Advisory Business A. General Description of Advisory Firm M28 Capital Management LP (“M28 Capital”, the “Firm”, “we”, “us”, and similar terms) is a Delaware limited partnership formed in October 2019 with a principal place of business in Stamford, Connecticut. M28 Capital began operations as an investment adviser to private fund clients on April 1, 2020. Marc Elia (the “Chief Investment Officer”) is the founder and principal owner of M28 Capital and the managing member of M28 Capital’s general partner, M28 Capital Management GP LLC, a Delaware limited liability company. Mr. Elia has ultimate responsibility for M28 Capital’s management and investment decisions. Christopher Taliercio, President and Chief Compliance Officer (the “Chief Compliance Officer”), is responsible for all non- investment-related operations of M28 Capital. M28 Capital Fund GP LLC (the “Fund General Partner”), a Delaware limited liability company, is an affiliate of M28 Capital and serves as the general partner of private fund clients that are organized as U.S. or offshore partnerships. M28 Capital and the Fund General Partner share facilities and personnel. Mr. Elia is the managing member of the Fund General Partner. B. Description of Advisory Services This Brochure generally includes information about M28 Capital and its relationships with its clients. While much of this Brochure applies to all such clients, certain information included herein applies to specific clients only. M28 Capital provides investment advisory services on a discretionary basis to the following private fund clients (the “Funds”):
• M28 Capital Onshore Fund LP, a Delaware limited partnership (the “Domestic Fund”);
• M28 Capital Offshore Fund Ltd, an exempted company incorporated under the laws of the Cayman Islands (the “Offshore Fund”); and
• M28 Capital Master Fund LP, a Cayman Islands exempted limited partnership (the “Master Fund”), which serves as the master fund into which the Domestic Fund and the Offshore Fund invest all of their investable assets through a “master feeder” structure. The Fund General Partner serves as the general partner of the Domestic Fund and the Master Fund. The Offshore Fund is governed by its Board of Directors. Certain strategic investors (collectively, the “Strategic Investors”) have made a significant investment in the Funds. In connection with such investment, the Strategic Investors benefit from certain rights that are customary for strategic investors in a private fund and that are in addition to, and more favorable than, the rights of other Fund investors, as more fully described in the Funds’ private placement memorandum. In addition to the investment advisory services provided to the Funds, M28 Capital, in connection with certain Master Fund investments, provides investment advisory services on a discretionary basis to investment vehicles that make investments alongside the Master Fund (each a “Co- investment Vehicle”). Currently, M28 Capital provides investment advisory services to the following Co-Investment Vehicles: (i) Veltro Argento LP (“Veltro”) and Sparviero LP (“Sparviero”), Delaware limited partnerships established and operated by M28 Capital, and (ii) a separate account of Bluestem Partners, L.P., a private fund established and operated by Bluestem Asset Management, LLC, a third-party investment manager (the “Separate Account”). The Fund General Partner serves as the general partner of Veltro and Sparviero. M28 Capital expects

to enter into other co-investment arrangements with third parties in the future. References throughout this document to “Clients” refer to each Fund and to each Co-Investment Vehicle listed above and to any other private investment funds, separately managed accounts, and Co-Investment Vehicle that M28 Capital may advise in the future. In providing advisory services, M28 Capital pursues a long/short equity strategy focused on companies in the life sciences and biotechnology sectors. M28 Capital seeks to generate attractive, risk-adjusted returns over the long term, powered by major technological breakthroughs and advances in human health. As part of its investment program, the Funds have made investments in securities that M28 Capital and/or Fund General Partner, in its sole and absolute discretion, elected to designate as “Designated Investments” and may, from time to time, make additional investments in securities or other assets or instruments that M28 Capital and/or Fund General Partner, in its sole an absolute discretion, elect to designate as “Designated Investments.” M28 Capital and/or the Fund General Partner generally expect that Designated Investments will include illiquid investments or investments that are difficult to value. If M28 Capital and/or the Fund General Partner determine that an investment opportunity will be deemed a Designated Investment, allocations of such investment opportunity will generally be made to the Funds based on the participation elections made by the investors in such Funds. Please see “Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss” for a description of the M28 Capital’s investment strategies and certain related risks. Notwithstanding the foregoing, subject to any limitations in the governing documents of the Funds, M28 Capital is not limited with respect to the types of investment strategies it may employ or the markets or instruments in which it may invest. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended, and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. Investors in the Funds must meet the qualifications set forth in the applicable offering documents. Persons reviewing this Brochure should not construe this as, and should understand that this Brochure is not, an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. C. Tailored Advisory Services for Client Accounts M28 Capital manages assets in accordance with the stated investment objectives of each Client, as described in any relevant investment management agreement or similar agreement (an “IMA”) or in an offering memorandum or a Client’s organizational documents (together with the IMA and the offering memorandum, the “Offering Documents”). Investment advice is provided directly to Clients and not individually to the limited partners, shareholders, and investors in Clients (the “Investors”). D. Wrap Fee Programs M28 Capital does not currently participate in wrap fee programs. E. Assets Under Management M28 Capital manages, on a discretionary basis, approximately $157,716,000 of Client regulatory assets under management. This figure for regulatory assets under management was determined as of December 31, 2023. M28 Capital does not manage any assets on a non-discretionary basis.