governments have a significant interest in pursuing healthcare reform. Because regulation governing the healthcare industry is so unpredictable, Trails Edge cannot predict whether new regulations will be enacted or what effect such regulations might have on the Funds. New laws, regulations, and judicial decisions, or new interpretations of existing laws, regulations, and decisions, that relate to healthcare availability, methods of delivery, or payment for products and services, or sales, marketing, or pricing, may increase costs of operations for the Funds, which could have a material negative impact on their overall performance. The Funds expect to invest primarily in the securities of certain companies in the healthcare industry, such as biotechnology and pharmaceutical companies, engaged in the development of products or

technologies or that are conducting clinical trials on products. Obtaining product approval often requires the submission of extensive preclinical and clinical data, information about product manufacturing processes, and inspection of facilities and supporting information for each therapeutic indication to establish a product candidate’s safety and efficacy. Varying interpretations of the data obtained from preclinical and clinical testing could delay, limit, or prevent regulatory approval of a product candidate. The process of obtaining and maintaining regulatory approvals may vary and involves substantial regulatory discretion, is expensive, and often takes many years, if approval is obtained at all. Failure to obtain and maintain regulatory approval for a product candidate following a business combination would have an adverse effect on the value of the underlying securities of such a company. Rapidly Evolving Nature of Healthcare Industry. The Funds’ investments depend on a broad spectrum of products, technologies, and businesses that advance health, including, but not limited to, therapeutics, devices to improve medical diagnosis and treatment, contract service organizations, and adaptation of technological advances to improve drug discovery, development, services relating to hospitals and managed care, and marketing. The market for most of these products and technologies is rapidly evolving and, for some, only beginning to develop. Several specific risks can be typical of a market characterized by rapid change and frequent new product and service introductions. First, the public market for healthcare companies continues to be volatile. The state of the market may adversely affect the development of biotechnology and pharmaceutical companies, the ability of the Funds to dispose of investments, and the value of investment securities on the date of sale or distribution by the Funds. Second, certain products and technologies produced by biotechnology and pharmaceutical companies may become obsolete. This can be a function of the significant technological change that persists in the healthcare industry, the highly uncertain levels of demand, and market acceptance for new products, or the intense competition. If a company is unable to respond successfully to these developments or does not respond in a costeffective manner, the company’s business, financial condition, and operating results will be adversely affected. To be successful, a company must adapt to the rapidly changing markets by continually improving the responsiveness, services, and features of its products and services and by developing new features to meet the needs of its customers. There can be no assurance that the companies in which the Funds invest will be able to meet these competitive requirements, and failure therein will result in an adverse effect on the Funds’ investments. Regulated Industries. Investments in the healthcare and healthcare-related industries are subject to regulatory controls at the national, local, and, in some instances, international levels. As such, new or increased regulations could adversely affect the performance of biotechnology and pharmaceutical companies. Healthcare management and reimbursement policies can be significantly influenced by political events and these events can have an impact on the equities of biotechnology and pharmaceutical companies. In this regard, there has periodically been some political sentiment for government intervention in the pricing of pharmaceuticals. While there has been consistent debate, there has been little change. Any change in the pricing policy of pharmaceuticals through government intervention could have an adverse effect on the performance of the Funds. Risks Related to Litigation and Regulatory Actions – Healthcare. Companies in the healthcare industry are often subject to significant risks related to litigation, regulatory action, and liability for damages and penalties in connection with their operations, or products or services offered. The testing, marketing, and sale of medical and healthcare products, services, and technologies entail an inherent risk of product liability. Accordingly, companies in the healthcare industry are exposed to potential liability risks inherent in the testing, manufacturing, marketing, and sale of healthcare products and/or the provision of healthcare services. The share price of a healthcare-related company can drop dramatically not only as a reaction to an adverse judicial ruling, but also from the adverse publicity accompanying threatened litigation. A liability claim or the imposition of liability may, also, have an adverse effect on the share price of such company’s securities and on its performance. This may

permanently impair the value of, and/or cause the total loss of an investment in, such company. Further complicating the industry, the litigation, enforcement, and liability environment in the healthcare industry is constantly evolving, and new judicial decisions and legislative and regulatory activity may increase exposure to any of these types of claims. There is no assurance that these companies will maintain liability insurance. Even if liabilities insurance is maintained by such companies, including, without limitation, as a result of warranty and product liability claims. Other conditions affecting public health also can affect the performance of healthcare companies. In addition, the Funds could become subject to litigation and judicial and regulatory action as a result of making, holding, or disposing of healthcare investments, and therefore be required to pay judgments and penalties. Investors’ capital may be utilized to fund indemnification and other expenses arising out of such litigation and judicial and regulatory action. Risks Related to Intellectual Property – Healthcare. In addition to operation, testing, and productrelated litigation risk for companies in the healthcare industry, intellectual property rights in the fields of medical devices, diagnostics, pharmaceuticals, and biotechnology are highly uncertain and frequently involve complex legal and scientific questions. The healthcare product industry places considerable importance on obtaining patent and trade secret protection for new technologies, products, and processes. The success of a pre-revenue life sciences investment may depend, in part, on its ability to obtain patent protection for its products, preserve its trade secrets, and operate without infringing the proprietary rights of others. Healthcare companies may not be able to successfully obtain additional issued patents relating to their products, methods, processes, services, or other technologies, or they may be unable to do so in a timely manner. Even if issued, patents may be challenged, narrowed, invalidated, or circumvented, or others may obtain patents claiming aspects similar to those covered by such patents and patent applications, which factors could limit a company’s ability to stop competitors from marketing similar products or services, limit the length of term of patent protection they may have for their products or services, and expose them to substantial costs and risks in litigation and administrative proceedings and drain resources. Changes in either patent laws or in interpretations of patent laws in the U.S. and other countries may diminish the value of biotechnology and pharmaceutical companies’ intellectual property or narrow the scope of their patent protection. Furthermore, the Funds expect that companies in the healthcare industry rely on trademarks, copyrights, trade secrets, and know-how to develop, maintain, and strengthen their competitive positions. However, third parties may know, discover, or independently develop equivalent or superior proprietary information or techniques, or they may gain access to trade secrets or disclose trade secrets to the public. Misappropriation or other loss of intellectual property would have an adverse effect on the competitive position of the affected healthcare company, and adversely impact the Funds’ investment in such company. Risks Related to the Research and Development Process in Healthcare. Research and development are essential to companies operating in the early-stage technology sector. Product development requires substantial investment, and there are inherent risks in the research and development process. A successful product development process depends on many factors, including, without limitation, the ability to anticipate and satisfy customer needs, adapt to new technologies, obtain regulatory approvals on a timely basis, demonstrate satisfactory results, produce or manufacture products in an economical and timely manner, and differentiate products from those of competitors. If a company cannot successfully introduce new products or adapt to changing technologies, its products may become obsolete, and revenue and profitability could suffer, and adversely impact the Funds’ investment in such company. Risks Related to Regulatory Approvals. In the United States, under the Federal Food, Drug, and Cosmetics Act (the “FDC Act”), the Food and Drug Administration (the “FDA”) regulates all aspects of medical treatments and devices and pharmaceutical products that are made or distributed in or from the United States, including manufacturing, testing, and marketing. Certain products of healthcare

companies may require approval from the FDA before such products may be marketed to the public. The Funds cannot guarantee that any healthcare company they are investing in will ever have marketable products or will receive the necessary FDA approval for many reasons, including, among others:

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The FDA may disagree with the design or implementation of such company’s clinical trials;

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Such company’s clinical trials may not produce results demonstrating that its products are safe and effective; and

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The FDA may determine that such company has identified the wrong reference-listed drug or drugs or that approval of its application is blocked by patent or non-patent exclusivity of the reference-listed drug or drugs.

In addition, the process of seeking regulatory clearance or approval to market such products is expensive and time consuming and often requires the submission of extensive preclinical and clinical data, information about product manufacturing processes, and inspection of facilities and supporting information for each therapeutic indication to establish a product’s safety and efficacy. Varying interpretations of the data obtained from preclinical and clinical testing could delay, limit, or prevent regulatory approval of a product candidate. The process of obtaining and maintaining regulatory approvals may vary and involves substantial regulatory discretion, is expensive, and often takes many years. Notwithstanding the effort and expense incurred, clearance or approval is never guaranteed. If a healthcare company is not successful in obtaining timely clearance or approval of its products from the FDA, it may never be able to generate significant revenue and may be forced to cease operations, leading to disappointing results for the Funds. Use of Alternative Data. Trails Edge may purchase and use in its investment process alternative data, consisting of datasets culled from a variety of sources (including, among others, credit card panels, satellite imagery, geolocation and mobility data, app usage, social media sentiment, internet usage, transaction and payment records, and government and other public records databases), including through its incorporation in Trails Edge’s research of target companies. The purchase, onboarding, analysis, and interpretation of alternative data involves a high degree of uncertainty, and no assurance can be given that the use of alternative data by Trails Edge will prove beneficial to the Funds. The use of alternative data involves an inherent risk that Trails Edge may rely on data outputs that reflect faulty system logic or that are based on inaccurate or incomplete data inputs. Moreover, the use of alternative data for investment purposes has been subject to increased scrutiny from regulators, and its use or misuse under current or future laws and regulations, whether related to securities or privacy laws and regulations or otherwise, could create liability for Trails Edge and for the Funds in various jurisdictions. Trails Edge cannot predict what, if any, regulatory or other actions may be asserted with regard to alternative data, but any regulatory investigations or formal actions could cause reputational, financial, or other harm to Trails Edge and/or the Funds. In addition, the use of alternative data may entail significant expense, which is expected to be borne, in whole or in part, by the Funds. Reliance on Experts. As part of its research process, Trails Edge may engage and retain, on the Funds’ behalf and at the Funds’ expense, industry experts, consultants, and other similar professionals, including members of “expert networks,” who are not employees or affiliates of Trails Edge. The nature of the relationship with each of these experts, consultants, and professionals, and the amount of time devoted or required to be devoted by them may vary considerably. In general, such industry experts, consultants, and other similar professionals provide Trails Edge with industry- or jurisdictionspecific insights and/or analysis so that Trails Edge may understand a broader number of viewpoints than simply those accessible to Trails Edge through management teams, third-party research papers, and from other sources of publicly available information. While Trails Edge will maintain specific policies and procedures regarding the use of such industry experts, consultants, and other similar professionals, which are designed to detect and prevent insider

trading, it is possible that Trails Edge may come into possession of material non-public information or confidential information while conducting consultations with such industry experts, consultants, and other similar professionals. In the event that material non-public information is obtained during such consultations, the Funds may become (or may elect to become) subject to trading restrictions pursuant to the internal trading policies of Trails Edge or as a result of applicable law or regulations or be prohibited from purchasing or selling securities while in possession of material non-public information, which restrictions and prohibition may have a material adverse effect on the Funds and the value of an investment in the Funds. Industry experts, consultants, and other similar professionals have also become subject to increased regulatory oversight. As a result of such increased regulatory oversight, Trails Edge may experience certain administrative burdens in connection with Trails Edge’s retention and engagement of such industry experts, consultants, and other similar professionals. Such burdens may include, without limitation, responding to examinations, investigations, and document requests, implementing new policies and procedures, and complying with recordkeeping and reporting obligations. Such burdens may divert such parties’ time, attention, and resources from portfolio management activities. There can also be no assurance that any of the industry experts, consultants, and other similar professionals will continue to serve in such roles and/or continue their arrangements with Trails Edge and the Funds. As a result of the foregoing, the Funds, Trails Edge, and the General Partner may also become subject to legal, regulatory, reputational, and other unforeseen risks as a result of utilizing the services of these industry experts, consultants, and other similar professionals. Artificial Intelligence and Machine Learning Risks. Trails Edge uses generative artificial intelligence technologies, including ChatGPT and similar large language models and chatbots (“Generative AI”), in certain business and investment research processes. Trails Edge is also exposed to risks associated with the use of Generative AI by third parties, including service providers, counterparties, data vendors, and other market participants, and the Firm may not always be aware of such use or able to control how third-party systems are developed, maintained, or operated. Generative AI tools rely on large datasets that may be incomplete or unreliable, and their outputs may be inaccurate, biased, misleading, or otherwise unreliable. The use of Generative AI may also present cybersecurity, confidentiality, data privacy, intellectual property, and other operational or legal risks. Because Generative AI technologies are rapidly evolving, Trails Edge’s related policies and procedures may continue to develop, and it may be difficult to predict the full scope of risks associated with current or future uses of such technologies. Cyber Security Breaches and Identity Theft. The information and technology systems of Trails Edge, the General Partner, their affiliates, the Funds, and their service providers and their portfolio companies may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons, other security breaches, and/or usage errors by their respective professionals. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design, manufacture, or other problems that could unexpectedly compromise information security. Although Trails Edge, the General Partner, and/or their affiliates have implemented, or expect to implement, measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, Trails Edge, the General Partner, their affiliates, the Funds, their service providers, and/or their portfolio companies may have to make a significant investment to fix or replace them. The failure of these systems for any reason could cause significant interruptions in such parties’ operations and/or a failure

to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to Investors (and the beneficial owners of Investors). Such a failure could harm the reputation of Trails Edge, the General Partner, their affiliates, the Funds, and/or their portfolio companies, subject any such entity and their respective affiliates to legal claims, and/or otherwise affect their business and financial performance. Specifically, cyberattacks and the failure of such systems may interfere with the processing of Investor subscriptions or withdrawals, impact the Funds’ ability to value their assets, cause the release of confidential information, and/or subject the Funds to regulatory fines, penalties, or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. The Funds also may incur substantial costs for cyber-security risk management to prevent any cyber incidents in the future. The Funds and the Investors could be negatively impacted as a result. Incentive Allocation. The General Partner may be entitled to receive an Incentive Allocation, which if applicable, will be calculated and applied at the Master Fund level, but which will consider the impact of any gains, losses, or expenses incurred at the level of the Feeder Funds. The amount allocated to the General Partner is variable and cannot be determined in advance. Depending upon the Master Fund’s rate of return, the amount allocated to the General Partner may be substantial compared to a fee calculated as a percentage of the assets under management, which might be paid to a money manager for managing a comparable amount of money. This could provide an incentive to the General Partner to approve more speculative trading strategies or to act to crystalize long-term or short-term capital gain treatment or to crystallize losses in an effort to maximize the Master Fund’s rate of return and the General Partner’s Incentive Allocation. Litigation. It is possible that Trails Edge, the General Partner, and/or one or more of the Funds may be plaintiffs, defendants, or otherwise involved in civil or criminal proceedings, including bankruptcy court proceedings. The expense of litigation related to the Master Fund’s investment activities, including, but not limited to, expenses related to prosecuting claims, for which there is no guarantee of success, defending against claims by third parties, and paying any amounts pursuant to settlements or judgments, and/or other involvement in litigation, would generally be borne by the Master Fund, and would reduce net assets or may, pursuant to applicable law, require Investors to return to the Funds distributed capital and earnings. Misconduct of Employees and of Third-Party Service Providers. Misconduct by employees or by third-party service providers could cause significant losses to Funds. Employee misconduct may include binding the Master Fund to transactions that exceed authorized limits or present unacceptable risks and unauthorized trading activities or concealing unsuccessful trading activities (which, in either case, may result in unknown and unmanaged risks or losses). Losses could also result from actions by thirdparty service providers, including, without limitation, from the failure to recognize trades and the misappropriation of assets, including situations where third-party service providers may act as directors, trust companies, or in a similar capacity that may give such third-party service providers signing authority over certain Master Fund assets. In addition, it is possible that employees and thirdparty service providers may improperly use or disclose confidential information of the Funds, which could result in litigation or serious financial harm, including limiting the Funds’ business prospects or future marketing activities. In addition, without any misconduct, employees and third-party service providers may make errors that cause significant losses to the Funds and their Investors, including, among others, with respect to the calculation of net asset value, the handling of assets and wiring of withdrawal proceeds, the handling of personal information, the negotiation of contracts, the maintenance of data, or the safeguarding of one or more of Trails Edge’s systems. Outsourced Trading. One or more broker-dealers (each, an “External Trading Desk”) will be engaged by Trails Edge on behalf of the Master Fund to execute and/or direct a portion of the Master Fund’s trades on an outsourced basis. In causing the Master Fund to enter into or maintain such

arrangements, Trails Edge has a conflict of interest because the fees paid to (or commissions agreed to with) and expenses reimbursed to an External Trading Desk are borne by the Master Fund and, thus, the Feeder Funds, which reduces or eliminates unreimbursed trading-related costs and expenses that would otherwise have been incurred by Trails Edge. While Trails Edge will only maintain any such arrangement for so long as it remains satisfied that such arrangement is consistent with Trails Edge’s duty to seek best execution, the foregoing means that Trails Edge will be economically incentivized to continue such arrangement or enter into similar alternative arrangements even if it has the capacity to provide the same services in-house at a comparable level.

Personal Trading The Code prohibits access persons from purchasing securities of individual companies that are publicly

traded in the health care sector as classified under the Global Industry Classification Standard (GICS).1 Trails Edge believes that this prohibition mitigates the most likely conflict of interest that may arise from personal trading activity by generally prohibiting trading in securities that largely comprise the investable universe of Trails Edge’s clients. Access persons are permitted to buy and sell private securities (such as investments in hedge fund, private equity funds and private companies) with prior approval. Access persons are also permitted to invest in mutual funds and U.S. and non-U.S. government issued obligations without prior approval. In addition, Trails Edge may permit access persons to maintain accounts that are managed on a discretionary basis by a third party if the access person has no direct or indirect influence or control over the investments for the account. Exceptions to the personal trading policy are handled on a case-by-case basis. For example, an exception may be granted for legacy positions that were held by an access person (or a covered family member) prior to that access person joining Trails Edge or to sell an investment that was originally made when the company was private and subsequently became publicly traded. In such a case, the access person would be required to obtain prior approval to sell such positions and may be subject to other restrictions as deemed appropriate by Trails Edge under the circumstances. Gifts and Entertainment, Political Activities and Outside Activities The Code provides that gifts and entertainment must be reasonable in light of industry practices and should never be given or received if the purpose is to influence the recipient. Trails Edge requires access persons to report or receive approval for the receipt or giving of gifts and entertainment under certain circumstances. The Code also generally requires access persons to obtain prior approval before the access person, a spouse or certain other immediate family members makes a political contribution or engages in certain campaign-related fundraising activities. This policy is intended to prevent scenarios whereby an access person may make a contribution or engage in an activity for the selection of Trails Edge as an investment adviser for a governmental entity. Finally, the Code provides that, without prior approval, access persons are generally not permitted to engage in certain types of outside business activities. This policy is intended to prevent material conflicts of interest that could arise from an access person’s personal activities. Participation or Interest in Client Transactions Trails Edge, its principals and employees do not purchase or sell any securities for their own accounts to or from the Funds. However, in the future, if Trails Edge is to advise multiple client accounts, subject to Funds’ investment guidelines and restrictions, Trails Edge may effect rebalancing or internal cross transactions. In such cases, Trails Edge may determine that it would be in the best interests of the Master Fund and one or more other accounts to transfer a security from one account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including tax purposes, liquidity purposes, to rebalance the portfolios of the accounts, or to reduce transaction costs that may arise in an open market transaction. If Trails Edge decides to engage in a Cross Trade, Trails Edge will determine that the trade is in the best interests of both of the accounts involved and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those accounts.

Health care securities classified under GICS’ Health Care Sector include Health Care Equipment and Services, and Pharmaceuticals, Biotechnology, and Life Sciences. For more information, see: Global Industry Classification Standard (GICS) Methodology

Although unlikely, in the event that Trails Edge is to execute Cross Trades, it would do so with the assistance of a broker-dealer that executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a cross transaction between two fund clients may occur as an “internal cross”, where Trails Edge instructs the custodian for the accounts to book the transaction at the price determined in accordance with Trails Edge’s Valuation Policy. If Trails Edge effects an internal cross, Trails Edge will not receive any fee in connection with the completion of the transaction. Additional Considerations From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities, partners and personnel in connection with client transactions. Trails Edge has established written policies and procedures, which contain procedures to monitor and resolve conflicts and will endeavor to resolve conflicts in a manner it deems equitable to the extent possible under the prevailing facts and circumstances.

Subject to best execution, in selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services, Trails Edge may consider, among other factors that are deemed appropriate to consider under the circumstances, the following: the ability of the brokers and dealers to effect the transaction; the brokers’ or dealers’ facilities, reliability and financial responsibility; and the provision by the brokers of capital introduction, talent introduction, marketing assistance, consulting with respect to technology, operations and equipment, commitment of capital, access to company management and access to deal flow. Accordingly, the prices and commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Master Fund by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Trails Edge need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Trails Edge nor the Master Fund separately compensates any broker or dealer for any of these other services. Trails Edge maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Soft Dollar Usage From time to time, Trails Edge pays a broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transactions) for effecting Master Fund transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. Trails Edge will effect such transactions, and receive such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). Trails Edge believes it is important to its investment decision-making processes to have access to independent research.

Research services within Section 28(e) that Trails Edge uses soft dollars for generally include: research reports (including market, industry and company research); financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and proxy advisory services; attendance at seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); and advice from brokers regarding order execution, trading strategies or market structure. Brokerage services within Section 28(e) that Trails Edge uses soft dollars for generally include: services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (including connectivity services between Trails Edge and broker-dealers, custodians or other relevant parties); trading software operated by a broker-dealer to route orders; software that provides trade analytics or trading strategies; software used to transmit orders; clearance and settlement services; electronic communication of allocation instructions; routing settlement instructions; posttrade matching of trade information; electronic confirmations or trade affirmations; and services required by the SEC or applicable self-regulatory organizations. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by the Master Fund may be used by Trails Edge to service one or more other accounts, including accounts that may not have paid for the soft dollar benefits. Trails Edge will not seek to allocate soft dollar benefits to accounts in proportion to the soft dollar credits the accounts generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to Trails Edge (i.e., a “mixed use” item), Trails Edge will make a good faith allocation of the cost which may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest may exist by reason of Trails Edge’s allocation of the costs of such benefits and services between those that primarily benefit Trails Edge and those that primarily benefit the accounts. When Trails Edge uses brokerage commissions (or markups or markdowns) generated by any accounts to obtain research or other products or services, Trails Edge receives a benefit because it does not have to produce or pay for such products or services. While Trails Edge is obligated to seek best execution for each account, the fact that Trails Edge can obtain or receive such products or services may create an incentive for it to select or recommend a particular broker-dealer based on Trails Edge’s interests, to the exclusion of another broker-dealer that offers business terms that are also favorable to one or more accounts. At least annually, Trails Edge considers the amount and nature of research and research services provided by broker-dealers, as well as the extent to which such services are relied upon and attempts to allocate a portion of the brokerage business of its accounts on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation but can (and often does) exceed the suggested level, because total brokerage is allocated on the basis of all of the considerations described above. In no case will Trails Edge make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. Trade Aggregation and Allocation Policies and Procedures Trails Edge executes trades and investments in the Master Fund. In the future, if Trails Edge is to advise other actively traded client accounts, in addition to the Master Fund, it will be the policy of Trails Edge to allocate investment opportunities to the Master Fund and to any other accounts on a fair and equitable basis, to the extent practical and in accordance with the Master Fund’s or other accounts’

applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those accounts for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: whether the risk-return profile of the proposed investment is consistent with an account’s objectives, the potential for the proposed investment to create an imbalance in an account’s portfolio, the liquidity requirements of an account, potentially adverse tax consequences, regulatory restrictions that would or could limit an account’s ability to participate in a proposed investment, and the need to re-size risk in an account’s portfolio. Trails Edge will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, the Master Fund or other accounts solely because Trails Edge purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another account or the Master Fund if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for the Master Fund or the other account. In particular, when the Master Fund is ramping up its investment or trading strategies, it may receive larger allocations of certain securities than the other accounts in order to obtain its desired risk and portfolio size. Conversely, when other accounts ramp up their investment and trading strategies, the Master Fund may receive reduced or no allocations of certain securities. Trade Errors Trade errors involving transactions in any account directly or indirectly held by the Master Fund or any derivatives contract or other similar agreement of the Master Fund and/or any trading vehicle (each, a “Trade Error”) may occur. Trade Errors include the placement of orders (either purchases or sales) in excess of, or less than, the amount of Securities the account intended to trade; the sale of a security when it should have been purchased; the purchase of a security when it should have been sold; the purchase or sale of the wrong security; and the purchase or sale of a security for the wrong account and the post-settlement discovery of such purchase or sale. Trades implemented as a result of faulty data, systems, coding, modeling or analysis, trades that are properly executed but result in losses, errors committed by other persons (including brokers and custodians), or that are otherwise caused by human error other than those specifically described above, are not considered Trade Errors. The loss of an investment opportunity is not considered a Trade Error. Such errors may result in losses or gains. Trails Edge will use reasonable efforts to detect such errors prior to settlement and promptly correct them. To the extent that an error is caused by a counterparty, such as a broker-dealer, Trails Edge will use reasonable efforts to recover any losses associated with such error from the counterparty. Pursuant to the exculpation and indemnification provided by the Master Fund to Trails Edge and its affiliates and personnel, Trails Edge and its affiliates and personnel will generally not be liable to the Master Fund for any act or omission, absent bad faith, gross negligence, willful misconduct or actual fraud of such person, and the Master Fund will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Master Fund, absent bad faith, gross negligence, willful misconduct or actual fraud of such person. As a result of these provisions, the Master Fund (and not Trails Edge) will benefit from any gains resulting from Trade Errors and other errors and will be responsible for any losses (including additional trading costs) resulting from Trade Errors and other errors, absent bad faith, gross negligence, willful misconduct or actual fraud of the relevant person. Trails Edge will not offset any such gains and losses resulting from Trade Errors and other errors unless the underlying transactions constitute a single transaction or closely related series of transactions. Trails Edge will reimburse the Master Fund for losses for which Trails Edge is responsible under the exculpation provisions. Given the potentially large volume of transactions executed by Trails Edge on behalf of the Master Fund, Investors should assume that Trade Errors and other errors will occur and that, to the extent permitted by applicable law and under the Funds’

respective offering documents, the Master Fund will be responsible for any resulting losses, even if such losses result from the negligence (but not gross negligence) of Trails Edge’s personnel.

The referral arrangements described above involve potential conflicts of interest because the placement agent may have an incentive to favor sales of interests in a Fund over sales of other investment products for which the agent will receive no or lower fees. Prospective and existing investors should consider this potential conflict of interest when evaluating any recommendation or referral by an agent regarding an investment in a Fund.

Trails Edge does not expect to be required to comply (or expects to be deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the provisions of the so-called "Pooled Vehicle Annual Audit Exception", which, among other things, requires that (i) each Fund be subject to an audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (PCAOB), (ii) each Fund’s audited financial statements are prepared in accordance with U.S. generally accepted accounting principles (GAAP), and (iii) each Fund distributes its audited financial statements to all Investors in the relevant Fund(s) within 120 days of the end of its fiscal year.

Trails Edge will vote proxies as it deems necessary or appropriate, on a case-by-case basis. Prior to voting, the CCO will determine whether the conflict is material to the vote and will either resolve the conflict or refer the proxy vote to an outside service for its independent consideration. In limited circumstances, Trails Edge may refrain from voting Proxies where Trails Edge believes that voting would be inappropriate, taking into consideration the cost of voting the Proxies and the anticipated benefit to the Funds. Investors or clients may also contact Trails Edge via e-mail or telephone to request a copy of its proxy voting policy. Class Action Participation Procedures To the extent that Trails Edge has discretion to participate in class action lawsuits filed against companies or issuers in which the Funds are invested, Trails Edge may participate in such class action lawsuits if it believes that such participation is in the best interest of the Funds on a case-by-case basis.