CastleArk Management, L.L.C. was founded in 1999 and is an independent, employee-owned investment manager for institutions, investment companies, pooled investment vehicles, other advisers and high net worth individual clients, with an emphasis on equity growth strategies. CastleArk Alternatives, LLC which has been in existence since 2005, sponsors and manages unregistered private (alternative investment) funds. Jerome Castellini, co-founder of CastleArk Management, owns controlling interests in both advisory firms. 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. 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. For most of our clients, we manage a specific equity investment strategy (i.e. Large Cap Growth, Mid Cap Growth, Small and SMID Cap Growth, International Small Cap Growth) to complement a client’s existing investment portfolio lineup. We also provide a more diversified All Cap portfolio to meet a client’s broader investment objectives. The scope and type of the investment management service, including any corresponding investment restrictions or unique circumstances, are set forth in writing and made a part of the investment management agreement with our client. CastleArk 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 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 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 specialized 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 CastleArk 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 in minor differences from time to time among client accounts in the same strategy. See below. Specialized energy strategies CastleArk manages strategies that invest primarily in the energy sector. The energy strategies invest in US and non-US energy stocks, and one specializes in limited partnerships. Our Energy MLP strategy seeks to provide a high level of total return with an emphasis on cash distributions. It seeks to achieve its objective by investing primarily in Master Limited Partnerships (MLPs) in the energy sector. These investments predominantly derive their revenues from the businesses of exploring, developing, producing, gathering, transporting, processing, storing, refining, distributing, mining or marketing of natural gas, natural gas liquids, crude oil, refined petroleum products or coal. 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 Items 6 and 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 an 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 written notice in advance to the other party. CastleArk permits customization of an account’s guidelines to meet the particular needs of a client, as long as we believe 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 sub-advisory 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 sub-advisory 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. Wrap fee accounts sponsored by others CastleArk provides some portfolio management services under a "wrap fee" arrangement offered by an unaffiliated broker-dealer Sponsor. We invest the Wrap Program accounts using the same base model portfolio used for non-Wrap Program accounts. Clients in the program pay a single, all inclusive (or “wrap”) fee charged by the Sponsor based on the value of the client’s account assets for asset management, trade execution, custody, performance monitoring and reporting through the Sponsor. The Sponsor typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment advisers to manage the client’s account, and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or investment objectives that warrant a change in the management of the client’s assets. The sponsor recommends us as an investment adviser for the strategy, pays our management fee on behalf of the client, and monitors and evaluates our performance. CastleArk Management’s investment advisory fee under the arrangement is likely to be different from that offered to our other clients. Trades are generally expected to be executed only with the broker-dealer with whom the client has entered into the wrap fee arrangement, so we will not be free to seek best price and execution by placing transactions with other brokers and dealers. The minimum account size under the “wrap fee” arrangement is generally lower than the minimum size we accept for other clients. CastleArk will not have access to complete information regarding the Wrap Program client’s financial circumstances, investment objectives or overall investment portfolio. In addition, we receive information about the client at a later time than the Sponsor. As a result, any determination by CastleArk as to the appropriateness or suitability for a Wrap Program client of a particular investment will be made without regard to any other portion of the client’s portfolio, none of which is managed by CastleArk, and such determinations may be different than would have been the case had we had access to more complete information about the client’s financial circumstance, investment objectives and overall investment portfolio. 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, the client account usually holds the same investments as other client accounts in the same strategy, except for any holding that is restricted for that 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, 2022, for CastleArk Management were approximately $2.78 billion, and for CastleArk Alternatives, were approximately $16 million.