Graham is a limited partnership organized under the laws of Delaware in May 1994. The principal owners of Graham are KGT, Inc., a Delaware corporation which serves as the general partner of Graham and of which Kenneth G. Tropin is the president and ultimate sole shareholder, and KGT Investment Partners, L.P., a Delaware limited partnership in which Kenneth G. Tropin and members of his immediate family are significant beneficial owners. Graham Capital LLP, a limited liability partnership registered in England and Wales, is majority owned by Graham Capital Holdings Ltd, a corporation registered in England and Wales, which is wholly owned by Graham. As of December 31, 2023, Graham offers investors various trading strategies that trade in global currency, commodity and other financial markets. Graham utilizes both quantitative and discretionary strategies. Graham’s quantitative trading strategies are generally based on computerized mathematical models that use price-based or fundamental data, or a combination, as the basis of trading decisions. The quantitative strategies pursue various trading approaches, including trend-based programs that seek to identify trends, which allow Graham to participate selectively in potential profit opportunities that can occur during periods of price trends in a diverse number of U.S. and international markets and other quantitative investment strategies such as macro (including fundamental and price-based indicators), beta (market) neutral, high-frequency systems, counter-trend systems and non-trend systems. Currently, each quantitative program generally trades global interest rate futures and swaps, global stock index futures, commodity futures, foreign exchange instruments and direct investments in equity securities, equity futures, swaps and other equity-linked derivatives that are diversified by market and geography and/or, in the case of securities, by security type. Quantitative risk management and portfolio construction techniques are employed with the goal of diversifying risk across the portfolio and enhancing risk- adjusted returns. Graham’s discretionary trading strategies include global macro and non-macro strategies and are generally non-correlated with traditional and other alternative investments. The discretionary strategies trade actively in both U.S. and foreign markets, primarily on major futures exchanges as well as in inter-bank currency and swaps markets, equity exchanges and OTC markets. Graham is generally granted broad investment authority with respect to the management of the accounts of its clients, which include investment vehicles and managed futures separate accounts intended for sophisticated institutional investors, including managed futures separate accounts for investment companies registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Graham may make changes to the trading strategies or systems employed in its trading programs at any time, in its sole discretion. Clients,

as well as investors in the investment vehicles that Graham advises, will not be informed of these changes as they occur. With respect to managed futures separate accounts, Graham can, to a certain extent, tailor such accounts to the specific investment objectives of a client. Graham may agree in the investment management agreement or similar document with each such separately managed account client to investment restrictions or guidelines with respect to the types or amounts of financial instruments that may be purchased or sold for the client’s account as well as volatility targets and other desired characteristics. Graham and its affiliates, Mr. Tropin and members of his immediate family (directly, or through estate planning vehicles) and eligible employees of Graham and their affiliated entities invest in certain funds and accounts that Graham manages. Graham and its principals and their related parties may invest proprietary capital in investment programs different from those offered by any specific fund and in addition invest proprietary capital to start new untested research strategies of Graham, which are not available for investment by Graham clients or fund investors. Certain qualified employees, including portfolio managers, also have exposure to Graham trading strategies as a result of the indexing of portions of their compensation to the performance of such trading strategies. Discretionary portfolio managers and quantitative traders may also be permitted to gain synthetic exposure to the performance of their individual trading strategies through a bilateral agreement between the portfolio manager or quantitative trader and Graham (or an affiliate thereof). The aforementioned arrangements may function as a retention program for participating portfolio managers and other qualified employees and can serve to better align the interests of Graham’s principals and employees with those of Graham’s clients. As of December 31, 2023, Graham provides discretionary investment advisory services to private investment funds and managed futures accounts with aggregate net assets of $17,758,723,738. Graham has been a registered commodity pool operator and commodity trading advisor under the Commodity Exchange Act and a member of the National Futures Association (the “NFA”) since July 27, 1994. Graham has been registered as an investment adviser with the SEC since March 30, 2012. Graham serves as investment adviser to managed futures commodity pools sponsored by Graham and managed futures separate accounts collectively representing $11,395,574,266 of the $17,758,723,738 in net assets. This brochure generally does not address matters related to Graham’s managed futures business, except as it relates to Graham’s role as sub-adviser to registered investment companies. Graham may in the future provide advisory services, either on a discretionary or non-discretionary basis, to other funds or managed accounts on behalf of clients. Graham does not participate in any wrap fee programs.