Page 4 A. Ownership/Advisory History 1128 Capital, LLC (“1128 Capital” or the “firm”) is a Delaware limited liability company. The firm was formed in January 2022 and is owned by 1128 Capital Holdings LLC. Vincent Spreuwenberg is Managing Member and CCO of 1128 Capital, and Sharon Koh is a Member and CEO of 1128 Capital. B. Advisory Services Offered Sub-Advisory Services 1128 Capital provides management services, either directly or as a sub-adviser, to insurance companies and institutional accounts. 1128 Capital acts as a sub-advisor to other investment managers and their respective clients, and may select and retain sub-advisors which provide 1128 Capital’s clients with exposure to various investment strategies. The primary strategies that 1128 Capital utilize or may in the future utilize on behalf of 1128 Capital’s investors are identified below (each, a “Strategy”): ▪ Direct Commercial Real Estate Loans ▪ High Yield Debt: including primarily non-investment grade USD-denominated corporate debt ▪ Equity-Based Real Estate Financing ▪ Investments in other pools which invest in similar strategies ▪ Client-imposed strategies/securities 1128 Capital provides investment management services (i) to an insurance company, (ii) as sub- advisor to a registered investment advisor managing investments on behalf of four insurance companies and intends to provide similar services, directly and indirectly, to other insurance companies and institutional clients in the future and (iii) through sub-advisors which are retained in consultation with and approval of 1128 Capital’s clients. 1128 Capital only manages assets which are the subject of its management and sub-advisory agreements, and does not consider the client's other assets and other obligations (subject to “Additional Services” described below). 1128 Capital receives authority to supervise and direct the investment of the assets on a discretionary basis in accordance with the client’s written objectives and limitations as outlined in each individual client’s Investment Management Agreement or Sub-Advisory Agreement, as applicable, and may, in the future, supervise and direct the investment of assets on a non-discretionary basis. Clients may impose restrictions or limitations on investing in specific securities, specific types of securities, or specific strategies. Additionally, 1128 Capital may provide investment management services utilizing strategies and asset types outside of the two primary Strategies described herein to the extent consistent with an individual client’s Investment Management Agreement or Sub-Advisory Agreement, as applicable. Page 5 Direct Commercial Real Estate Loans The small to mid-tier commercial real estate loan market is both inefficient and fragmented creating quality loan opportunities that can be captured through 1128 Capital and its sub- advisors’

dynamic underwriting and origination processes. Relationships, expertise, and knowledge allow 1128 Capital and its sub-advisors to source, underwrite, and structure loan opportunities with favorable yields and acceptable risk. 1128 Capital and its sub-advisor(s) focus on making loans secured by well-positioned properties with appropriate risk-return profiles. Investment Grade Debt 1128 Capital and its sub-advisors seek to generate attractive risk-adjusted returns for 1128 Capital’s clients by investing in a combination of domestic and international fixed income bonds. The portfolio will invest across various fixed income asset classes including Treasury Bonds, Agency MBS, Non-Agency MBS (high grade), Senior Secured Bank Debt and Investment Grade Bonds. The objective is to produce returns that exhibit low correlations to the broad markets through disciplined credit selection and active portfolio management. 1128 Capital may employ consultants (as well as sub-advisors) in connection with its management in these asset classes. High Yield Debt 1128 Capital and its sub-advisors plan to invest on behalf of 1128 Capital’s clients in bonds, loans, or other debt instruments, which are rated Ba or lower by Moody’s or BB or lower by S&P or are unrated but determined to be of comparable quality. Below investment grade debt securities have higher yields but generally involve greater risk of loss, are subject to greater price volatility and are less liquid, especially during periods of economic distress, than higher rated debt securities. Fixed-income securities may have fixed or variable principal payments and all types of interest rate and dividend payment and reset terms, including fixed rate, adjustable rate, zero coupon, contingent, deferred, payment in kind and auction rate features. Equity-Based Real Estate Financing The firm may recommend investments in certain public or privately traded real estate investment trusts and/or private equity real estate funds. The firm conducts due diligence on such investment trusts and funds that meet the client’s investment goals and objectives. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment mandate and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs 1128 Capital does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) Page 6 E. Client Assets Under Management As of December 31, 2023, the firm had $151,776,405 in discretionary assets under management and $0 in non-discretionary assets under management. Item 5: Fees and Compensation