PCP is an SEC-registered investment adviser with its principal place of business in London, United Kingdom. PCP was founded in 2001 by:
• Douglas Polunin: Chief Executive Officer and Chief Investment Officer
• Julian Garel-Jones: Director and Chief Financial Officer
• Paul Parsons: Director, Risk and Compliance; Chief Compliance Officer
• Aditya Mehta: Director and Chief Operations Officer The firm commenced business in 2001. PCP is a U.K. Limited Company registered in England and Wales that is authorized and regulated by the Financial Conduct Authority in the United Kingdom. PCP is also registered as an investment adviser with the Securities and Exchange Commission in the United States. Our firm is wholly-owned by Polunin Capital Partners Pte. Ltd., which operates under a Capital Markets Services License from the Monetary Authority of Singapore. Mr. Douglas Polunin, the firm’s CEO owns more than 25% but less than 50% of the Singapore parent company. PCP provides discretionary investment management services predominantly to offshore investment companies. Investors in these funds should refer to the appropriate fund prospectus for important additional information and considerations prior to subscribing to invest. PCP is the appointed investment manager of two pooled investment funds in the U.S.; the investment manager to investment companies domiciled in Luxembourg and the Cayman Islands; the adviser to a U.S. ERISA collective investment fund (collectively, the “Funds”) and sub-adviser or adviser to US segregated mandates. The following Funds are accessible to U.S. persons: 1. Polunin Capital Partners Emerging Markets Active Fund. This is a Cayman Islands-domiciled hedge fund with a minimum subscription size of $250,000. The fund aims to provide investors with absolute returns through a combination of long and short investment positions, predominantly in the securities and derivatives of Emerging Market issuers. This fund is permitted to use leverage, subject to limitations set forth in its prospectus. 2. Polunin Developing Countries Fund, LLC. This fund was launched in 2011 to provide a domestic pooled investment vehicle domiciled in the U.S. This fund mirrors PCP’s core long-only emerging markets all cap investment strategy. The fund has a minimum subscription size of $1,000,000. The all cap Developing Countries strategy is currently closed to new investments and PCP is operating a “commitment list” of investors. As capacity becomes available through investor withdrawals or market conditions Polunin may at its discretion allocate additional capacity. This will generally be offered on a first come, first served basis. 3. Polunin Emerging Markets Small Cap Fund, LLC. This fund was launched in 2014 to provide a domestic pooled investment vehicle domiciled in the U.S. This fund mirrors PCP’s core long-only emerging markets small cap investment strategy. The fund has a minimum subscription size of $1,000,000. The Emerging Markets Small Cap strategy is currently closed to new investments and PCP is operating a “commitment list” of investors. As capacity becomes available through investor withdrawals or market conditions Polunin may at its discretion allocate additional capacity. This will generally be offered on a first come, first served basis. 4. Polunin Capital Partners Collective Investment Trust (the “PCP CIT”). This stand-alone collective investment fund was launched in 2019 to take forward the assets of the white label product that had historically hosted PCP’s ERISA offering. Investors transferred from the white label product into PCP CIT on 29 March 2019. The PCP CIT is managed by PCP in the same style and using the same PCP team as the legacy vehicle, and while it has a different CUSIP number it has retained the relevant performance track record. PCP CIT is available to plan sponsors of both defined benefit and defined contribution tax-qualified employee retirement plans. Global Trust Company (“GTC”), is the appointed Trustee of PCP CIT. GTC has retained PCP to provide investment advisory services to this stand-alone CIT. The all cap Developing Countries strategy, of which the PCP CIT forms a part, is currently closed to new investment and operating a “commitment list” of investors. As capacity becomes available through investor withdrawals or market conditions Polunin may at its discretion allocate additional capacity. This will generally be offered on a first come, first served basis. We also manage or sub-advise separate accounts for institutional clients, including U.S. clients. We provide investment advice to our clients in accordance with specific investment guidelines and restrictions, some of which include restrictions on investing in certain securities or types of securities or other financial instruments. These guidelines and restrictions are mandated by the client with or without consultation with PCP. In contrast, an investment in our Funds does not, in and of itself, create an advisory relationship between Fund investors and PCP. We manage the Funds in accordance with investment guidelines and restrictions specified in each Fund’s offering documents. Typically we have investment management agreements with our Funds. The shares of particular Fund investors or shareholders cannot be managed according to different investment guidelines or restrictions specified by individual Fund investors. The all cap Developing Countries strategy is currently the only strategy which is offered in a managed account. As this strategy is closed to new investments, PCP is not currently accepting additional managed accounts. We have an automated pre-trade compliance process overseen by the firm’s Chief Compliance Officer to help ensure that we manage portfolios in accordance with their specified guidelines and restrictions. PCP specializes in investing in listed Global Emerging Markets’ equities. Our investment philosophy is based on the two distinctive perspectives we hold when seeking opportunities in emerging markets:
• that Replacement Cost in a common currency (USD) is the best valuation metric for companies in emerging markets at any given point in time; and
• that defining the Industrial Sector as the common ground for companies in emerging markets gives the best vantage point. Only companies with the most discounted values relative to replacement costs in each sector, with strong or improving balance sheets, and with the most favorable

sector outlooks are considered for investment. PCP’s methodology is based on Replacement Cost and, with the use of a proprietary database, we calculate the replacement value of emerging markets companies in a common currency unit, the U.S. dollar. We view emerging markets not by country, but by Replacement Cost in each sector. This allows us to differentiate between companies trading above or below the median replacement value in each sector. It also gives PCP an objective top-down view of the emerging world based on bottom-up valuations – a unique perspective. We rank emerging market companies within their respective industrial sectors, based on their RVBRIC (pronounced “Rubric”) values. The RVBRIC value is a proprietary valuation metric developed by Douglas Polunin and his team. It is an acronym that stands for Replacement Value, Balance sheet Risk, and Industry Conditions. The RVBRIC value is calculated as the quotient of Enterprise Value divided by Industrial Capacity, or replacement value. Enterprise Value is the sum of market capitalization and net working capital, all in U.S. dollars, while Industrial Capacity is expressed in the relevant unit of capacity for each company. PCP has created a proprietary database that calculates RVBRIC values and ranks companies accordingly by industrial sector. The database houses financial data on over 21,000 publicly listed emerging market companies, including key balance sheet, income statement and corporate data going back at least five years. Pricing and exchange rates are updated. Balance sheet items are also populated on a quarterly or half yearly basis, depending on individual countries' reporting requirements. PCP has also developed a proprietary data importer application, which permits the manual inputting of data on companies, including industrial capacity data, using information obtained directly from the companies in question. Complete RVBRIC calculations are currently available for approximately 10,000+ names. Once the ranking has been calculated by the proprietary database for a given industrial sector, the Median Company in the list is defined as fair value. It is the average at which the emerging market companies in that sector trade. PCP defines all companies trading below the Median as potentially undervalued, and all those above as overvalued. Liquidity screens reduce the number of potential portfolio candidates to approximately 1,500 large cap companies and approximately 5,000 small cap1 companies. Stocks that are too illiquid are eliminated immediately. For our core Developing Countries strategy, PCP’s liquidity policy is that at least 70% of the invested portfolio will at all times be in securities that can be liquidated within 7 (seven) trading days, accounting for no more than one third of the daily market volume. PCP’s smaller capitalization niche strategies, in particular our Emerging Markets Small Cap strategy, have less onerous liquidity requirements, with a liquidity policy that requires at least 75% of the invested portfolio to at all times be in securities that can be liquidated within 15 (fifteen) trading days, accounting for no more than one third of the daily market volume. PCP then conducts extensive on-site visits and/or research telephone calls with the management of companies that are identified as being potentially mispriced. The visits and calls are designed to obtain new, or to verify existing capacity information. In addition, the visits are designed to understand why the market is placing such a large valuation discount or premium on the target company versus the remainder of the sector in emerging markets. 1 Small cap company is defined as a company that typically has a market capitalization of USD $2.5 billion or less. If the company is extremely undervalued, the visits are intended to cast light on the management or majority shareholders’ strategy for realizing the company’s true value. The investment managers conduct extensive additional sector research, tracking variables such as supply and demand, product pricing, mergers and acquisitions, capital expenditures and pricing power on a global basis. If a company appears excessively over-valued, the visit will concentrate on understanding which factors have caused the company to enjoy a premium rating by the market, and which factors, if any, are vulnerable to disappointments. Trading liquidity is a key consideration when investing in emerging markets. Our larger cap strategy portfolios typically comprise around 150 stocks and our small cap strategy portfolios typically comprise around 175 stocks, in both cases with stocks spread across at least 10 countries and over 10 industrial sectors. PCP’s portfolios have a high active share, typically around 90% within our larger cap strategy portfolios and around 95% within our small cap strategy. Investors in the Funds should refer to the relevant Fund offering documents for additional information. Clients for whom we manage separately managed accounts will find more information in their investment management agreements and related account documentation. Assets: As of December 30, 2022, PCP had $4,155,893,543 in discretionary assets under management. PCP does not manage any assets on a non-discretionary basis. PCP contingency plans and remote working capabilities: PCP hosts all I.T. infrastructure on a private cloud located at a data centre in Kent, United Kingdom which in turn is backed up offsite on a regular basis. All employees work on virtualised desktops which are accessible both at work and from offsite locations. The virtual desktop provides access to all office resources (depending on roles-based permissions), and offsite access is protected by two-factor authentication. In addition, PCP uses a cloud-based phone system ensuring that not only can all DDIs be easily switched to mobile, but also that there is no interruption of the compliance requirement for all business calls to be recorded. The only requirement to enable work to be conducted from any offsite location is a stable internet connection. The last full Disaster Recovery test was conducted on December 29, 2022. PCP retains the ability to implement both split-team working and shelter-in-place working scenarios. The firm is able to split employees into two teams that complement one another for investment, client service, compliance and back-office functionality.