A. General Description of Advisory Firm RWC is a limited liability partnership incorporated under the laws of England and Wales. The Firm was formed in December 2007. Redwheel is an investment adviser with a principal place of business in London, England, United Kingdom. The Firm’s principal owner is RWC Partners Limited (“RWC Partners”). RWC Partners is wholly owned by RWC Midco Limited (“RWC Midco”) and RWC Midco is fully owned by RWC Holdings Limited (“RWC Holdings Ltd”). RWC Holdings Ltd is substantially owned by its staff (former and present, directly or via an employee benefit trust) with LPC Pinetree LLC retaining the remainder of the ownership. B. Description of Advisory Services Redwheel primarily provides investment advisory services to pooled investment vehicles (collectively referred to herein as the “Funds” and individually a “Fund”) on a discretionary basis. These Funds rely on an exemption from registration under Section 3(c)(7) of the Investment Company Act of 1940 (the “Investment Company Act”). Redwheel also provides discretionary investment advisory services to separately managed accounts (“Managed Accounts”); collectively, the Funds and the Managed Accounts will be referred to herein as (“Clients”). Redwheel generally has broad and flexible investment authority with respect to certain of its Clients. For Redwheel European Focus Fund Inc. (the “European Focus Fund”), Redwheel seeks to generate attractive absolute returns over the long term as well as significant alpha relative to relevant European reference indices. The strategies invest in a concentrated portfolio of principally European equities and seeks to generate excess returns through active ownership of listed companies. For Redwheel Horizon Equity Fund Limited (the “Horizon Fund”), Redwheel aims to generate alpha over a rolling 4-year period (relative to the benchmark) by investing predominantly in a portfolio of equities from around the world. The flexibility and long-term nature of the fund will entail significant performance divergence from the MSCI All Countries World Index. For Redwheel Frontier Markets Equity Fund (the “Frontier Equity Fund”), Redwheel seeks to uncover medium to long term growth opportunities, investment themes and valuation inefficiencies in frontier

markets. The strategy invests in a portfolio of equities on a long only basis and targets outperformance of frontier market equities over a market cycle. The fund invests in fast-growing and early stage frontier markets around the world with no regional or sectoral bias. For Redwheel International Equity Fund Limited (the “International Equity Fund”), Redwheel is to achieve long-term capital appreciation by investing in global markets (excluding the United States). By employing a thematic investment strategy that combines top-down and bottom-up approaches to investing in global markets (excluding the United States) For Redwheel Funds, an open-ended collective investment company with an umbrella structure comprising different sub-funds offered to non-U.S. investors, Redwheel seeks return compatible with the specific investment policies of the sub-funds, as described in the offering memoranda. The Firm employs various strategies and can invest or trade in a wide variety of financial instruments, including, but not limited to: equities, currencies, commodities, fixed income, warrants, rights, options, swaps, preferred stocks, convertible securities and money market obligations, amongst others. C. Tailored Advisory Services Generally, the Firm does not expect to tailor its advisory services to the individual or particular needs of investors in the Funds. Such investors will accept the terms of advisory services as set forth in each Fund’s governing documents. The Firm expects to have broad investment authority with respect to the Funds and, as such, investors should consider whether the investment objectives of the Funds will be in line with their individual objectives and risk tolerance prior to investment. Redwheel may tailor its advisory services to the individual needs of its Managed Accounts by negotiating the terms of its advisory contracts. Managed Accounts may also be tailored for legal, regulatory or tax purposes. Each investment management agreement and related account documentation for a Managed Account will specify the particular investment program and any related investment restrictions. D. Wrap Fee Programs Redwheel does not participate in wrap fee programs. E. Assets Under Management As of December 31, 2023, Redwheel had assets under management of $ 10,180,349,177.