Client & Investor Information and Privacy Policy

The Company is required by federal regulations to adopt certain procedures designed to protect all Client & Investor confidential and nonpublic information and to safeguard personal information contained in both paper and electronic records. The following policy (the “Privacy Policy”) is designed to meet the standards set forth in the federal regulations as well as the Commonwealth of Massachusetts Standards for Protection of Personal Information (to the extent that such standards are applicable). For purposes of this Privacy Policy, the term Client includes, where appropriate, investors in Funds managed by the Company.

Regulation S-P

Regulation S-P, a set of privacy rules promulgated by the SEC under the Gramm-Leach-Bliley Act, requires Advisers to provide their natural person clients with notice of their privacy policies and practices. Advisers also are not permitted to disclose nonpublic personal information about a consumer to non-affiliated third parties unless the institution provides certain information to the consumer and the consumer has not elected to opt out of the disclosure. Although the regulation applies only to the personal information of natural persons, as a best practice, most Advisers treat institutional client information as they would individual client information. The Company complies with Regulation S-P as follows:

• The Company provides notice to Clients and Investors in its Funds about its Privacy Policy in the form of a privacy notice at the inception of the relationship with the Client and annually thereafter.

• The initial privacy notice is delivered to prospective investors with the subscription documents for the Fund. The notice is distributed to each Fund and investor if the notice is materially changed. The CCO or Compliance Team oversees the distribution of initial and annual privacy notices.

• The Company strives to: (a) ensure the security and confidentiality of Fund and investor records and information; (b) protect against any anticipated threats or hazards to the security or integrity of client and investor records and information; and (c) protect against unauthorized access to or use of client or investor records or information that could result in substantial harm or inconvenience to any Fund or investor.

Regulation S-AM

Regulation S-AM, promulgated by the SEC under the Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Act of 2003, governs the sharing of an Adviser’s consumer information with affiliates for marketing purposes. As with Regulation S-P, the rules protect information on individuals. Advisers generally are prohibited from using information obtained from an affiliate to market products or services to a “consumer” unless the consumer has been notified of all affiliate information sharing arrangements for marketing purposes, and the consumer has been given an opportunity to opt out of the solicitations.

The Company’s relationships with the General Partners of the Funds may be deemed to be affiliate relationships for purposes of Regulation S-AM. To this end, the Company’s Privacy Notice to Clients makes full disclosure of the information sharing practices between the Company and the General Partners and will provide an opt-out to investors if required under the regulation. The CCO or designee will review the Privacy Notice to Clients to ensure that it accurately depicts the information sharing arrangements in place between affiliates.

State Privacy Laws

In addition to Regulation S-P and Regulation S-AM, certain states have adopted consumer privacy laws that may be applicable to Advisers with clients or investors who are residents of those states. For example, Massachusetts has a law (201 CMR 17.00) that requires any company with personal information about its residents to adopt and implement a comprehensive information security program. The California Consumer Privacy Act Exemption (“CCPA”) includes certain notification provisions for California consumers, as well as provisions allowing such consumers to obtain copies of their information, request that such information be deleted, and opt out of having their data sold or shared, subject to certain exceptions in the law. The New York’s Stop Hacks and Improve Electronic Data Security Act (“NY SHIELD Act”) requires notification to resident consumers and specified government offices in the event of a breach, without regard to whether there was mere unauthorized access of consumer data or such data was actually taken. Advisers that collect information from such residents must incorporate these standards into compliance policies. Privacy laws are constantly changing in the United States, and other state privacy laws may apply depending on the Company’s activities and location of its Investors and Employees. The Company seeks to comply with all applicable legal regulations to which it is subject and has taken steps as identified in this policy and the Cybersecurity Policy to protect confidential information and establish an incident response plan in the event of any potential breach.

Identity Theft Risks

Pursuant to Regulation S-ID (Identity Theft Red Flags) (“Red Flags Rule”), each registered investment adviser that (i) is a “financial institution” or “creditor” and (ii) offers or maintains one or more “covered accounts” is required to develop and implement a written identity theft prevention program that is reasonably designed to detect, prevent, and mitigate identity theft (and otherwise in accordance with the Red Flags Rule). A “financial institution” generally is defined as any “person that, directly or indirectly, holds a transaction account belonging to” an individual. A “transaction account” includes any account on which an individual is permitted to “make withdrawals by negotiable or transferable instrument, payment orders of withdrawal, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others.” In general, an adviser may meet the definition of “financial institution” if: (i) it has the ability to direct transfers or payments from accounts belonging to individual clients to third parties upon such clients’ instructions, or it acts as agent on behalf of clients, or (ii) it acts as adviser to a private investment fund and has the authority, pursuant to an arrangement with the private fund or the individual Investor, to direct an Investor’s withdrawal or distribution proceeds to third parties upon instructions received from the Investor. An investment adviser may be a “creditor” if it advances funds to an Investor that are not for expenses incidental to the services provided to that Investor, such as where a private fund adviser regularly and in the ordinary course of business lends money, short-term or otherwise, to permit Investors to make an investment in the fund, pending the receipt or clearance of an Investor’s check or wire transfer.

The Company has reviewed its business practices to determine whether or not it currently fits within the definition of “financial institution” or “creditor” for purposes of the Red Flags Rule. The Company does not have any individual clients and does not have authority to withdraw or transfer (or direct the applicable custodian to withdraw or transfer) any funds of securities from an Investor’s account to third parties. Fund subscription agreements state that any amounts paid to an Investor in connection with distributions will be paid to the same account from which capital contributions were originally remitted, which must be in the name of the Investor, unless the General Partner agrees otherwise. The Company does not accept payments from third parties or direct distributions to third parties. In addition, the Company is not a creditor because it does not regularly advance funds to Investors as contemplated by the Red Flags Rule. Based upon the foregoing, the Company does not believe that it is currently subject to the Red Flags Rule or otherwise required to develop and implement an identity theft program pursuant to the Red Flags Rule. The Company will review this determination on a periodic basis and in light of changing business practices to verify whether or not it is subject to the Red Flags Rule.

Based upon its business and activities and the nature of its Client and Investor relationships, the Company generally believes that the risk of identity theft or other fraudulent activity is relatively low. Nevertheless, prevention of identity theft is an integral aspect of the Company’s Privacy Policy, and the Company is committed to protecting its Clients and the Investors from identity theft and other fraudulent activity. All Employees are required to take reasonable and appropriate actions in order to protect Clients and Investors from identity theft and other fraudulent activity, including being alert to any suspicious activity by or on behalf of or with respect to a Client or Investor.

An identity thief can obtain a victim’s non-public personal information through a variety of methods, such as the following:

• Pretext Calling or Emailing – An identity thief may call or email the Company pretending to be an Investor and may even use bits of an Investor’s personal information (such as a Social Security Number) to maintain the deception. The information thief seeks to convince an Employee to provide additional information over the phone or by email, which can be used for fraudulent purposes. • Phishing – An identity thief or other criminal may attempt to acquire sensitive information such as usernames, passwords, bank account numbers or other information for malicious reasons by masquerading as a trustworthy entity in an electronic communication.

• Computer Hacking, Malware, or other Electronic Schemes – An identity thief may attempt to hack into computer systems, servers or files, or use of malware or other malicious electronic software or code to access the Company’s computers, networks, or email servers or other electronic records and obtain Investor personal information (or other confidential or proprietary information).

• Dumpster Diving or Data Theft – An identity thief may attempt to retrieve Investor’s personal information (or other confidential or proprietary information) from discarded documents or electronic records.

• Shoulder Surfing – An identity thief may attempt to retrieve an Investor’s personal information (or other confidential or proprietary information) by viewing information from an Employee’s computer screen or casually viewing materials an Employee is reading or using in a public location (e.g., an airplane).

• Unauthorized Access on Company Premises – An identity thief may pose as a cleaning crew member or other service provider and obtain to gain access to Investor personal information (or other confidential or proprietary information) while working in or visiting the Company’s offices.

All Employees should be aware of how their actions may expose Investors to the dangers of identity theft and must abide by the following procedures to protect non-public personal information and other confidential and proprietary information.

Implementation

The Company is committed to (i) safekeeping personal information collected from potential, current and former Clients and Investors and (ii) safeguarding against the unauthorized acquisition or use of unencrypted data or encrypted electronic data regarding each Client and Investor. The proper handling of personal information is one of the Company’s highest priorities.

To this end, the CCO has been designated to implement, maintain, review and revise, as necessary, a comprehensive information security program. The primary objectives for the CCO are to identify and assess any and all reasonably foreseeable internal and external risks to the security, confidentiality and/or integrity of any electronic, paper or other records containing personal information, and to evaluate and improve, where necessary, the effectiveness of current safeguards for limiting such risks. To this end, the Company

Employs ongoing Employee training;

• Sets policy for Employees relating to the storage, access and transportation of Client records and personal information;

• Reviews the scope of security measures at least annually;

• Reasonably monitors its information systems, including for unauthorized use or access; and

• Reasonably reviews and tests electronic encryption and other elements of its computer security system (including its secure user authentication protocols, secure access control measures and system security agent software).

The CCO reviews contractual relationships with key third party service providers engaged by the Company to ensure adequate protections are in place with respect to the safeguarding of personal information.

Client & Investor Information

The Company collects and keeps only such information that is necessary for it to provide the services requested by its Clients and Investors and to administer Client and Fund business with the Company. For instance, the Company may collect nonpublic personal information (such as name, address, social security number, assets, income, net worth, copies of financial documents and other information deemed necessary to evaluate the Client’s financial needs or an Investor’s eligibility) from SMA Clients and Fund Investors when they complete a subscription or other agreement. The Company may also collect nonpublic personal information from Clients or Investors or potential Clients or Investors as a result of transactions with the Company, its affiliates, its Clients, Investors or others (such information to include information received from outside vendors to complete transactions or to effect financial goals).

Sharing Information

The Company only shares the nonpublic personal information of its Clients or Investors with unaffiliated entities or individuals (i) as permitted by law and as required to provide services to the Company’s Clients or Investors, such as with representatives within our firm, securities clearing firms, insurance companies and other services providers of the Company, or (ii) to comply with legal or regulatory requirements. The Company may also disclose nonpublic personal information to another financial services provider in connection with the transfer of an account to such financial services provider. Further, in the normal course of business, the Company may disclose information it collects about Clients or Investors to entities or individuals that contract with the Company to perform servicing functions such as recordkeeping or computer-related services. Finally, the Company may make good faith disclosure of the nonpublic personal information of its Clients or Investors to regulators who have regulatory authority over the Company.

Companies hired to provide support services to the Company are not allowed to use personal information for their own purposes and are contractually obligated to maintain strict confidentiality. When the Company provides personal information to service providers, it requires these providers to agree to safeguard such information, to use the information only for the intended purpose and to abide by applicable law.

The Company does not (x) provide personally identifiable information to mailing list vendors or solicitors for any purpose or (y) sell information relating to its Clients or Investors to any outside third parties.

Employee Access to Information

Only Employees with a valid business reason have access to Clients’ or Investors’ personal information. These Employees are educated on the importance of maintaining the confidentiality and security of such information and are required to abide by the Company’s information handling practices. The Company employs reasonable procedures to prevent terminated Employees from accessing records containing personal information.

Protection of Information

The Company maintains security standards to protect Clients’ and Investors’ information, whether written, spoken, or electronic. To that end, the Company restricts access to nonpublic personal information to Company personnel who need to know such information in order to provide services to Clients and Investors. All electronic or computer files containing such information is password secured and firewall protected from access by unauthorized persons. The Company periodically updates and checks its systems to ensure the protection and integrity of information.

The Company also maintains reasonable restrictions upon physical access to records containing personal information and stores such records in secure facilities.

Maintaining Accurate Information

The Company’s goal is to maintain accurate, up to date Client and Investor records in accordance with industry standards. The Company has procedures in place to keep information current and complete (including the timely correction of inaccurate information).

E-Mail

Should a Client or Investor send the Company a question or comment via e-mail, the Company will share the Client’s or Investor’s correspondence only with those Employees or agents most capable of addressing the Client’s or Investor’s question or concern. All written communications pertaining to such question or comment will be retained by the Company until such time as the Company believes (in its good faith judgment) that it has provided the Client or Investor with a complete and satisfactory response. After that time, the Company may archive it according to the requirements of applicable securities laws.

Please note that, unless expressly advised otherwise, the Company’s e-mail facilities do not provide means for completely secure and private communications. Although every attempt will be made to keep Client and Investor information confidential, from a technical standpoint, there is still a risk. For that reason, Employees should not e-mail to communicate information to the Company that is considered to be confidential. If the Client or Investor wishes, communications with the Company may be conducted via telephone or by facsimile.

Disclosure of Privacy Policy

The Company recognizes and respects the privacy concerns of its potential, current and former Clients and Investors. The Company is committed to safeguarding this information. As a member of the financial services industry, the Company provides its Privacy Notice (included in Fund subscription documents) for informational purposes to Clients, Investors, and Employees and will distribute and update it as required by law. The Privacy Policy is also available upon request.

Violations

Employees are strictly prohibited from accessing, sharing, selling or otherwise utilizing non-public personal information, confidential or other proprietary information for any fraudulent purposes. The Company imposes reasonable disciplinary measures, which may include termination, for violations of its Privacy Policy.