A. The Adviser, an investment advisory firm located in Boston, Massachusetts, advises on investing in and actively manages primarily a long-short equity and equity derivatives investment portfolios. The Adviser’s principal investment objective is to seek to maximize total return for the Clients primarily through the capital appreciation of their investments. In attempting to achieve this investment objective, the Adviser expects to invest in, hold, sell, sell short and trade equity securities, equity derivatives, exchange traded funds (“ETFs”), ETF derivatives and PIPEs (private investment in public equities). The Adviser may also engage in other financial instruments including, but not limited to, currency swaps for hedging purposes. The Adviser was formed in 2019 and is a Delaware limited liability company but the Adviser has been operating the advisory business through certain affiliates since 2012. Devesh Gandhi is the sole principal owner of the Adviser. B. The Adviser provides investment advisory services to pooled investment vehicles operating as private funds for sophisticated, qualified investors, including high net worth individuals, retirement plans, trusts, partnerships, corporations, or other businesses (each, the “Fund” and, collectively, the “Funds”) and separately managed accounts (each an “SMA,” Funds and SMAs collectively referred to as “Clients”). The governing documents of each Fund may also provide for the establishment of parallel or other alternative investment vehicles in certain circumstances. Fund investors may participate in such vehicles for the purposes of certain investments, and if formed, such vehicles would also become Clients of the Adviser. The Adviser’s investment objective is to seek to maximize total return primarily through the capital appreciation

of its investments. In attempting to achieve this investment objective, the Adviser expects to invest in, hold, sell, and trade equity securities, equity derivatives, exchange traded funds, and other related financial instruments, although the Adviser also expects that it may invest in a number of other asset classes and/or financial instruments, as further described below. The Adviser primarily expects to take long positions in equity securities, or in other assets it believes are undervalued, and short positions in equity securities, or in other assets the Adviser believes are overvalued. The Adviser expects the majority of its investments will be focused in the United States, but also expects to invest in other developed markets. The Adviser may consider investments in companies in less developed markets on an opportunistic basis. C. While each of its Clients generally follows the strategy stated above, the Adviser may tailor the specific advisory services with respect to each Client based on the particular investment objectives and strategies described in the applicable Client’s confidential offering memorandum, if any, and governing documents, including Fund’s operating agreement, or the investment management agreement of the SMA (referred to collectively as “Governing Documents”). All discussion of the Clients in this Brochure, including but not limited to their investments, the strategies used in managing the Clients, and conflicts of interest faced by the Adviser in connection with the management of the Clients are qualified in their entirety by reference to each Client’s respective Governing Documents. D. The Adviser does not participate in wrap fee programs. E. As of December 31, 2023, the Adviser manages $538,709,225 in discretionary assets.