A. Description of Nephila Capital Ltd. Nephila Capital Ltd. (the “Adviser”), a Bermuda exempted company, is an investment manager specializing in catastrophe risk and weather risk investments for sophisticated institutional and high net worth clients. The Adviser was founded by Frank Majors and Greg Hagood in 1997 (under a predecessor name) as part of Willis Ltd, one of the world’s largest reinsurance brokers. The Adviser relocated to Bermuda in 1999 to establish a local presence in the world’s catastrophe reinsurance centre. The Adviser is registered with the SEC as an investment adviser. The Adviser’s principal owner is Markel Corporation (“Markel”) (through Nephila Holdings Ltd., (“Nephila Holdings”)). Previously, KKR Nevada Ventures LLC and Man Group Holdings Ltd. ("Man Holdings”) held minority passive interests in Nephila Holdings, the Adviser’s sole shareholder. On November 14, 2018, Markel purchased 100% of Nephila Holdings Ltd. from KKR Nevada Ventures LLC, Man Holdings and Nephila Partners, L.P. Markel is a holding company for insurance, reinsurance, and investment operations around the world and is a publicly traded company listed on the New York Stock Exchange (NYSE – MKL). B. Advisory Services Offered. The Adviser provides investment management services regarding catastrophe risk and weather risk strategies to its clients, which are organized as privately offered pooled investment vehicles open for investment by qualified institutional and high net worth investors. The Adviser currently acts as the sponsor and investment manager of offshore private investment funds (each, an “Offshore Feeder Fund”) and general partner and investment manager of U.S. private investment funds (each, an “Onshore Feeder Fund”). The Offshore Feeder Funds and the Onshore Feeder Funds invest through a wholly owned master trading vehicle whose investment manager also is the Adviser (each, a "Master Fund"). The Adviser also acts as sponsor and investment manager of stand-alone offshore private investment funds (the "Offshore Funds"). The Adviser also previously acted as sub-adviser to an open-end mutual fund registered with the SEC under the Investment Company Act of 1940, as amended, and a pooled investment vehicle authorized pursuant to the European Communities (Undertaking for Collective Investment in Transferable Securities) Regulations, 2011, as amended (collectively, the “Registered Funds”). The Offshore Feeder Funds, the Onshore Feeder Funds, the Master Funds, the Offshore Funds and the Registered Funds are referred to collectively as the “Funds” and individually, as a “Fund”, and such Funds also are referred to collectively as “Clients” or each, a “Client”. Each Fund is open for investment only by qualified institutional or high net worth investors that meet the suitability requirements set forth in the applicable Fund's subscription documents. Generally, the Onshore Feeder Funds are open only to qualified U.S. taxable investors and the Offshore Feeder Funds are open only to qualified non-U.S. investors and U.S. tax-exempt investors and will conduct trading activity pursuant to the investment strategies described generally below. Each Feeder Fund invests its assets into its respective Master Fund, with the Master Fund conducting all trading activity pursuant to the investment strategies described generally below. Funds may be organized and offered for private investors generally or may be customized for single investors or groups of investors as agreed with the Adviser. The catastrophe risk Funds pursue investment strategies that purchase or sell various types of securities and financial instruments, the return or performance of which are linked to catastrophic events and other property insurance risk. The weather risk Funds pursue investment strategies that purchase or sell weather-linked investment instruments, including weather derivatives and other financial instruments, the returns of which are tied primarily to weather risk. The Adviser expects that its advisory services will be limited to advice regarding the foregoing investment strategies and instruments, as generally described. The Funds engage in transactions that are typically structured as securities in the form of notes, as International Swap and Derivatives Association, Inc. (ISDA)-based over-the-counter

swaps or other derivatives contracts, or weather futures and options traded over-the-counter or on U.S. or non-U.S. futures exchanges. The primary differences between the Funds are the degree of leverage used, the extent of portfolio diversification, the nature and terms of specific portfolio investments, the Adviser's fees, and the investors' redemption or withdrawal rights. A Fund may be organized into one or more classes of shares or interests, each with its own terms and conditions. For a complete description of a Fund's investment objectives and strategies, as well as a description of the material terms of an investment in a Fund (including the risks of an investment and associated conflicts of interest), please refer to the relevant Fund's Confidential Offering Memorandum (the “Memorandum”). To facilitate its Clients’ access to the traditional reinsurance market, the Adviser has caused to organize Poseidon Re Ltd. (“Poseidon”), Ananke Re Ltd. (“Ananke”) and Nephila Syndicate Holdings Ltd. (“NSH”). To facilitate its Clients’ access to the weather market the Adviser has caused to organize Demeter Re Ltd. (“Demeter”). Together, Poseidon, Ananke, NSH and Demeter are the “Transformers”. Poseidon, Ananke and Demeter are licensed as Bermuda Class 3 reinsurance companies, and NSH is a Bermuda exempted company. The Adviser is the manager of Poseidon, Ananke, NSH and Demeter. The Adviser currently expects that all such reinsurance-related derivative and the weather derivative transactions for its Clients generally will be entered into with the Transformers as opposed to with a third-party transformer. The primary purpose of using the Transformers is to eliminate the “mark-up” that would otherwise be charged to Clients by a third- party transformer on the derivative transaction. It is currently expected that Poseidon, Ananke, NSH and Demeter will enter into derivative transactions only with the Adviser’s Clients, and not with third parties. The Transformers do not make a profit. The Adviser also acts as the insurance manager to a Bermuda incorporated reinsurance company, as further described in Item 7 below. C. Tailored Services. An offering to invest in a Fund can be made only by means of such Fund's Memorandum. As the investment manager and sponsor/general partner of each Fund, the Adviser makes decisions on how each Fund should allocate its assets to certain investments; selects brokers, dealers, banks and other counterparties or intermediaries by or through whom portfolio transactions will be executed or carried out; monitors each Fund's investments; and makes all other necessary or appropriate recommendations to carry out its portfolio management duties. Each of the Adviser’s Funds has different risk/return objectives with varying allocations to investment instruments, such as catastrophe bonds and other over-the-counter insurance-linked instruments. The Adviser may form and manage additional privately offered pooled investment vehicles in the future and, from time to time, may manage separately managed accounts of other qualified clients on a limited basis, although it is expected that such separate accounts will be organized in the form of single member limited liability entities whose manager is the Adviser (e.g., similar in structure to a privately offered pooled investment vehicle). For purposes of this Brochure, all of the foregoing additional funds and accounts shall also be referred to interchangeably herein as a “Fund” or a “Client”. Clients may impose restrictions on investing in certain securities or types of securities. D. Wrap Fee Programs. The Adviser does not participate in any wrap fee programs. Please refer to Item 5 – Fees and Compensation, below, for more information regarding the Adviser’s fees. E. Client Assets the Adviser Manages. The Adviser’s Client net assets under management as of December 31, 2023 were approximately U.S. $6,020,000,000 on a discretionary basis, and the Adviser manages no assets on a non-discretionary basis. The amount disclosed under this item is calculated based on net assets after deducting investments of one Fund in another Fund so as to avoid the double counting of net assets, which differs from the Adviser’s “regulatory assets under management” disclosed under Part 1 of Form ADV.