A. Accumulus Capital Management, LLC (“the Firm”) provides investment advisory services to three private pooled investment vehicles that are offered to investors on a private placement basis and investment advisory and discretionary investment management services to Managed Account clients (“Managed Accounts”). The Firm is a Delaware limited liability company which was formed on May 17, 2001 and has been in business since that time. The private pooled investment vehicles advised by the Firm are: Accumulus Fund, L.P., a Delaware Limited Partnership (“AFLP”), Accumulus Fund (the “AF”), a Cayman Islands exempted company incorporated with limited liability, and Accumulus Fund SICAV (“AF SICAV”), (AFLP, AF, and AF SICAV collectively are referred to in this Form ADV Part 2A as the “Funds” and each a “Fund”). Pursuant to investment advisory agreement with the Funds and advisory/management agreements with respect to Managed Accounts, the Firm is responsible for: (i) deciding on the securities to be purchased and sold consistent with the investment objectives; (ii) decisions with respect to leverage and hedging transactions and (iii) monitoring client investments. Benjamin Schliemann and Stefan Zellmer are responsible for managing and selecting the assets of the Funds and Managed Accounts. B. The investments of a Fund are managed in accordance with the Fund’s investment objectives, strategies and guidelines and are not tailored to any particular investor in the Fund. Other than Fund investors which are also Managed Account clients, the Firm does not provide investment advice to the Funds’ investors; therefore, investors should consider whether an investment in a Fund meets their investment objectives and risk tolerance. The Firm’s investment advisory services include adhering to the investment objectives of the Funds and Managed Accounts, determining appropriate asset allocation across investment strategies,

selecting and managing assets and investments, and monitoring existing and prospective investments in accordance with the Funds and each Managed Account’s objectives and risk parameters. The Firm specializes in providing advisory services where the primary investment objective is to achieve superior long-term risk-adjusted returns by investing in a diversified portfolio, consisting primarily of non-traditional investments that seek an appreciation of capital higher than the long-term returns generally obtainable from a balanced portfolio of traditional equity, fixed income and money market securities. Non-traditional investments are defined as funds and other investment structures (collectively, the “Money Managers”), which (i) seek to achieve positive or “absolute” performance, (ii) use a broad range of Form ADV: Part 2A Page 6 investment strategies including short sales and leverage, and (iii) involve management with commitment of its own capital, and (iv) compensate management through a performance based fee structure. Each Money Manager invests according to its individual philosophy and strategy, independent of the other Money Managers which the Firm invests client assets. The Firm does not provide financial planning. C. The advisory services provided to a Fund are in accordance with the Fund’s investment objectives, strategies and guidelines. The advisory services provided to Managed Accounts are in accordance with each Managed Account’s investment objectives, strategies and guidelines. Managed Account clients may impose restrictions on investing in certain securities or types of securities. D. The Firm does not participate in any wrap fee programs. E. Client assets under management on a discretionary basis as of December 31, 2023 were US$580,102,878. Client assets under management on a non-discretionary basis as of December 31, 2023 were US$559,211,443.