A. General Description of Advisory Firm. Ghisallo is an investment advisory firm organized in March 2020 under the laws of the State of Delaware and it provides discretionary investment advisory services to clients that currently includes commingled funds and other vehicles (collectively, the “Clients”). Ghisallo is controlled by Mr. Michael Germino. B. Description of Advisory Services. Ghisallo either currently does or expects to manage assets for various clients, including, but not limited to, the following commingled funds and other vehicles: 1
• Ghisallo Master Fund LP, a Cayman Island exempted limited partnership (“Master Fund”), Ghisallo Partners LP, a Delaware limited partnership (the “Onshore Feeder”), and Ghisallo International Fund Ltd (the “Offshore Feeder”), a Cayman Islands exempted limited company; and
• Ghisallo Credit Opportunity Master Fund LP, a Cayman Island exempted limited partnership (the “Credit Master Fund”), Ghisallo Credit Opportunity Partners LP, a Delaware limited partnership (the “Onshore Credit Feeder”), and Ghisallo Credit Opportunity International Partners LP (the “Offshore Credit Feeder” and together with the Credit Master Fund the Onshore Credit Feeder, the “Credit Funds”), a Cayman Islands exempted limited partnership (together with the Master Fund, Onshore Feeder, and Offshore Feeder, the Credit Master Fund, and the Onshore Credit Feeder, each a “Fund” and collectively, the “Funds” or the “Fund Group”). Ghisallo Credit Opportunity Capital Management LLC (the “Credit IM”) is a relying adviser of the Investment Manager and the investment manager of the Credit Master Fund. References to "Ghisallo” herein shall mean the Investment Manager, the Credit IM, and/or their affiliates in each case as applicable. Ghisallo Master Fund General Partner LP (“General Partner”) is the general partner of Ghisallo Partners LP and Ghisallo Master Fund LP. Ghisallo Credit Opportunity Fund General Partner LP (the “General Partner”) is the general partner of Ghisallo Credit Opportunity Partners LP, Ghisallo Credit Opportunity International Partners LP, and Ghisallo Credit Opportunity Master Fund LP. Ghisallo (and together with the General Partner, the Credit General Partner, and their respective affiliates including those described below, collectively the “Ghisallo Group”), in addition to investment management, provides certain administrative services to Clients. 1 In addition to its current and future commingled structures, Ghisallo may in the future, manage or sub-advise separate dedicated bespoke vehicles, single trading subsidiaries and/or managed accounts. Ghisallo currently applies a multidisciplinary approach to investing and may pursue multiple investment strategies including, without limitation: multi-asset global macro; long/short equities; investing in commodity and commodity-related industries; high yield, credit and distressed credit; event-driven/special situations investing; and relative value investing. The Master Fund’s investment objective is to achieve superior risk-adjusted returns through event driven and credit investing that aims to take advantage of dislocations, inefficiencies, and liquidity events in the market. Ghisallo will seek to retain flexibility in executing the investment strategy through investing across asset classes, geographies, and instruments. The Credit Master Fund seeks to generate asymmetric returns by investing capital primarily in structured credit, fixed income securities, loan instruments, and derivatives, throughout the capital structure and at a variety of leverage points. In addition to directional investing in structured credit and fixed income, the Fund Group may pursue, other strategies, capital structure arbitrage, as well as short-term trading opportunities. Some Client portfolios will also include global macro-overlays

opportunistically, as applicable, and will attempt to identify opportunities regardless of market direction. In some cases, there are no limitations on the markets or types of instruments in which Ghisallo may pursue investments. Ghisallo, in its discretion, utilizes the services of third parties (including, Key Square Capital Management LLC (the “Service Provider”)) to provide certain non-binding research (i.e., it has no authority to bind the Fund Group (as defined below) or make investment decisions), trade execution, accounting and operational and infrastructure support services to Ghisallo. Please see Item 10 (Other Financial Industry Activities and Affiliations) below for additional information associated with the Service Provider. Ghisallo’s investment strategies are more fully described in the offering documents for each Fund and will be available in the offering documents or agreements for any other current or future Client. Please see Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) below for a more detailed description of the investment strategies pursued and types of investments made by Ghisallo. The descriptions set forth in this Brochure of specific advisory services that Ghisallo offers to Clients, and investment strategies pursued and investments made by Ghisallo on behalf of its Clients, should not be understood to limit in any way Ghisallo’s investment activities. Ghisallo may offer any advisory services, engage in any investment strategy and make any investment, even if not described in this Brochure, that Ghisallo considers appropriate, subject to each Client’s investment objectives and guidelines. Not all of the strategies described in this Brochure may be used at the same time or in the same proportions, and Ghisallo may add, suspend, eliminate or modify investment strategies at its discretion. The investment strategies Ghisallo pursues are speculative and entail substantial risks. Investors should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. C. Availability of Tailored Services for Clients. As mentioned above, Ghisallo’s investment advice is subject to investment objective and guidelines of each Client, as set forth in the offering documents and/or constituent documents of such Client, as applicable. With respect to the Funds, Ghisallo’s advice is not subject to modification by investors, other than certain investors who currently have and may in the future have more favorable rights not afforded to other investors such as (i) greater information than may be provided to other investors, including greater transparency into a Client’s portfolio; (ii) different liquidity rights; (iii) different fee and/or allocation terms; (iv) different transfer rights; (v) risk, tax or other reporting and/or (vi) different portfolios. The terms of Clients (other than the Funds) in some cases, currently are, or may in the future be, individually negotiated and provide better terms than those offered to investors in the Funds, including, but not limited to, lower management and performance-based compensation, different liquidity, leverage, expenses, loss carry forward, high water mark, liability, indemnity, risk and/or compliance restrictions, tax reporting, co-investment, most favored nation and information rights (including better transparency with respect to the holdings of each Client) relative to other investors. Some Clients (including the Service Provider’s clients) have overlapping strategies to other Clients and some do not and may not in the future. D. Wrap Fee Programs. Ghisallo does not participate in wrap fee arrangements. E. Assets under Management. As of December 31, 20232, Ghisallo had approximately $3.4 billion in assets under management.