GAMS, has been in business since 2006 and offers portfolio management services to its clients on a discretionary basis, based upon the individual needs and objectives of each client. GAMS is a UK- based firm and a direct subsidiary of GAM (UK) Limited, which in turn is a direct subsidiary of GAM (Switzerland) Holding AG. The firm is ultimately owned by GAM Holding AG, an independent asset management firm that is headquartered in Zurich, Switzerland, and whose shares are listed on the SIX Swiss Exchange. GAMS is authorized and regulated by the UK Financial Conduct Authority (“FCA”) in addition to being a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”) and a registered Commodity Pool Operator (“CPO”) and Commodity Trading Adviser (“CTA”) with the U.S. Commodity Futures Trading Commission (“CFTC”) under the U.S. Commodity Exchange Act (“CEA”). GAMS is also a member of the U.S. National Futures Association (“NFA”). As of December 30, 2024, GAMS’s regulatory assets under management were approximately $2 billion. All the assets are managed on a discretionary basis. GAMS offers various investment products and services through managed account and investment fund structures, including private funds that operate pursuant to an exemption from registration as an investment company under the Investment Company Act of 1940, as amended (the “Investment Company Act”), and are offered to U.S. and non-U.S. investors in private placements pursuant to Regulation D or Regulation S (as applicable) under the Securities Act of 1933, as amended (the “Securities Act”). GAMS does not provide financial planning services. Additionally, GAMS may serve as manager, adviser or sub- adviser to other investment funds, including European regulated commingled funds (referred to as “UCITS”) and U.S. investment companies registered under the Investment Company Act (“Registered Investment Company/ies”).

GAMS’s investment team pursues its own individual approach and preferred investment style so that it has the flexibility in its efforts to implement its talents to the greatest effect, but within the wider risk control framework provided by the GAM group. Institutional Accounts GAMS offers institutional investors the flexibility of investing through individually customized managed accounts (including sub-advisory relationships, as described above) or dedicated single investor private funds, or non-U.S. domiciled commingled funds designed for multiple investors that are managed by GAMS (these commingled funds are referred to as the “GAMS Funds”). In instances where GAMS advises separately managed accounts and pooled investment vehicles (“GAMS Accounts”), whose investment management has been delegated to GAMS, the firm may invest:
• in other GAMS Funds managed by GAM;
• in other pooled investment vehicles, including GAMS Funds managed by affiliates of GAMS in the GAM group of companies (the “GAM Group”) and/or funds managed by other unrelated asset managers;
• in separate non-U.S. investment vehicles established or formed by an affiliate of GAMS and typically managed by Portfolio Managers (as defined below), which are generally only available to investment advisory clients of a member of the GAM Group;
• with Portfolio Managers (as defined below) via one or more fund of funds commingled managed account platforms; or
• directly in securities, commodities, currencies, derivatives and other financial instruments. In relation to U.S. domiciled funds, GAMS may act as sub-adviser to GAM USA Inc., a U.S. based SEC-registered investment adviser and an affiliate of GAMS. Where a client is invested in a separately managed account or dedicated private fund, the client may impose restrictions on investing in certain securities or types of securities. This is not possible where an investor chooses to invest in a GAMS Fund.