A. General Description of Advisory Firm. Lombard Odier Asset Management (USA) Corp (the “Investment Adviser” or the “Firm”), a Delaware corporation formed in 2000, commenced operations in its present form in 2007 with an office in New York, New York. Hubert Keller, J ean-P as cal P o rchero t, and Peter Clarke serve as the board of directors of the Investment Adviser (the “Board of Directors”). Mr. Hubert Keller is the chairman of the Board of Directors. The Investment Adviser is owned by LO Holding SA which is ultimately owned by Compagnie Lombard Odier SCmA. B. Description of Advisory Services. The Investment Adviser and its affiliates provide investment advisory and sub- advisory services on a discretionary basis to (i) private pooled investment vehicles, the securities of which are offered to investors generally on a private placement basis (each, a “Fund” and collectively, the “Funds”) and (ii) investment advisory accounts (including separate vehicles set up for a single “investor” for a variety of purposes) for institutional clients (“Managed Accounts”) and (iii) U.S. registered investment companies, including ETFs. The Funds, Managed Accounts and ETF are referred to in this Brochure as “Clients”. Please see Item 8 for further information about the Investment Adviser’s advisory services. The Funds are generally structured as non-U.S. corporations that are generally open-ended collective investment schemes (e.g., Cayman Islands Corporations), and non-U.S. public limited companies (e.g., Luxembourg, société d’investissement à capital variable as Undertakings for Collective Investment in Transferable Securities (UCITS)). All of the Funds are either privately offered investment vehicles excepted from the definition of “investment company” under the Investment Company Act of 1940, as amended, (the “1940 Act”) and therefore are not required to register as an investment company or UCITs vehicles offered outside of the United States. The Investment Adviser’s advice with respect to the Funds and Managed Accounts is made in accordance with the investment objectives and guidelines as set forth in the applicable Fund’s confidential offering memorandum or the Managed Account’s investment management agreement. Affiliates of the Investment Adviser include: Lombard Odier Asset Management (Switzerland) SA, a Swiss société anonyme, Lombard Odier Asset Management (Europe) Limited, a U.K. limited company, and Lombard Odier Funds (Europe) S.A., a Luxembourg société anonyme. These affiliates, together with the Investment Adviser, are collectively referred to herein as Lombard Odier Investment Managers or “LOIM”. Certain affiliated advisory firms are considered to be “Participating Affiliates” of the Investment Advisor (as that term is used in relief granted by the staff of the Securities and Exchange Commission (“SEC”)) allowing investment advisers registered with the SEC to use portfolio management, operations, and trading resources of advisory affiliates and personnel subject to the supervision of an SEC-registered adviser. Professionals from such Participating Affiliates render portfolio management, valuation, operations, research, due diligence, risk management, trading, or other related services to the Investment Adviser’s Clients and/or the Investment Adviser as “Associated Persons” of the Investment Adviser and are subject to supervision by the Investment Adviser. In addition, the Investment Adviser provides portfolio management, risk management, research, due diligence, or other services to the Participating Affiliates under separate services agreements. Fees are paid by and received from the parties under these arrangements. Each Associated Person of the Participating Affiliates are subject to regulatory oversight, training and compliance with the

Compliance Manual, including the Code of Ethics, of the Investment Adviser. The Funds managed are generally structured as either “master feeder” funds whereby one or more ‘feeder funds’ are offered for investment by investors, which in turn invest in a ‘master fund’ that conducts the investment activities, each of which pursues a separate investment strategy or stand-alone direct investment vehicles. Some of the Funds managed by the Investment Adviser invest in more than one underlying master funds managed by the Investment Advisor (each, an “Underlying Master Fund”) which provides investors with access to a diversified set of investment strategies pursued by the Investment Adviser. This Brochure generally includes information about the Investment Adviser and its relationships with its Clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only. This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended (the “1933 Act”), and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. Investors in the Funds generally must be both “accredited investors”, as defined in Regulation D, and “qualified purchasers”, as defined in the 1940 Act. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. C. Availability of Customized Services for Individual Clients. The Investment Adviser’s investment decisions and advice with respect to each Client are subject to each Client’s investment objectives and guidelines, as set forth in its offering documents or investment management agreement. In general, the Funds’ underlying investors may not impose restrictions on investing in certain securities or types of securities. However, the Investment Adviser provides advisory services to Managed Accounts according to investment objectives specified in the pertinent managed account agreements. The Investment Adviser has full discretion in all investment decisions made on behalf of the Clients. The Investment Adviser may provide advice to Clients regarding foreign exchange, interest rates, sovereign credit, fixed income, equities, commodities, corporate credit, options, futures, swaps, other derivatives, and other investments. While there are generally no material limitations on the instruments, strategies, markets or countries in which Clients may invest, the Investment Adviser may permit separately Managed Account Clients to impose restrictions on their accounts with respect to:
• the specific types of investments or asset classes that the Investment Adviser will or will not purchase for their account;
• the nature of the issuers of investments that the Investment Adviser will or will not purchase for their account (e.g., specific industries or sectors); or
• the risk profile of instruments the Investment Adviser will or will not purchase for their account, or the risk profile of the account as a whole. D. Wrap Fee Programs. The Investment Adviser does not participate in wrap fee programs. E. Assets Under Management. As of December 31, 2023, the Investment Adviser had regulatory assets under management of approximately $8.2 billion.