ADVISORY BUSINESS Penso Advisors, LLC (“Penso Advisors”, “Penso” or “we”) is a Delaware limited liability company with offices in New York, New York and Cedarhurst, New York. Penso Advisors was founded in February 2010 and its principal owners are Ari Bergmann, Penso Manager, LLC and Penso Partners, LLC. Penso Manager, LLC and Penso Partners, LLC are owned by Mr. Bergmann and two of his family trusts, respectively. Penso Advisors is a discretionary global macro manager with a niche focus on derivatives structuring and trading. Currently, the core trading categories we employ are Risk Mitigation and Absolute Return. Within Risk Mitigation, we manage the Negative Correlated Alpha (“NCA”) and Macro Dislocations strategies. Within Absolute Return we manage the Macro Convexity strategy. We may utilize one or more new strategies, including any of our historically utilized strategies based upon our belief of anticipated market conditions and investor interest (any new strategy and collectively with NCA, Macro Dislocations and Macro Convexity, the “Strategies” and each, a “Strategy”). The more highly levered version of any of the Strategies is termed “Ultra”. The core trading categories are listed here for ease of reference and are not necessarily mutually exclusive. Trades may be considered for any of the Strategies as Penso may deem appropriate in accordance with any of our Clients’ mandates. Risk Mitigation: The NCA Strategy is a derivatives-based, risk mitigation overlay solution whose goal is to produce highly convex payouts during systemic/liquidity events categorized by volatile environments with substantial equity drawdown (attachment points). NCA employs a multi-asset class based hedging approach and a dynamic monetization strategy intended to reduce drag during benign, low volatility, risk on environments. The Strategy aims to have a positive expected value over a full market cycle. NCA generally trades in liquid markets ie. Equities, FX, Rates, Credit and Commodities. The NCA Strategy uses a macro trading approach to take advantage of what the manager believes are mispriced correlations and uses proprietary quantitative models that seek to optimize the level and cost of direct equity protection. The Macro Dislocations Strategy is discretionary macro strategy whose goal is to target convex payouts during high vol, risk repricing events while aiming to stay flat during low vol, benign market environments. This Strategy may also seek risk-on opportunities after a market sell-off event. The Macro Dislocations Strategy aims to construct a portfolio of convex tail risk positions combined with multi-purpose macro trades that can help offset the cost of the hedges. The Strategy generally trades in liquid markets ie. Equities, FX, Rates, Credit and Commodities. Most trades are expressed via derivatives structures with limited downside risk limited to premium spent. Absolute Return: The Macro Convexity Strategy is an absolute return strategy that uses a discretionary macro trading approach focused on convex trades across liquid asset classes. The goal of this Strategy is to construct a portfolio of high conviction macro themes with a high convexity profile. The Strategy explores trade opportunities in all relevant asset classes including equities, FX, rates, credit and commodities in all geographies, but mostly G10 and liquid Emerging Market countries. Penso’s macro views are typically expressed using creative derivatives structures in order to control downside risks and to seek to extract the desired convexity. Each of the NCA, Macro Dislocations and Macro Convexity Strategies and, if utilized, other additional Strategies predominantly trade in listed and OTC derivative instruments. Investors may invest either through managed accounts or private funds, as they desire. The managed account structure (“Managed Accounts”) is used for investors who want to implement a Strategy on their own proprietary trading infrastructure or as part of a separate account established in conjunction with such investor and Penso Advisors. The private fund structure, based on fund vehicles sponsored by Penso Advisors (“Penso Private Funds”), has underlying investors (single or in a group) invest in a fund-of-one or fund-of-few vehicle which is comprised of a separate, ring-fenced fund or entity maintained

on a third-party infrastructure platform, primarily structured as a separate cell (a “Cell”) as part of a segregated portfolio company (“SPC”). As aforementioned, a Cell may be either (i) a fund-of-one, single or affiliated investors, or (ii) a fund-of-few or more, where underlying investors invest in a Cell that is commingled (a “Commingled Cell”). Mandates in all of Penso’s vehicles are generally implemented and managed on a bespoke basis and may choose to structure their vehicle using a different, and sometimes a more highly levered version of the strategy or a focus on a specific market (i.e., credit market); nonetheless, these sub-strategies generally will be invested on the same principles as the overall strategy, subject to their respective investment guidelines, as described herein. A Commingled Cell will be established and structured on a bespoke basis and any future investor will be subject to the terms of such Cell as may be modified by agreement. As of the date of this brochure, Penso Advisors’ clients consist of both Managed Accounts and the Penso Private Funds (“Clients”). To date, Penso Advisors’ Managed Account Clients and underlying investors in the Penso Private Fund Clients, have included institutional money managers such as hedge funds, funds of hedge funds, private equity funds, global insurance companies, state and private pension plans, endowments, foundations, family offices, and other institutional or ultra-high net worth investors. A Client or an underlying investor will first choose which Strategy it wishes to employ, including any sub-strategy, and then it can invest in or establish the advisory relationship with the most suitable structure offered by Penso Advisors. With respect to bespoke structures, namely all Client mandates, other than a Commingled Cell after its initial structuring, are generally designed and tailored to address the particular needs and requirements of the Client, including through specific investment guidelines that are set forth in the appropriate investment advisory or management agreement. The terms of the relationship with the Client or its underlying investors, as applicable, are typically detailed in (i) with respect to a Managed Account, an investment advisory or consulting agreement, as applicable, with Penso Advisors, or (ii) with respect to the Private Funds, a private placement memorandum or other offering document (“PPM”), and further, with respect to each Cell in an SPC vehicle, the PPM is then customized and supplemented by an Explanatory Memorandum (or an appropriate supplement) and Investment Management Agreement with each respective fund (or Cell, as applicable). An underlying investor in any of the Penso Private Funds may enter, and some underling investors have entered into, a side letter in connection with such fund, in which the investor is granted certain further customized terms, some of which may be preferential, and which may include among other things; additional representations or covenants, greater transparency, informative reporting, reduced fees and/or expenses and favorable withdrawal rights. In addition, we may grant terms requested by investors to address certain regulatory or policy requirements unique to such investor. Penso Advisors works with CIOs, CROs and trading teams of many of their Clients, or as applicable, their underlying investors on an ongoing basis to address all matters pertaining to macro/systemic risks, address specific issues and to review the progress of their Strategy and investment. Certain of the Penso Advisors’ Client relationships are managed on a non- discretionary basis, which may be based on various conditions, namely the account may or may not trade any proposed transactions and/or proposed trades may be made only by the Client directly, or trades may be made by Penso Advisors as investment manager after the Client’s authorization prior to each proposed transaction. Penso Advisors does not participate in wrap fees programs. As of December 31, 2023, Penso Advisors advises approximately $889,951,000 of regulatory client assets pursuant to specified investment guidelines, of which approximately $276,129,000 are assets for which Penso Advisors has discretionary trading responsibility and approximately $613,822,000 are assets for which Penso Advisors has non-discretionary trading responsibility.