Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Firm Description Founded in February 2016, True Partner Capital USA Holding, Inc. (the “Firm” or “TP US”), a Delaware corporation, maintains its principal place of business in Chicago, Illinois. It is exempt from registration with the Commodity Futures Trading Commission (“CFTC”) under CFTC Rule 4.14(a)(10) and has received Central Bank of Ireland clearance to act as an Investment Manager. The Firm and its affiliates, True Partner Advisor Limited (“TP Advisor”) and True Partner Advisor Hong Kong Ltd (“TP HK”), provide Clients with discretionary investment advisory and management services as an integrated group of companies. Discretionary investment advisory and management services are provided to the Clients below:
• True Partner Offshore Fund, a Cayman Islands exempted company (the “TP Offshore Feeder Fund”); True Partner Onshore Fund, LP a Delaware limited partnership (the “TP Onshore Feeder Fund” and, together with the TP Offshore Feeder Fund, the TP Feeder Funds”); and the master fund, True Partner Fund a Cayman Islands exempted company (the “TP Fund” and, together with the TP Feeder Funds, the “TP Funds”). The TP Feeder Funds invest substantially all their respective assets in the master fund, TP Fund. The purpose of the TP Fund is to achieve administrative efficiencies and to offer terms suitable to the particular needs of various investors. The TP Fund has no investors other than the TP Feeder Funds.
• True Partner Volatility Fund, a Cayman Islands exempted company (the “TP Vol Offshore Feeder Fund”); True Partner Volatility U.S. Fund, L.P., a Delaware limited partnership (the “TP Vol Onshore Feeder Fund” and, together with the TP Vol Offshore Feeder Fund, the “TP Vol Feeder Funds”); and the master fund, True Partner Volatility Master Fund, a Cayman Island exempted company (the “TP Vol Master Fund” and together with the TP Vol Feeder Funds, the “TP Vol Funds”). The TP Vol Feeder Funds invest substantially all their respective assets in the TP Vol Master Fund. The purpose of the TP Vol Master Fund is to achieve administrative efficiencies and to offer terms suitable to the particular needs of various investors. The TP Vol Master Fund has no investors other than the TP Vol Feeder Funds.
• TP Customized Volatility Fund, a Cayman Islands exempted company (“TPCV Fund”), is a fund- of-one and the sole investor is a trustee on behalf of a U.S. corporate pension fund. NOTE: TPCV Fund is being wound down and assets have been returned to the investor. (The TP Funds, the TP Vol Funds and the TPCV Fund together, “the True Partner Funds,” or individually, “the True Partner Fund”) The True Partner Funds are private fund CFTC Rule 4.7 commodity pools and TP Advisor acts as the Commodity Pool Operator (“CPO”).
• Three sub-funds of two separate and distinct Undertakings for the Collective Investment in Transferable Securities (the “UCITS Sub-funds” or individually, the UCITS Sub-fund). For the TP Funds and the TP Vol Funds, TP Advisor delegates portfolio management to TP HK, which in turn sub-delegates portfolio management to the Firm. For the TPCV Fund, TP Advisor delegates portfolio management to the Firm, which meets the requirements of qualified professional asset manager. For the three UCITS Sub-funds, the Firm delegates portfolio management to TP HK. To ensure maximum efficiency, the Client portfolios are passed over the course of the trading day from Hong Kong to Amsterdam to Chicago. TP Advisor is a Cayman Islands registered, Registered Person; CFTC registered Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”); and a member of the National Futures Association (“NFA”). It is exempt from SEC registration as it is a “participating affiliate” of the Firm under the relief described in the 1992 SEC staff no action letter granted

to Uniao de Banco de Brasileiros S.A. and related no action letters. (IM-INFO-2017-03). TP HK is licensed to conduct Type 9 (asset management) regulated activities by the Securities and Futures Commission of Hong Kong (“SFC”). It is exempt from SEC registration as it is a “participating affiliate” of the Firm under the relief described in the 1992 SEC staff no action letter granted to Uniao de Banco de Brasileiros S.A. and related no action letters. (IM-INFO-2017-03). TP HK is exempt from registration with the CFTC under CFTC Rule 4.14(a)(10) and has received Central Bank of Ireland clearance to act as an Investment Manager. True Partner Onshore Fund GP, LLC (“TP GP”) is the general partner of the TP Onshore Feeder Fund. TP GP has delegated its CPO responsibilities to TP Advisor. True Partner Volatility Fund GP, LLC (“TP Vol GP”) is the general partner of the TP Vol Onshore Feeder Fund. TP Vol GP has delegated its CPO responsibilities to TP Advisor. The Firm and its affiliates are an integrated group of registered/licensed companies. The Firm’s officers and directors also serve as officers and directors of the Firm’s affiliates. For TPCV Fund, the Firm has an agreement with TP HK whereby the Hong Kong-based co- CIO and Portfolio Managers have double-hatted employment agreements with the Firm. Principal Owners/Ownership Structure The Firm is owned and controlled by True Partner Holding Limited, a limited private company based in Hong Kong. The ultimate parent company is True Partner Capital Holding Limited, a Cayman Islands company with limited liability, and its shares are listed on the Growth Enterprise Market (GEM) of the Hong Kong Stock Exchange (Stock Code: 8657). Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. The Firm provides Clients with portfolio management services that apply global equity volatility arbitrage strategies which are described in Item 8. A. below. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. The advisory services provided to the Clients are tailored to the investment objectives, investment strategy and investment restrictions, if any, as set forth in Client governing documents and advisory service agreements. The advisory services are provided directly to the Clients, not to the Clients’ investors individually. A True Partner Fund may enter into side letters or similar agreements with certain significant investors that have the effect of establishing rights or altering or supplementing a True Partner Fund’s governing documents. Such rights may include notification and disclosure rights, modified fee arrangements, and transfer rights. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. The Firm does not participate in wrap fee programs. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non- discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2022, the Firm and its affiliates had $1,078,939,293 of assets under management, all managed on a discretionary basis.