CastleArk Management, L.L.C. is an independent, employee-owned investment manager to institutional clients, with an emphasis on equity growth strategies. CastleArk was founded in 1999 by Jerome Castellini and his co-founder. Castellini is principal owner, president and Chief Investment Officer of the company. The company’s executive committee includes Castellini, CEO Kevin Dolsen and other senior officers. Castellini also owns the majority interest in CastleArk Alternatives, LLC , which has been in existence since 2005 and is adviser or general partner to unregistered private (alternative investment) funds it sponsors. CastleArk Management and CastleArk Alternatives are separate and distinct companies that may have differing investment goals, capabilities and functions. The companies generally have the same policies and procedures and share senior management teams. Unless otherwise noted or the context otherwise requires, this brochure describes common policies and procedures of the companies. Throughout this brochure, unless the context otherwise implies, the use of the term “CastleArk” alone is generally in reference to practices of both companies. CastleArk offers investment management services in a several investment strategies for which we have portfolio managers with an established investment style that our clients have sought. Our clients include private and government investment funds and institutions, a large proportion of which are retirement plans Our clients are generally sophisticated investors and often have internal and external consultants and advisers to assist them with determinations of their individual needs, such as allocations among types of investments, and generally do not seek those determinations from us. Investment strategies overview CastleArk provides investment advisory services to institutional separately managed accounts, registered funds and collective trusts by implementing strategies that are designed to generate superior returns over time. The goal of all of our investment strategies is to out-perform market benchmark returns over time. We manage portfolios and offer investment advisory services to institutional investors, for U.S. and non-U.S. equity strategies. CastleArk manages diversified growth investment styles and also energy sector and energy sub-sector strategies. Diversified growth equity strategies include U.S. large cap, mid cap, smid cap and small cap growth and international small cap growth, plus a U.S. all cap growth strategy that employs all of our U.S. growth strategies. CastleArk also manages separate energy sector strategies. Finally, we manage fixed income portfolios with a core bond strategy, plus a balanced strategy, which combines U.S. growth equity and core bond strategies. All of CastleArk’s investment strategies are based upon time-tested processes for constructing portfolios. Our portfolio management teams use criteria which have been developed in-house, along with fundamental research, including research provided by third parties, to build and maintain the investment strategies we provide. Within each investment strategy, all client accounts are managed in accordance with CastleArk’s model portfolio for the strategy. We do, however, adhere to restrictions a client may impose on the holding of certain securities, which can result minor differences from time to time among client accounts in the same strategy. See below. 3 CASTLEARK MANAGEMENT, LLC Asset allocation CastleArk may provide asset allocation services. For selected clients, CastleArk may advise as to the appropriate allocation of their assets among equity securities strategies or other asset classes. From time to time CastleArk may recommend to a separately-managed account client that it invest in a private fund sponsored by CastleArk Alternatives. Any such recommendation could carry the risk of a conflict of interests. See below at Item 11 for our approach to monitor and mitigate such conflicts. Alternative investment strategies CastleArk Alternatives provides investment advisory services to alternative investment funds that are exempted from registration as investment companies under section 3(c)(7) of the Investment Company Act of 1940, as amended. Fund strategies include a global energy

strategy and a volatility strategy. Separately managed account services CastleArk Management generally provides its services on a fully discretionary basis to separately managed accounts. Services are provided under the terms of an advisory agreement between CastleArk and the client. The advisory agreement generally permits either the client or CastleArk to terminate the arrangement at any time after advance written notice to the other party. Typically, separately managed account clients establish their own investment guidelines and restrictions for their accounts, and those guidelines are usually compaitible with our own guidelines, which we apply to all accounts in a strategy, by default. We may agree with certain clients on investment guidelines that restrict the securities or types of securities that we invest in on their behalf. CastleArk permits customization of an account’s guidelines to meet the particular needs of a client, as long as we believes such customization will not significantly impair our ability to implement the strategy. Funds In addition to the separately managed account services, CastleArk Management provides advisory or subadvisory services to mutual funds. Information about these funds, including a description of the services provided and advisory fees, is generally contained in each fund’s prospectus. CastleArk also provides advisory or subadvisory services to other investment funds such as collective investment trusts and other types of pooled vehicles. Additional information concerning these funds is generally included in the relevant offering documents. Model portfolio A model portfolio may be provided by CastleArk to a select number of clients without exercising investment discretion or trading the accounts. For those clients, no amount of assets under management is included as part of our discretionary assets under management. Wrap fee accounts sponsored by others We indirectly receive a share of the fees charged to clients of Wrap Accounts, and we may benefit from the marketing, and client screening services of the Wrap Account Sponsor. 4 CASTLEARK MANAGEMENT, LLC Investment restrictions CastleArk generally provides investment management services in accordance with applicable investment guidelines and restrictions, including restrictions on investing in certain securities, or types of securities or other financial instruments. CastleArk uses both automated and manual processes to manage portfolios in accordance with their stated portfolio investment guidelines and restrictions. CastleArk can normally accommodate reasonable requests by clients to restrict their accounts from owning investments that the client account is not permitted to own or that they wish not to own. In those cases, a particular client account usually holds the same investments as other client accounts in the same strategy, except for any holding that is restricted for that particular client. For any account that is affected by a client restriction, CastleArk cannot necessarily achieve the same performance as that of unrestricted accounts for the same strategy. Nevertheless, we seek to maximize returns for all client accounts, including accounts with restrictions. Services between affiliated advisers CastleArk Alternatives may use the services of appropriate personnel of CastleArk Management for investment advice, portfolio execution and trading, and client servicing. Arrangements between CastleArk Management and its affiliate may take a variety of forms, including delegation agreements or informal servicing arrangements. This practice is designed to make CastleArk’s capabilities available to clients of its affiliate as efficiently as possible. In these circumstances, CastleArk Alternatives remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliate’s services. Assets under management CastleArk Management and CastleArk Alternatives only manage client portfolios on a discretionary basis. Assets under management, as of December 31, 2018, for CastleArk Management were approximately $2.87 billion, and for CastleArk Alternatives, were approximately $136 million.