Zweig-DiMenna seeks to achieve its Clients’ investment objectives primarily through a strategy of investing and trading in stocks, both long and short, and other financial instruments. Zweig-DiMenna primarily uses fundamental analysis in its stock selection. Further details regarding Zweig-DiMenna’s methods of analysis and investment strategies are provided below in Item 8. Zweig-DiMenna, which was founded in 1983, provides discretionary investment advisory services primarily to several privately offered unregistered funds (the “Funds”). Zweig-DiMenna may also provide investment advisory services to persons or entities on a managed account basis (each such arrangement, a “Managed Account,” and the person(s) or entity(ies) funding a Managed Account, a “Managed Account Client”). For the purposes of this Brochure, the term “Client” refers to a Fund (but not the investors in the Fund; each an “Investor”) and/or a Managed Account Client, as appropriate in context. Joseph A. DiMenna is the principal owner of Zweig-DiMenna Associates LLC, Zweig-DiMenna Associates, Inc. and Zweig-DiMenna International Managers, Inc. (“ZD Managers”). Zweig-DiMenna Associates LLC and Zweig-DiMenna Associates, Inc. (collectively, “ZD Associates”) and ZD Managers (collectively, “Zweig-DiMenna”) are all managed by the same individuals. In addition, the management persons and employees of each of the Zweig-DiMenna entities are subject to the same supervisory structure and compliance policies and procedures. Zweig-DiMenna has a strategic partnership with an affiliate, Brenton Point Wealth Advisors LLC (“Brenton Point”). Zweig-DiMenna provides Brenton Point with various services, including certain general investment market strategy guidance, and certain administrative, accounting, compliance and

operational support. Brenton Point’s principal owner is Brenton Point LLC, whose principal owner is Joseph DiMenna. In some cases, the officers and employees of Zweig-DiMenna provide services as dual employees and officers of Brenton Point. Please see Item 10 about our dual officer/employee arrangements. Funds Zweig-DiMenna Associates LLC and Zweig-DiMenna Associates, Inc. are the co-general partners, or the general partner and investment manager, respectively, of several Funds that are domiciled within the United States. Zweig-DiMenna through ZD Managers serves as investment manager to a Fund that is domiciled outside the United States. The governing documents of the Funds may, in some cases, contain certain investment restrictions or limitations. However, Investors cannot impose their own restrictions or limitations on the Funds’ investments. Managed Accounts Zweig-DiMenna may from time to time have a limited number of Managed Account Clients whose accounts have substantially the same long/short equity strategy as the Funds. In some cases, a Managed Account Client may be a pooled investment vehicle for which Zweig- DiMenna acts as an investment manager or sub-manager or sub-adviser. Managed Account advisory services are governed by a written agreement (“Managed Account Agreement”) between Zweig-DiMenna and the Managed Account Client. The Managed Account Agreement contains any investment guidelines or restrictions that a Managed Account Client may require. At this time Zweig-DiMenna does not have any Managed Accounts. As of December 31, 2023 Zweig-DiMenna managed approximately $484 million in Client assets, including assets beneficially owned by Zweig- DiMenna and its principals and employees. All assets are managed on a discretionary basis.