A. Firm Description. Polar Capital (America) Corporation (“Polar America”) is an investment management firm located in Darien, Connecticut. The firm is a corporation formed under the laws of Delaware. It is a subsidiary of Polar Capital US Holdings Limited, a subsidiary of Polar Capital Holdings PLC, a public company whose shares are listed on the London Stock Exchange “Polar Holdings”). Approximately eighteen percent of the equity interests of Polar Holdings is held by or reserved for directors, management and employees of Polar Holdings and its subsidiary companies, including Polar America. Polar America is regulated by the U.S. Securities and Exchange Commission. Polar America was established in 2010 and has been registered as an investment adviser with the Securities and Exchange Commission under the Investment Advisers Act of 1940 (“Advisers Act”) since October 19, 2010. An affiliate, Polar Capital LLP in London, England (“Polar Capital”), is also registered with the SEC as an investment adviser. Polar Capital provides support services to Polar America. See Item 10. Other affiliates include Phaeacian Partners LLC in El Segundo (“Phaeacian Partners”); a registered SEC investment adviser (inactive). B. Advisory Services. Polar America offers fundamental research driven investment advisory services. Polar America serves as a sub-adviser to Polar Capital, as the investment manager to the Polar Capital Funds Plc – Global Convertible Fund and Polar Capital Funds Plc – Global Absolute Return Fund (the “Served Polar Funds”). Polar Capital offers fundamental research driven investment advisory services to professional and institutional investors through a range of geographic and sector investment funds which it offers and manages (“Polar Funds”) and managed accounts. Polar Funds are organized in jurisdictions outside the United States and are not registered as investment companies under the Investment Company Act of 1940. However interests in certain of the Polar Funds are offered to certain pre-qualified U.S. persons who must be “Qualified Purchasers” as defined by Section 2(a)(51) of the Investment Company Act. Such offerings are made only in private placements pursuant to exemptions under the Investment Company Act and the Securities Act of 1933. Each Polar Fund itself is a Qualified Purchaser. This Brochure describes only the investment

advisory services that Polar America provides to Polar Capital for the Served Polar Funds. At any point in time interests in the Served Polar Funds may be offered to existing and new investors in the U.S. who are Qualified Purchasers. As sub-adviser, Polar America provides investment supervisory services to the Served Polar Funds, which is considered a “Hedge Fund,” as described more fully below. Hedge Fund. An alternative investment vehicle only available to sophisticated investors such as institutions and individuals with significant assets that is designed to protect investment portfolios from market uncertainty, while seeking positive returns in both up and down markets. Open End Investment Companies - (OEIC) A type of company that allows investors to collectively pool together money to invest in various opportunities. As money is invested, shares are created. When a shareholder requests to sell shares, that money is then redeemed. The value of a share varies with the value of the OEIC's net portfolio value (NPV). It is most often used in the United Kingdom. In the United States it is referred to as an open-ended mutual fund. Polar Capital Funds plc. An umbrella fund company with variable capital and segregated liability between funds, incorporated with limited liability under the laws of Ireland with registered number 348391, and authorized in Ireland as an investment company pursuant to the European Community’s Undertakings for Collective Investment in Transferable Securities, or UCITS, Regulations. The company is structured as an umbrella fund consists of a number of different funds, each fund representing a single portfolio of assets, with segregated liability between funds. Each fund may have more than one share class allocated to it. The funds are: Global Convertible Fund. Investment objective/strategy: to generate positive returns with low volatility through a variety of investment and trading strategies, primarily in the global convertible market. Global Absolute Return Fund. Investment objective/strategy: to deliver capital growth over rolling 12-month periods, in all market conditions. There is no guarantee the Fund will achieve this objective over any given period. C. Assets under Management. Polar America’s assets under management on a discretionary basis as of March 31, 2023 are U.S.$ 706,350,618.