Canso Investment Counsel Ltd.: investment adviser

Advisory Services We intend to provide investment advisory services across a range of fixed income strategies, including specialty bond and credit strategies, to U.S. clients that establish separately managed accounts with us (the “U.S. Clients”), and to pooled investment vehicles offered or sold to U.S. investors (the “Fund Clients” and together with the U.S. Clients, the “Advisory Clients”). Advisory Clients targeted by Canso in the U.S. will be primarily institutional investors. We do not currently provide investment advisory services to U.S. Advisory Clients; however, we may, in the future, provide such services to U.S. Clients and to Fund Clients that are offered or sold to U.S. investors. We also provide investment advisory services to clients that are not U.S. persons, including through pooled investment vehicles that are offered or sold solely to non-U.S. persons. Services will be provided to the U.S. Clients in accordance with an investment management agreement and on a continuing basis. This means that we may transact in securities on our U.S. Clients’ behalf or carry out other investment advisory services activities without obtaining consent or consulting with our U.S. Clients. When providing investment services to the U.S. Clients, we will generally tailor our advisory services to the individual needs of such clients, including any specific guidelines or restrictions such clients may request. Services will be provided to the Fund Clients in accordance with a separate investment management agreement. The investment objectives, including any investment restrictions of Fund Clients, are generally established in the offering document (i.e., offering memorandum or private placement memorandum) of the applicable Fund Client and/or the Fund Client’s investment management agreement. We do not participate in wrap fee programs.

Assets Under Management As of June 30, 2026, we manage a total of $46,645,743,893 of client assets, all of which are managed on a discretionary basis. Assets under management are provided in USD.

Client’s specific arrangement with us, we will calculate and accrue the investment management fee, in arrears, on a monthly or quarterly basis, and bill quarterly on the last business day of each quarter. This fee will be paid within the separately managed account. We do not have the ability to directly debit investment management fees from U.S. Clients’ accounts. U.S. Clients must instruct and approve the payment of an invoice by the U.S. Client’s custodian. We do not charge performance fees or operating expenses for separately managed accounts. U.S. Clients should refer to their investment management agreement for the precise amount of, and the manner and calculation of, the investment management fees. Fees are subject to taxes, as applicable. As compensation for investment services rendered to Fund Clients, we intend to receive from each such Fund Client an investment management fee typically calculated based on a percentage of the Fund Client’s net asset value. The precise amount of, and the manner and calculation of, the investment management fees for each Fund Client are set forth in such Fund Client’s offering documents and/or organizational documents.

Other Fees and Expenses Canso will only be compensated through investment management fees that it charges Advisory Clients. Advisory Clients will incur other fees and expenses unrelated to Canso. Such fees can include brokerage commissions or fees, and custodial charges related to the account. Custodial charges are separately negotiated between you and the custodian, without our involvement. When a broker is used in connection with an investment by an Advisory Client, such Advisory Client will incur brokerage charges which are embedded in the purchase and sale of fixed income securities. We do not earn any of the foregoing fees. For additional information regarding brokerage practices, please see Item 12 below.

We may in the future offer investment advisory services to other clients, pooled investment vehicles, or in respect of other investment products. With respect to Advisory Clients, we will generally impose a minimum investment amount to open an account. However, we may waive any such requirements at our discretion.

Our mandates do not focus on term or yield curve decisions, and our portfolios are built to maximize the credit spread and credit opportunity. We tend to invest in the term cohort where we believe the spread potential is the best to maximize yield at an acceptable level of credit risk. We typically hold positions until maturity or until we believe the security becomes overvalued or a better security is discovered.

INVESTMENT PHILOSOPHY Canso was founded on the principle that we conduct our own independent research and evaluation of each investment opportunity. Our fixed income approach concentrates on fundamental analysis and security selection. Traditional “core” bond management combines corporate bonds with government bonds in an “active” bond mandate. The corporate bonds usually selected are a limited number of higher investment grade issues, which form a portion of the overall bond portfolio at a weight that is typically higher than the corporate bond weight in the market index. Alternatively, a smaller portion of the bond portfolio is allocated to “high yield” management, which is exclusively invested in lower quality bonds. Our approach allocates a dedicated portion of a client’s bond portfolio to corporate bonds and manages these as its own universe. When permitted by a client’s mandate, the credit range of a portfolio may include all investment grade bonds (AAA to BBB) and below investment grade issues. We believe this latitude frees us from the necessity of trying to mimic index holdings and allows us to accept risks in the portfolios when we are appropriately compensated. Given the risk/return trade-off, we do not distinguish among bonds by credit rating, but rather on fundamentals. We are opportunistic in our process, moving between bonds as their valuations change; buying unpopular bonds cheaply and selling overvalued, highly sought after bonds into strength. We would rather buy an out-of-favour and cheap “A” bond than a highly sought after and overpriced junk bond. RESEARCH PROCESS Our investment process is focused on bottom up, fundamental research and security selection, and our primary focus is on our internal credit research. We generally do not rely on external research and credit rating agencies. We conduct research on issuers before making an investment and we continue to update our research on an ongoing basis for each issue in the portfolio. Our investment process begins with a fundamental review of the issuer of a security. An internal quality rating is then assigned to the issuer. At this point, the merits of the particular financial security are examined with particular regard to the legal structure and ranking of the security. The expected future cash flow stream is identified, and the risks associated with the investment are analyzed. Fundamental analysis is used to identify the credit risk of an issuer. In addition, the issuer is analyzed with respect to financial strength, management capability, and business environment, and the terms and conditions of the security (including covenant package, priority in a default, ability to incur additional debt and make dividend payments) are assessed. Following such analysis a risk/return profile is determined.

As part of our fundamental credit research process, we may consider environmental, social and governance ("ESG") factors where we believe such factors are financially material to an issuer's creditworthiness, cash flows, valuation or recovery prospects. ESG considerations are evaluated alongside other financial and credit factors and are not assigned a separate weighting in our investment process. The relevance and importance of ESG factors will vary by issuer and industry, and certain ESG factors may not be considered where they are not deemed financially material. We invest solely to achieve financial returns and do not pursue ESG-focused investment strategies or seek specific ESG-related outcomes. INVESTMENT OR DECISION-MAKING PROCESS As part of our overall investment process, a team meeting is held to consider an issue or issuer in which Canso is considering making an investment. After our initial review is completed, an internal credit rating is then assigned to the issuer, and a valuation is established by referring to other similar issuers and market pricing. In order to decide on the appropriate position size, we determine the potential downside of the security from its current market value using our proprietary Maximum Loss analysis. This analysis captures the potential return that will be available to the bondholders and creditors in an insolvency and workout situation, allowing us to better understand the intrinsic value of a security in a negative scenario. Issuers held in our portfolios are monitored on an ongoing basis and reviewed as required. If corporate development arises, the analyst responsible will present their analysis and recommendation to the other team members who provide peer review and input. After the development has been reviewed, the portfolio manager makes the investment decision. PORTFOLIO CONSTRUCTION Our portfolios reflect our “bottom up” research emphasis. Rather than identifying likely sectors for investment, we select individual securities with regard to their intrinsic risk and return trade-off. Our portfolios are constructed with little regard for the industry and geographic breakdowns of market indices but we maintain credit limits for individual holdings and ratings categories. Our “buy” or selection process focuses primarily on the absolute price of the issue given the fundamental credit quality of the issuer and the terms and conditions of the specific security. Then we determine the relative value of the prospective issue. If the yield spread is attractive both absolutely and relatively, we will establish a position. Our portfolios are constructed to maximize yield at an acceptable level of credit risk. When a security becomes overvalued on a peer or absolute basis, we look to sell it and will put the proceeds into Treasury bonds if no other attractive investment can be found at that time. If a security deteriorates from an operational or credit point of view, we will sell it on opportunity. Our strategy is “buy and hold,” although we will take advantage of market opportunity.

RISK MANAGEMENT Our firm defines risk in terms of absolute capital loss. In our bond portfolios, we use a proprietary system of default risk for our bond holdings called Maximum Loss. Compared to commercial credit ratings, our Maximum Loss methodology estimates the maximum potential loss on a position given its trading value. This limits exposure to bonds trading expensively compared to their potential losses and encourages purchase of bonds trading near or below their workout values. This limits the portfolio’s downside risk and creates more upside potential than by using traditional credit rating methodology. The Maximum Loss methodology limits each position according to its potential impact on a portfolio’s long term value-added. Each position is analyzed independently. The higher the trading price of a security compared to its downside potential, the smaller the position allowed. The risk assessment allows the security’s specific features that modify its downside risk to be considered. This includes the priority of the security and nature of the issuer. Portfolios are diversified by issuer type and industry sector. Positions are then limited individually by the determination of the Maximum Loss potential of each issue. In addition, portfolio weightings in credit cohorts are established by investment policy statement constraints which reflect client risk tolerances.

Material Risks of Significant Investment Strategies Investing in securities involves a substantial degree of risk. An Advisory Client may lose all or a substantial portion of its investments, and investors must be prepared to bear the risk of a complete loss of their investments. In addition, material risks relating to the investment strategies and methods of analysis described above, and to the types of securities typically purchased by or for the Advisory Clients, include the following: Recent Financial Market Fluctuations. Various sectors of the U.S. and global financial markets and the broader current financial environment have been, and continue to be, characterized by uncertainty, volatility and instability. The financial services industry generally and investment activities are affected by general economic and market conditions, including interest rates, availability of credit, lack of price transparency, inflation rates, economic uncertainty, changes in tax and other applicable laws and regulations, trade barriers, national and international and environmental and socioeconomic circumstances. These financial market fluctuations have the tendency to reduce the availability of attractive investment opportunities for an Advisory Client and may affect the Advisory Client’s ability to make investments and the value of the investments held by an account. Instability in the securities markets and economic conditions generally may also increase the risks inherent in an Advisory Client’s investments. The public securities markets have seen increased volatility and the ability of companies to obtain financing for ongoing operations or expansions may be severely hampered by the tightening of the credit markets and the ongoing financial turmoil. It is unclear what the repercussions of this market

turmoil may be. Moreover, it remains unknown whether governmental measures undertaken in response to such turmoil (whether regulatory or financial in nature) will have a positive or negative effect on market conditions. There can be no assurance that the market will, in the future, become more liquid than it is at present, and it may well continue to be volatile for the foreseeable future. Derivatives Risk. An account’s investments may include derivative instruments and Canso may engage in various hedging and other investment strategies in an effort to hedge various market risks (such as interest rates, currency exchange rates, and broad or specific equity market movements) or to manage the effective maturity or duration of fixed-income securities or the account’s exposure to various securities markets. These hedging and other investment strategies involve certain risks, including the possible default of the other party to the transaction, the lack of liquidity, the imperfect nature of the hedge or the ineffectiveness of the strategy in a particular situation, and the possible accentuation of losses or reductions in gains of the underlying portfolio securities. Currency/ Foreign Exchange Risk. Currency risk is the risk that fluctuations in exchange rates between the U.S. dollar and foreign currencies may cause the value of foreign currency investments to decline significantly. If the value of the U.S. dollar has increased relative to the foreign currency, the return on the foreign security may be reduced, eliminated or made negative. The opposite can also occur, where the return on the foreign security may benefit from an increase in the value of the foreign currency relative to the U.S. dollar. In addition, movements in the exchange rate between the U.S. dollar and the foreign currency could increase or reduce the value of foreign securities valued in such foreign currency when translated to U.S. dollars. Credit or Company Specific Risk. Credit risk is the risk that an Advisory Client could lose money if an issuer or guarantor of a debt instrument becomes unwilling or unable to make timely principal and/or interest payments, or to otherwise meet its obligations. An Advisory Client’s investment in a debt instrument could decline because of concerns about the issuer’s credit quality or perceived financial condition. Fixed income securities are subject to varying degrees of credit risk, which are sometimes reflected in credit ratings. High-Yield Risk. An Advisory Client’s investments in high-yield securities and unrated securities of similar credit quality (commonly known as junk bonds or below investment grade debt) may be subject to greater levels of interest rate, credit and illiquid investment risk than vehicles that do not invest in such securities. These securities are considered predominately speculative with respect to the issuer’s continuing ability to make principal and interest payments. An economic downturn or period of rising interest rates could adversely affect the market for these securities and reduce Canso’s ability to sell these securities (illiquid investment risk). If the issuer of a security is in default with respect to interest or principal payments, an Advisory Client may lose its entire investment. Issuer Risk. Changes in the financial condition of an issuer of or counterparty to a debt security, changes

in specific economic or political conditions that affect a particular type of debt security or issuer, and changes in general economic or political conditions can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s credit quality or value. Entities providing credit support, or a maturity-shortening structure also can be affected by these types of changes. If the structure of a security fails to function as intended, the security could decline in value. Lower-quality debt securities (those of less than investment-grade quality) tend to be particularly sensitive to these changes and involve greater risk of default or price changes due to changes in the credit quality of the issuer. Convertible Instruments Risk. An Advisory Client’s investments may include convertible instruments. A convertible instrument is a bond, debenture, note, preferred stock, or other security that may be converted into or exchanged for a prescribed amount of common stock of the same or a different issuer within a particular period of time at a specified price or formula. Convertible debt instruments have characteristics of both fixed income and equity investments. An Advisory Client may invest in convertible instruments that have varying conversion values. If a convertible instrument held by an Advisory Client is called for redemption, the Advisory Client will be required to permit the issuer to redeem the instrument, or convert it into the underlying stock, and will hold the stock to the extent the adviser determines that such equity investment is consistent with the investment objectives of the Advisory Client. Counterparty and Settlement Risk. Some of the markets in which an Advisory Client’s transactions will be effected may be “over the counter” or “interdealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange based” markets. This exposes the Advisory Client to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether or not bona fide) or because of a credit or liquidity problem, thus causing the Advisory Client to suffer a loss. In addition, in the case of a default, the Advisory Client could become subject to adverse market movements while replacement transactions are executed. Such “counterparty risk” is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Advisory Client has concentrated its transactions with a single or small group of counterparties. Canso is not restricted from dealing with any particular counterparty or from concentrating any or all of its Advisory Client transactions with one counterparty. Moreover, neither an Advisory Client nor Canso has an internal credit function which evaluates the creditworthiness of its counterparties. The ability of an Advisory Client to transact business with any one or number of counterparties, the lack of any meaningful and independent evaluation of such counterparties’ financial capabilities and the absence of a regulated market to facilitate settlement may increase the potential for losses by an Advisory Client. Liquidity of Underlying Investments Risk. The securities in which an Advisory Client intends to invest in may be thinly traded. There may be no restrictions on the investment of account assets in illiquid securities. It is possible that an Advisory Client may not be able to sell or purchase significant portions of such positions without facing substantially adverse prices. If an Advisory Client is required to transact in

such securities before its intended investment horizon, the performance of the Advisory Client could suffer. Force Majeure Risk. Natural disasters, incidences of war, riot or civil unrest, terrorist attacks, public health crises including epidemics, pandemics or outbreaks of new infectious disease or viruses can materially adversely affect an Advisory Client’s business, financial condition, liquidity or results of operations. Cybersecurity Risk. With the increased use of technologies such as the internet to conduct business, we have become potentially more susceptible to operational and information security risks arising from cybersecurity breaches. In general, a cybersecurity breach may result from either a deliberate attack or an unintentional event. Cybersecurity breaches may involve, among other things, infection by computer viruses or other malicious software code or unauthorized access to our electronic systems, networks, or devices through “hacking” or other means, in each case for the purpose of misappropriating assets or sensitive information (including, for example, personal investor data), corrupting data, or causing operational disruptions or failures in the physical infrastructure or operating systems that support us or the Advisory Clients. Cybersecurity risks also include the risk of losses of service resulting from external attacks that do not require unauthorized access to our systems, networks or devices. Any such cybersecurity breaches or losses of service may cause us or the Advisory Clients to lose proprietary information, suffer data corruption or lose operational capacity, which, in turn, could cause us or the Funds to incur regulatory penalties, reputational damage, increased compliance costs associated with corrective measures, and/or financial loss. While we have implemented policies, procedures, business continuity plans and risk management systems designed to mitigate the impact of cybersecurity incidents, there are inherent limitations in such plans and systems due in part to the rapidly evolving nature of technology and cybersecurity threat tactics, and there is a possibility that certain risks have not been fully identified or prepared for. In addition, cybersecurity incidents by or breaches of our third-party service providers may disrupt the business operations of the service providers and of us. These disruptions may result in financial losses, the inability of investors to transact business with us, violations of applicable privacy and other laws, rules and regulations, regulatory fines, penalties, reputational damage, reimbursement or other compensatory costs and/or additional compliance costs associated with remediation measures. Cybersecurity risks may also impact issuers of securities in which an Advisory Client invests, which may cause the Advisory Clients’ investments in such issuers to lose value. Artificial Intelligence. The emergence of recent technology developments in artificial intelligence and machine learning such as OpenAI and ChatGPT (collectively, “Machine Learning Technology”) can pose risks to us or the Advisory Clients. While we prohibit the use of Machine Learning Technology to conduct registrable activities, in a way that may directly affect registrable activities, or to generate final Canso work product, we are nonetheless exposed to the risks of Machine Learning Technology from any uses of Machine Learning Technology that may be undertaken by our personnel in contravention of our

restriction, or by third-party service providers, whether or not known to us. Use of Machine Learning Technology involves the risk of inaccuracies or errors in the data utilized by Machine Learning Technology, may directly or indirectly create security or data risks, and may increase trademark, licensing and copyright risks. Machine Learning Technology continues to develop rapidly, and it is impossible to predict the future risks that may arise from such developments. Tax Considerations. We expect Advisory Clients to be subject to income or withholding taxes and/or tax return filing obligations in the various jurisdictions in which they conduct investment activities. In addition, changes in tax laws or interpretation of such laws could occur while Advisory Clients remain a client of ours and may result in adverse consequences. Environmental, Social and Governance Matters. As a fixed income manager, we recognize that the sustainability of borrowers’ business models is critical given the long-term nature of our investment activities, and the willingness to hold bonds to maturity. We believe environmental, social, and governance (“ESG”) issues can affect the long-term performance of issuers included in the investment portfolios we manage. We employ an ESG integration approach in our bottom-up fundamental fixed income investment research process and demonstrate our commitment to this process through our status as signatory to Principles for Responsible Investment (PRI) since 2019. Oversight of ESG is governed by Canso’s Responsible Investment Committee, which reports to the CEO and to the Board. It is responsible for maintaining accountability for external ESG commitments, setting Canso’s ESG strategy, and ensuring that our ESG integration process is consistently applied by members of the research team. The Committee is comprised of the President, Vice President Investment Research, and senior Portfolio Managers. It is chaired by a Portfolio Manager with a mandate to promote best practice, and to provide thought leadership to staff and clients. Responsibility for the implementation of Canso’s ESG process sits with each member of our investment team. We structure our research coverage purposefully to ensure knowledge is spread across the firm. We do not allocate analysts to our coverage list by industry or rating. Similarly, we do not segregate ESG due diligence but require that all team members take ownership to make sure that ESG considerations are fully incorporated into their investment analyses. Canso’s ESG integration process requires an ESG assessment to be made in credit reviews. That assessment involves a separate analysis of each of the ESG factors individually, with particular attention given to the subset of environmental, social and governance issues that are most material to business and financial performance. The focus is on determining the impact of these issues on a company’s cash flows and ultimately its Canso Rating. We judge whether ESG risks reflected in our Canso Rating are fairly priced, and whether client portfolios are compensated for the risks they assume. It is our experience that when companies move to address weaknesses in their corporate practices, including practices related to ESG considerations, these inflection points may represent attractive investment entry points.

Climate Change. The Advisory Clients may acquire investments that are located in, or have operations in, areas that are subject to climate change. Any investments located in coastal regions may be affected by any future increases in sea levels or in the frequency or severity of hurricanes and tropical storms, whether such increases are caused by global climate changes or other factors. There may be significant physical effects of climate change that have the potential to have a material effect on the Advisory Clients’ investments’ business and operations. Physical impacts of climate change may include increased storm intensity and severity of weather (e.g., floods or hurricanes), sea level rise, fires, and extreme and changing temperatures. As a result of these impacts from climate-related events, the Advisory Clients may be vulnerable to the following: risks of property damage to the Advisory Clients’ investments; indirect financial and operational impacts from disruptions to the operations of the Advisory Clients’ investments from severe weather; increased insurance premiums and deductibles or a decrease in the availability of coverage for investments in areas subject to severe weather; decreased net migration to areas in which investments are located, resulting in lower than expected demand for both investments and the products and services of the Advisory Clients’ investments; increased insurance claims and liabilities; increase in energy costs impacting operational returns; changes in the availability or quality of water, food or other natural resources on which the Advisory Clients’ investments’ business depends; decreased consumer demand for consumer products or services resulting from physical changes associated with climate change (e.g., warmer temperature or decreasing shoreline could reduce demand for residential and commercial properties previously viewed as desirable); incorrect long-term valuation of an equity investment due to changing conditions not previously anticipated at the time of the investment; and economic distributions arising from the foregoing. Possibility of Fraud and Other Misconduct of Employees and Service Providers. Misconduct by our employees, service providers and/or their respective affiliates could cause significant losses to the Advisory Client. Misconduct may include entering into transactions without authorization, the failure to comply with operational and risk procedures, including due diligence procedures, misrepresentations as to investments being considered by us, the improper use or disclosure of confidential or material nonpublic information, which could result in litigation, regulatory enforcement or serious financial harm, including limiting our business prospects or future marketing activities and noncompliance with applicable laws or regulations and the concealing of any of the foregoing. Such activities may result in reputational damage, litigation, business disruption and/or financial losses to us. We have controls and procedures through which they seek to minimize the risk of such misconduct occurring. However, no assurances can be given that we will be able to identify or prevent such misconduct. Custody and Banking Risks. The Advisory Clients will maintain funds with one or more banks or other depository institutions (“banking institutions”), which may include U.S. and non-U.S. banking institutions, and may enter into credit facilities or have other financial relationships with banking institutions. The distress, impairment or failure of one or more banking institutions with whom the Advisory Clients and/or

we transact may inhibit the ability of the Advisory Clients to access depository accounts or lines of credit at all or in a timely manner. In such cases, we may be forced to delay or forgo investments when it is not desirable to do so, resulting in lower performance for the Advisory Clients. In the event of such a failure of a banking institution where an Advisory Client holds depository accounts access to such accounts could be restricted and U.S. Federal Deposit Insurance Corporation (FDIC) protection may not be available for balances in excess of amounts insured by the FDIC (and similar considerations may apply to banking institutions in other jurisdictions not subject to FDIC protection). In such instances, the Advisory Clients may not recover such excess, uninsured amounts and instead, would only have an unsecured claim against the banking institution and participate pro rata with other unsecured creditors in the residual value of the banking institution’s assets. The loss of amounts maintained with a banking institution or the inability to access such amounts for a period of time, even if ultimately recovered, could be materially adverse to the Advisory Clients. In addition, we may not be able to identify all potential solvency or stress concerns with respect to a banking institution or to transfer assets from one bank to another in a timely manner in the event a banking institution comes under stress or fails. Additional information regarding the foregoing or the risks and conflicts with respect to any Fund or investment vehicle sponsored or managed by the Firm will be included in the applicable governing documents of the applicable Fund or investment vehicle.

CFM is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, Canada. CFM is the institutional pooled fund management arm within the Canso group as the fund manager of investment funds and other collective/ pooled investment vehicles offered under prospectus exemptions to non-U.S. investors (the “Canso Funds”) and is a wholly-owned subsidiary of Canso.

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Lysander is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, and as portfolio manager and exempt market dealer in the province of Ontario, Canada. Lysander is the retail fund management arm within the Canso group as the fund manager of investment funds offered under prospectus to non-U.S. investors (the “LysanderCanso Funds”) and is an affiliate of Canso under common control.

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PBY is registered as an investment fund manager in the provinces of Ontario, Quebec, and Newfoundland and Labrador, and as a portfolio manager and exempt market dealer across all Canadian provinces. PBY distributes the Canso Funds and the Lysander-Canso Funds to non-U.S. clients of family offices and multi-family offices as well as non-U.S. institutional clients and is also the fund manager of investment funds offered under prospectus exemptions to non-U.S. investors and is an affiliate of Canso under common control.

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PHW is registered as an investment dealer and is a member of the Canadian Investment Regulatory Organization in each province and territory in Canada and is an affiliate of Canso under common control.

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Jesselton is registered as an investment fund manager, portfolio manager and exempt market dealer in Ontario, Canada, and is an affiliate of Canso under common control.

Canso is affiliated through common ownership and control with several Canadian regulated entities, including CFM, Lysander, PBY, PHW. and Jesselton. These entities conduct separate regulated businesses in Canada and are subject to Canadian securities regulation. Certain directors, officers and employees of Canso may also serve as directors, officers or registered individuals of one or more affiliated entities, subject to applicable regulatory requirements and internal conflict management procedures. As of the date of this brochure, Canso does not provide investment advisory services to any U.S. clients and does not currently recommend, invest client assets in, or otherwise utilize affiliated investment products or services in connection with U.S. advisory activities. If Canso were in the future to provide advisory services to U.S. clients and recommend or utilize affiliated products or services, the resulting conflicts of interest would be managed in accordance with Canso's policies and procedures and disclosed to affected clients as appropriate.

is considered material if, depending on the circumstances, it is likely to affect the decision-making process of either party. Certain of these conflicts of interest, as well as a description of how we address such conflicts of interest, can be found below.

Allocation of Investment Opportunities Among Clients In connection with our investment activities, we may encounter situations in which we must determine how to allocate investment opportunities among various clients and other persons, which may include, but are not limited to, Advisory Clients. We maintain policies and procedures that address the potential conflict of interest in such situations. When allocating securities that have been aggregated for the purposes of trading or settlement efficiencies (bulk, block or bunched trades), care is taken to equitably share trading opportunities and expenses between client accounts. If pro-rata distribution is not practical due to security availability or costs, allocation is done based on an established methodology. If trade orders are filled at different times, these partial fills are allocated to client accounts as equitably as possible, taking into account trading costs, commissions and account size. If a pro-rata distribution would result in such a small allocation being made to an account such that it would not affect account performance, such accounts may be excluded from the allocation so that other accounts can benefit from a reasonable allocation. If a trading program continues over a longer period, we review the trading program to ensure that the allocations are fair and not biased towards large or small accounts. Partial fills are allocated to ensure that all account sizes have reasonably uniform positions over time. New issues are allocated to avoid preference to any account over time.

Cross Trades Trades between client accounts, or cross trades, may give rise to conflicts of interest because we are responsible for determining the terms of the trade, including the price, for both accounts. The terms of the trade may benefit one account to the detriment of the other account. This conflict is addressed in several ways, including by ensuring fair and independent pricing of the security being exchanged has been obtained by a reputable and unbiased third party pricing source, such as a broker-dealer or custodian, ensuring the sale or acquisition of the security is in the best interest of the Clients involved and

consistent with their investment objectives, ensuring that neither the Firm nor its related persons receive commissions or other form of compensation related to the cross trade , and that the trade is allocated in accordance with the policy on Allocation of Trades and Investment Opportunities.

Personal Trading To mitigate potential conflicts of interest, our personal trading policy requires our access persons and certain of their family members (“related persons”) to report to the Firm securities accounts and holdings, both upon first becoming an access person/related person of the Firm and on an ongoing basis. Accounts that cannot hold anything other than mutual funds and accounts the Firm determines are discretionary accounts managed by a third party over which the access person or related person does not exercise direct

or indirect influence or control are exempted from the reporting requirement. Access persons and related persons are also required to seek pre-clearance from Compliance prior to securities trading in personal accounts, except for certain types of securities, such as mutual funds, exchange traded funds, money market securities, certain index funds, government of Canada bonds and U.S. Treasury securities, bankers’ acceptance and commercial paper, guaranteed investment certificates and variable and fixed annuities. Access Persons are also prohibited from trading cryptocurrencies, cryptocurrencies ETFs, or any other digital assets, whether directly or by way of derivatives with the exception of selling grandfathered positions held prior to joining Canso, which can be sold without pre-clearance. Related persons are not subject to this restriction.

Gifts and Entertainment To mitigate potential conflicts of interest, our gifts and entertainment policy is intended to ensure that the practice of giving and accepting gifts or entertainment is not abused and does not compromise the integrity, objectivity or fiduciary responsibilities of the Firm or its supervised persons, create an appearance of impropriety or raise potential conflicts of interest. Compliance pre-approval is required for attendance at business events hosted by our business partners and any gifts received by employees are to be notified to the CCO and recorded by Compliance. Only gifts of modest value are permitted and we forbid our supervised persons to offer, solicit, or accept any gift, benefit, compensation, or consideration that reasonably could be expected to compromise their own or another’s independence and objectivity. Cash and cash equivalents (such as gift cards) are prohibited regardless of amount. The cumulative annual permitted expenditure on each person employed by a Business Partner is not to exceed CAD$1,000 (before taxes), except for employees of FINRA-regulated broker-dealers where the limit is CAD$300, unless the CCO gives prior written approval. No gift or entertainment must ever be accepted with the expectation of any quid pro quo from the Firm or any supervised person. Supervised persons are prohibited from giving, and must tactfully refuse, any gift of cash, gift certificate or cash equivalents. Supervised persons may not give or accept any gift or entertainment from any third party that is inappropriate under the circumstances, or inconsistent with applicable law or regulation.

Compensation and Incentive Practices Sales incentives for investment services, and internal sales and revenue targets, are an inherent conflict of interest because they can influence the registered individual to put their own interests ahead of their clients. Canso prohibits sales incentives for investment services, internal sales and revenue targets, and commission-based compensation models to avoid competitive behaviours and selling practices. Registered individuals, including the CCO, are compensated based on their individual contribution to Canso. Furthermore, a compensation committee comprising of members of senior management reviews compensation and bonus awards for all Canso employees.

Management of the Accounts

We intend to manage a number of accounts that have investment objectives similar to each other. We expect that we or our personnel will in the future establish one or more additional separately managed accounts or pooled investment vehicles with investment objectives substantially similar to, or different (and potentially conflicting) from, other Advisory Client accounts. We may give advice or take actions with respect to the investments of one or more Advisory Client accounts that may not be given or taken with respect to other Advisory Client accounts with similar investment programs, objectives or strategies. As a result, Advisory Client accounts with similar strategies will not hold the same securities or achieve the same performance. In addition, it is expected that our personnel responsible for managing a particular Advisory Client account will have responsibilities with respect to other Advisory Client accounts managed by us. Potential conflicts of interest can arise in allocating time, services or functions of these personnel. Personnel have an incentive to allocate more time, services or functions to Advisory Client accounts from which such personnel derive a higher economic benefit and/or better-performing accounts. As described above under Compensation and Incentives Practices, we address this potential conflict of interest by adopting certain anti-competitive compensation and incentive practices. We may from time to time, consider, and reject an investment opportunity on behalf of one Advisory Client account and subsequently determine to have another Advisory Client account make an investment in the same company. A conflict of interest arises because one Advisory Client will, in such circumstances, benefit from the initial evaluation, investigation and due diligence undertaken by us on behalf of the original Advisory Client account considering the investment. In such circumstances, the benefiting Advisory Client will not be required to reimburse the original Advisory Client account for expenses incurred in connection with researching such investment.

In determining whether a particular broker or dealer is likely to provide best execution in a particular transaction, we take into account all factors that we deem relevant to the broker’s or dealer’s execution capability, including, by way of illustration, price, the size of the transaction, the nature of the market for

the security, the amount of the commission, the timing of the transaction taking into account market prices and trends, the reputation, experience and financial stability of the broker or dealer, and the quality of service rendered by the broker or dealer in other transactions. When purchasing or selling over-thecounter securities with market makers, we generally seek to select market makers we believe to be actively and effectively trading the security being purchased or sold. We continuously monitor trade execution offered at different trading venues and maintain a list of approved brokers who are selected for their trade execution quality. In order to monitor best execution, Best Execution Committee meets to review our list of approved broker-dealers and determine whether all of the broker-dealers listed continue to demonstrate the ability and commitment to provide best execution. We do not receive “soft dollars” in connection with any use of broker-dealers.

Aggregation of Trades We may aggregate (or bunch) the orders of more than one Advisory Client for the purchase or sale of the same publicly traded or over-the-counter security. We often employ this practice because larger transactions may enable us to obtain better overall prices, including lower commission costs or mark-ups or mark-downs. We may combine orders on behalf of Advisory Clients with orders for other Advisory Clients for which we have trading authority, or in which we have an economic interest. In such cases, we generally aggregate trade orders for publicly traded or over-the-counter securities so that each participating Advisory Client will receive the average price for each execution of a transaction. If an order for more than one Advisory Client for a publicly traded or over-the-counter security cannot be fully executed, allocation shall be made based upon our procedures for allocation of investment opportunities, as described in Item 11 above.

Trades are discussed regularly. We also utilize computer-generated exception reports from our portfolio management system that will flag any non-compliance with investment constraints and restrictions as outlined in the investment management agreement for each respective Advisory Client. The compliance module in our portfolio

management system evaluates portfolio compliance with the compliance rules assigned to each account. When we take on a new client, investment constraints are codified in our portfolio management system as part of our account opening process and are updated as needed. Where a client has a specific investment restriction or constraint in their portfolio, the teams are made aware of the constraint during the account opening process. Our general practice is to notify clients of any breach to their constraints as soon as it is reasonably possible. There are instances where breaches can occur because of events outside of our control such as market movements and ratings downgrades. In these instances, if we feel it is in the best interests of our clients, we will request permission to continue to hold the security. Otherwise, we will advise clients of the breach and the corrective action taken. Subject to the provisions of the investment management agreement, we will typically provide the Advisory Clients with written quarterly portfolio statement that will list their holdings, the market value, and the position of their investments and transactions. In addition to the information typically provided to all Advisory Clients, at an Advisory Client’s request, we may in certain circumstances provide certain Advisory Clients with additional information.

The Corporate Action Team coordinates the proxy voting based on what the portfolio manager has decided. In the unlikely event a proxy vote presents a conflict of interest with an Advisory Client, the portfolio managers will inform Compliance.