General Description of the Firm Zephyr Management, L.P. and its affiliated investment advisers (“Zephyr” or the “Firm”), a New York limited partnership founded in 1994, is an investment adviser specializing in the creation and management of private equity funds investing in emerging markets and private marketable securities funds investing in global equities and fixed income. Zephyr’s advisory service offerings are described in more detail below. Zephyr is principally owned and controlled by Thomas C. Barry and Mukul Gulati. The General Partner of Zephyr Management, L.P., Zephyr Management, Inc., serves as the investment adviser to certain of the private investment funds. Additionally, ZP India Advisory Private Limited, Zephyr Peacock Management Limited and Zephyr Acorn LLC are wholly owned or controlled subsidiaries and affiliates of Zephyr Management, L.P. that serve as investment advisers to certain of the private investment funds. Description of Advisory Services Emerging Markets PE Advisory Services. Since the Firm’s founding in 1994, Zephyr has created and managed pooled investment vehicles that invest globally in private equity and venture capital securities (collectively, the “PE Funds”), each of which are managed by general partner-like entities, affiliated with the Firm (each a “General/Managing Partner,” and collectively, the “General/Managing Partners”). Currently, Zephyr’s Emerging Markets PE investment strategy (the “Emerging Markets PE Strategy”) is focused on private equity financing for small to medium sized companies in India and early-stage enterprises in Sub Saharan East Africa. Zephyr Waterfield Advisory Services. Since 2020, in collaboration with Waterfield Advisors Private Limited, a wealth and family office advisory firm based in India, the Firm also manages the Zephyr Waterfield Funds (each a “Zephyr Waterfield Fund”; collectively, the “Zephyr Waterfield Funds”). The U.S. Zephyr Waterfield Funds are organized as series vehicles of Zephyr Waterfield U.S. Funds, LLC, a Delaware limited liability company, while the non-U.S. Zephyr Waterfield Funds are organized as series vehicles of Zephyr Waterfield Fund Ltd., a Bermuda segregated accounts company. Each Zephyr Waterfield Fund has its own distinct objective, strategy and policies so that the Zephyr Waterfield Funds offering in its entirety provides a range of investment options. The investment objective of each Zephyr Waterfield Fund is to achieve long-term capital

appreciation through investment in a diversified portfolio of liquid publicly-traded assets including exchange traded funds (“ETFs”) and actively and passively managed mutual funds. Each Zephyr Waterfield Fund measures its performance against a custom benchmark that is a weighted blend of indices relevant to each Zephyr Waterfield Fund’s investment strategy. Each of the PE Funds and Zephyr Waterfield Funds are referred to as a “Fund” and collectively as “Funds” throughout the Brochure. The Funds are exempt from registration under Sections 3(c)(1) or 3(c)(7) of the Investment Company Act of 1940, as amended, and are offered to investors on a private placement basis. The investment strategies of the Funds are further described in Item 8. The Firm’s investment decisions and advice with respect to each Fund are subject to such Fund’s investment objectives and guidelines as set forth in the applicable investment management agreement, offering memorandum, limited partnership agreement, subscription materials or other governing documents (collectively, the “Governing Documents”). Investors in the Funds (referred to herein as “Investors”) generally cannot impose restrictions on investing in certain securities or types of securities. Investors participate in the overall investment program for the applicable Fund, but can be excused from a particular investment due to legal, regulatory or other applicable constraints, pursuant to the terms of the applicable Governing Documents. In accordance with industry common practice, the Firm or a Fund’s General/Managing Partner may enter into side letters or similar agreements with certain Investors in the Funds that have the effect of establishing rights under, or altering or supplementing the terms of, the relevant agreement with respect to such Investors (“Side Letters”). Examples of Side Letter rights include certain fee provisions, information rights, liquidity and withdrawal provisions, concentration limits, notification provisions and most favored nations provisions. These rights, benefits or privileges are not always made available to all Investors nor in some cases are they required to be disclosed to all Investors, consistent with general market practice. Wrap Fee Programs Zephyr does not currently participate in any wrap fee programs. Assets Under Management As of December 31, 2023, Zephyr managed $190,890,927 in assets on a discretionary basis. The Firm does not manage any assets on a non-discretionary basis.