Integral ILS Ltd. (“Integral” or the “Adviser”) is an investment management firm incorporated on September 26, 2019 as a Bermuda exempted company. Integral specializes in providing investment adviser services to funds that invest primarily in property catastrophe insurance and reinsurance risk-linked instruments (“RLI”). Integral’s co-founders and Managing Partners are Lixin Zeng and Richard Lowther, who together own a controlling interest in common voting shares of Integral. Lixin Zeng is also the Chief Executive Officer (“CEO”) and Investment Officer (“CIO”) and Richard Lowther is the Chief Operating Officer (“COO”) and Chief Compliance Officer (“CCO”) of Integral. Further information on the ownership structure is available in Schedule A and B of Part 1 of Form ADV, publicly available on the SEC’s website at: www.adviserinfo.sec.gov. Integral provides investment advisory services to privately offered Bermuda domiciled fund companies (the “Funds”), and institutional investors and sub-advisory services to funds located in other jurisdictions. Our investment advisory services specialize in gaining risk exposure to private market property catastrophe risks through the purchase of profit participation notes (“Notes”) issued by, Integral Reinsurance Ltd. (“Integral Re”), a Bermuda exempted company established in June 2020 and registered as a Special Purpose Insurer under the Bermuda Insurance Act 1978 and related regulations and investments in Catastrophe Bonds, as defined below. Integral Re provides risk transformation services to the Funds is wholly owned by Integral Managers, Ltd., a holding company owned and controlled by Richard Lowther. The proceeds of investments by the Funds in the Notes issued by Integral Re are used as security to fully collateralize RLI transactions, predominantly in the form of private market property insurance, reinsurance and retrocession transactions selected by Integral which cover natural catastrophes and other insurance events. While the RLI investments sourced by Integral are predominantly in the form of investments in private market property catastrophe insurance, reinsurance and retrocessional transactions, other RLI may include, but not be limited to, the following types of investments:
• Catastrophe bonds (“Cat Bonds” 1: principal-at-risk variable rate notes and other risk-linked securities, and;
• Industry loss warranties (“ILW”): indemnity-based and non-indemnity-based, binary reinsurance or derivative contracts triggered by industry-wide insurance losses,

and;
• Exchange or over-the counter risk-linked derivatives or futures and other securities or investments the return of which is predominantly linked to the performance of the underlying insurance or reinsurance transactions. Each Fund or Client account is open for investment solely to prospective investors who are: (i) non- U.S. Persons or (ii) U.S. Persons who are both “qualified purchasers,” as defined in the U.S. Investment Company Act of 1940, as amended (the “U.S. Investment Company Act”) and 1 Please note that Cat Bonds are generally issued under Rule 144A of the U.S. Securities Act of 1933, such 144A securities may only be purchased by clients/investors who are “qualified institutional buyers” (“QIB”). QIBs must in the aggregate own and invest on a discretionary basis at least $100 million in securities of issuers that are not affiliated with such a qualified institutional buyer. Certain risks associated with Cat Bonds are discussed in Item 8, below. “accredited investors,” as defined in Regulation D under the U.S. Securities Act of 1933, as amended (the “U.S. Securities Act”). In addition, each Subscriber must be a “qualified participant” within the meaning of The Investment Funds Act 2006 of Bermuda. The Funds will conduct trading activity pursuant to the investment strategies described generally below. Funds may be organized and offered for private investors or may be customized for single investors or groups of investors as agreed with Integral. Integral does not tailor its advisory services to the individual needs of Investors (although Integral’s advisory services are tailored to meet the investment mandates of the Funds, as described in the Funds’ offering documents) or pursuant to an investment management agreement in the case of sub advised Funds. The Funds may enter into side letter agreements with certain Investors. Such agreements may provide such Investors with most favored nation (“MFN”) status; including reduced fees, capacity rights, additional transparency and reporting, among others that vary from those described in the Funds’ offering documents. The Funds generally enter into side letters only with Investors who make substantial commitments of capital. Integral does not participate in wrap fee programs. Integral has approximately $2.6 billion in regulatory assets under management on behalf of non- US based clients, as of January 1, 2024, for the private funds and for the sub advised fund. Regulatory Assets Under Management are calculated in the same manner as in Part 1 of Form ADV, for private funds using the Gross Asset Value of each Fund plus uncalled but legally committed capital.