NCH Capital Inc. (“NCH” or the “Adviser”) is an investment management firm with its principal place of business in New York, New York. The Adviser commenced its business in 1993. The owners and co-founders of the Adviser are George Rohr and Moris Tabacinic (the “Principals”). NCH registered as an investment adviser with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) in November 2011. The Adviser also meets the requirements to be considered a Qualified Professional Asset Manager (“QPAM”) under applicable regulations. Certain NCH Funds may at times constitute plan assets under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). NCH generally provides investment management services directly and through affiliated management entities with respect to one or more clients for operational and other purposes (each, a “Relying Adviser” and collectively each is included within the term NCH, except as the context otherwise requires). NCH controls, or is under common control with, each Relying Adviser. Unless specifically noted otherwise, the response to the Form ADV Part 2A combines information about NCH and the Relying Advisers. The Adviser had $2,146,043,398 in regulatory assets under management, as of December 31, 2023. These assets are managed on a discretionary basis. The value of these assets continues to be significantly impacted by the invasion of Ukraine by Russia in 2022 and by the disruption of the markets for Russia- related securities. The present lack of ability to dispose of Russian securities under

current Russian regulations causes the Adviser to value Russian securities at zero on NCH Balkan Fund, L.P., New Century Holdings XI, L.P., NCH Russia Fund, L.P., and NCH Eagle Fund, L.P.’s annual audited financial statements in accordance with GAAP. The business conducted in Russia by NCH Agribusiness Partners, L.P. was transferred in April 2024 under temporary administration by Russian Presidential Decree to the Russian Agency for State Property Management, resulting in an impact on that Fund that the Adviser is unable to assess at this time. The Principals began investing in Eastern Europe and Russia in 1991. Encouraged by the potential of the early, undervalued investment opportunities they had identified, in 1993 they formed the Adviser and their first fund. Subsequent funds followed, formed to invest in equity-related securities, debt, private equity, real estate and agribusiness assets throughout this region. The Adviser provides investment supervisory and management services on a discretionary basis to clients that are pooled investment funds (“Fund(s)” or “NCH Fund(s)”) intended for institutional and other sophisticated investors (“Limited Partners”). These Funds hold investments in companies, operations and properties primarily in Bulgaria, Latvia, Moldova, Romania, Russia, and Ukraine. The Funds also hold investments in Albania, Croatia, Cyprus, Greece, Kazakhstan, Montenegro, Serbia, and the United Kingdom. NCH seeks profitability from these investments based on medium to long-term appreciation of the value of these assets.