GIML has been in business since 1984 and offers portfolio management services to its clients on a discretionary basis, based upon the individual needs and objectives of each client. 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. GIML is authorized and regulated by the UK Financial Conduct Authority in addition to being a registered investment adviser with the 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 CFTC under the Commodity Exchange Act. As of December 31, 2021, GIML’s assets under management were approximately USD 14.2 billion. All the assets are managed on a discretionary basis. GIML offers various investment products and services through separately managed account and investment fund structures using both fund of funds and single-manager strategies. Fund of funds strategies involve allocating a client’s assets among a portfolio of funds and accounts managed by other investment managers, 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. clients and investors in private placements pursuant to Regulation D under the Securities Act of 1933, as amended (the “Securities Act”). Single-manager strategies involve investing a client’s assets directly in shares, bonds or other instruments in investment strategies as described below. GIML does not provide financial planning services. Each of GIML’s investment teams pursues their own individual approach and preferred investment style so that they have the flexibility to implement their talents to the greatest effect, but within the wider risk control framework provided by the GAM Group. Many of our third-party managers have been discovered by GAM group’s hedge funds research team as part of its due diligence process. These selective partnerships enable clients to gain access to many high-calibre, well-established managers who previously either have only been available via funds of funds, to institutional investors or only via offshore vehicles. Institutional Accounts GIML offers institutional investors the flexibility of investing through individually customized managed accounts or dedicated single investor private funds, or U.S. and non-U.S. domiciled commingled funds designed for multiple investors that are managed by GIML or one or more of its affiliates (these commingled funds are referred to as “GAM Funds”). For the purposes of convenience, the privately offered funds and other client accounts that GIML manages or advises are sometimes referred herein as “GAM Accounts.” GAM Accounts may invest:
• directly in securities, commodities, currencies, derivatives and other financial instruments.
• in other GAM Funds managed by GAM’s Alternative Investments Solutions team (“AIS”);
• in other pooled investment vehicles, including GAM Funds managed by affiliates of GIML in the GAM group of companies (the “GAM Group”) and/or funds

managed by other unrelated asset managers (“Portfolio Managers”);
• in separate non-U.S. investment vehicles established or formed by an affiliate of GIML and typically managed by Portfolio Managers, which are generally only available to investment advisory clients of a member of the Group; or
• with Portfolio Managers via one or more fund of funds commingled managed account platforms. In relation to U.S. domiciled funds, GIML may act as sub-adviser to GAM USA Inc., a U.S. based SEC- registered investment adviser and an affiliate of GIML. 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 GAM Fund. Single Manager Mandates GAM Funds and accounts may utilize a wide range of investment strategies, depending on the specialty of the individual fund manager. Prospective investors should refer to the governing materials for the relevant GAM Fund. GAM Funds are typically set up as British Virgin Islands or Cayman Islands incorporated companies, Ireland or Luxembourg based UCITS funds or U.S. domiciled funds. For some funds, GIML as investment adviser may delegate to a third-party manager who has specific expertise in that particular mandate or strategy, as detailed in the relevant governing materials for that GAM Fund. Fund of Funds Mandates The AIS research team uses quantitative and qualitative methods to identify what the team believes are the most promising Portfolio Managers for potential investment. The team analyses each Portfolio Manager’s investment approach to identify the source and repeatability of the Portfolio Manager’s performance. The size of a portfolio position is generally based upon the strength of the investment case and the Portfolio Manager’s expected return, risk and correlation objectives. AIS uses different risk management tools throughout the investment process in order to better understand the sources of risk and reward in a particular portfolio. Strategy-specific investment professionals dedicated to particular market segments and geographic sectors conduct the research. A separate team (the “Operational Due Diligence Team”) conducts initial operational due diligence and ongoing assessments of the key non-investment risks of the underlying Portfolio Managers and certain of the underlying funds’ key service providers. The Operational Due Diligence Team has the power to veto any underlying fund/Portfolio Manager selection decision about which it has operational concerns. The AIS investment process provides discipline and risk management, which can be summarized in five stages:
• Establish objectives and weights - portfolio objective and allocation guidelines;
• Identification of Talent - quantitative and qualitative analysis;
• Manager Evaluation - investment and operational due diligence, performance expectations;
• Portfolio Construction - portfolio modeling; and
• Risk Management - Portfolio Managers, portfolio and risk monitoring Some of the above functions are performed by employees of GIML affiliates located in New York and Zurich.