A. Regal Partners Limited (formerly VGI Partners Limited) (“RPL AU” or the “Firm”) is an ASX listed (ASX: RPL) SEC-registered investment adviser. The Firm as it is currently composed was created by a merger (as announced March 30, 2022) between VGI Partners Limited and Regal Funds Management Pty Limited completed on 3 June 2022 following shareholder approval at VGI Partners Limited Annual General Meeting held 27 May 2022. The resulting entity holds significant ownership stakes in investment managers through which it operates an investment management business. Certain subsidiaries of the Firm file separately with the SEC on Form ADV as exempt reporting advisers. However, as currently structured, following the merger, RPL AU operates the investment management business that was formerly under VGI Partners Limited. Accordingly, this brochure relates to the legacy business of VGI Partners Limited. The Firm is also regulated by the Australian Stock Exchange (ASX) and is subject to the requirements of the Australian Corporations Act 2001 (Cth). The Firm is headquartered and maintains its principal office(s) in Sydney, Australia. The Firm is currently owned approximately 62% by the Board, Senior Management and staff of RPL AU and its subsidiaries/affiliates. The Firm has an affiliated subsidiary, Regal Partners US, Inc. (“Regal Partners US”) (formerly named VGI Partners, Inc.), incorporated October 2011 in New York (collectively, RPL AU, and Regal Partners US, “Regal”). The Firm has a wholly owned subsidiary, Regal Asian Investments Management Pty Limited (formerly named VGI Partners Asian Investments Management Pty Limited) in Sydney, Australia, which is investment manager to Regal Asian Investments Limited (ASX: RG8) (formerly named VGI Partners Asian Investments Limited (ASX:VG8)), listed November 2019. The investment manager, Regal Asian Investments Management Pty Limited has an investment advisory agreement with another wholly owned subsidiary of the Firm, Regal Funds Management Pty Limited. Regal Funds Management Pty Ltd assists the Manager with the investment of RG8’s portfolio. The investment team at Regal Funds Management Pty Limited for this arrangement is led by its Chief Investment Officer, Philip King. 5 | P a g e B. RPL is a high conviction global investment manager. RPL is mandated to use a broad range of financial instruments. RPL primarily focuses on listed equities, listed equity options and cash. The RPL investment strategy follows:  Invest in a focused equity portfolio of high-quality global securities.  Geographic Diversity (Global strategy): core markets include the USA, UK, Europe, Japan, South Korea, Singapore, Hong Kong, Taiwan, Australia, New Zealand. Geographic Diversity (Asia strategy): core markets include Asian listed securities and other companies with significant exposure to the Asian Region.  Select stocks through carefully constructed and consistently applied evaluation measures.

 Short sell securities which are assessed to be vulnerable to material decline in price where the trigger event is identifiable. The investment philosophy and investment process are based on the fundamental evaluation of businesses and not on changes to the global economy or market conditions. Shifting market conditions may change our investing and hedging activity. For example, during periods of high volatility we may hedge with cash or additional short selling. There has been no material change in RPL’s Global strategy since inception. The Asia strategy (RG8) follows a similar strategy to the Global strategy, other than the investment focus is on Asian listed equities and other companies with significant exposure to the Asian Region. The RPL investment philosophy aims for:  Capital preservation  Superior long term compound growth  Concentration in a relatively small number of high quality investments  Conviction resulting from detailed internal research  Primarily a ‘buy and hold’ strategy for long investments  Hold cash in periods when we feel no “margin of safety” exists  Selectively short companies which are identified to be structurally weak and believed to be vulnerable to material price declines. 6 | P a g e The RPL Investment Team invests in high conviction positions. The following are some of the qualities we look for when identifying investment opportunities:  Simple and easy to understand business model  Dominant in its industry  Superior returns on capital  Sustainable competitive advantage  Significant cash flow generation  Strong balance sheet  High quality management RPL provides financial product advice for securities; interests in managed investment schemes, foreign exchange contracts and derivatives. RPL does not generally provide any other advice to clients. C. RPL manages capital for a select number of pre-qualified, high net worth individuals, family offices and other wholesale clients. Capital management is achieved through managed investment funds, separately managed accounts and Australian listed investment companies. The managed investment funds, separately managed accounts, and Australian listed investment companies are all managed using RPL’s investment strategy and philosophy. All US investors into RPL-managed investment funds must be “accredited investors” under SEC Regulation D and “qualified clients” as defined in Rule 205-3 under the United States Investment Advisers Act of 1940 (the “Advisers Act”). The Australian listed investment companies (“LIC”) initial public offerings were only available to persons receiving the Electronic Prospectus in Australia and New Zealand. The initial public offerings were not open to persons in the United States. D. RPL does not participate in wrap fee programs. E. As of 31 December 2022 RPL, managed approximately US$948 million of client net assets globally on a discretionary basis. RPL generally reports net assets under management to its clients. 7 | P a g e