Varadero, a Delaware limited partnership, was formed in July 2009. The Firm is principally owned by Fernando Guerrero, the Firm’s Managing Partner and Chief Investment Officer, indirectly through his ownership and control of Guerrero Family Interests, LLC. As of December 31, 2022, Varadero had approximately $2,706,147,694 in net assets under management, all of which are managed on a discretionary basis. (Note that the method for computing “assets under management” is different than the method for computing “regulatory assets under management” required for Item 5.F. in Form ADV Part 1A). Varadero provides discretionary investment management services to pooled private investment funds and to institutions or other investors that have separate accounts and, from time to time, commercial real estate collateralized loan obligation vehicles for which Varadero may serve as collateral manager. Clients may engage Varadero to manage their assets on a discretionary or non-discretionary basis. Private Investment Funds Varadero serves as the investment manager to several private investment funds, including Varadero Master Fund, L.P. (the “Master Fund”), Varadero Partners, L.P. (“Partners”), Varadero International, Ltd. (“International”, and collectively with the Master Fund and Partners, the “VMF Funds”), Varadero Special Opportunities Master Fund, L.P. (the “VSOF Master Fund”), Varadero Special Opportunities International, L.P. (“VSOF International”) and Varadero Special Opportunities International (B), L.P. (“VSOF International B”, and collectively with the VSOF Master Fund and VSOF International, the “VSOF Funds”) (the foregoing private investment funds, collectively, the “Private Funds”). Partners and International serve as feeder funds into the Master Fund and, as such, invest all or substantially all of their investable assets directly or indirectly in the Master Fund. VSOF International B and VSOF International (through its investment in Varadero Special Opportunities Intermediate Fund, L.P., (the “VSOF Intermediate Fund”)) invest substantially all of their investable assets through VSOF Master Fund. The Firm acts as the investment adviser to the VMF Funds and VSOF Funds and is responsible for evaluating and monitoring investments and providing day-to-day managerial services to such Private Funds. An affiliate of Varadero, Varadero General Partner, LLC (the “VMF General Partner”), acts as the general partner to the Master Fund and Partners. Varadero Special Opportunities General Partner, LLC (the “VSOF General Partner”), also an affiliate of Varadero, serves as general partner to the VSOF Master Fund, VSOF Intermediate Fund, VSOF International and VSOF International B. The VMF Funds seek attractive risk-adjusted total returns for investors primarily by acquiring and actively managing a portfolio of debt instruments. Varadero focuses on investments that it believes to be fundamentally undervalued or to otherwise offer attractive returns with current market prices that are believed to be compelling relative to intrinsic value. In executing its investment program for the VMF Funds, the Firm anticipates investing in a variety of financial instruments with a focus on various forms of asset-backed and other structured credit securities, loans and other investments, including, but not limited to: investment-grade residential mortgage-backed securities (“RMBS”), asset-backed securities (“ABS”), collateralized debt obligations (“CDO”), commercial mortgage-backed securities (“CMBS”) and collateralized loan obligations (“CLO”), below investment-grade interests (equity tranches and residuals) in RMBS, ABS, CDO, CMBS and CLO, performing/non-performing/reperforming mortgage loans, commercial real estate loans, tax liens, consumer loans, small business loans and asset-based investments typically secured by physical, financial and/or tangible assets, including portfolios of receivables, mezzanine and equity investments in esoteric securitizations and special situation financing. In addition, from time to time, the VMF Funds also may structure and/or acquire participations in and/or assignments of sales of loans and interests therein and may also invest in equity securities of publicly traded companies. From time to time, Varadero may seek to pool commercial real estate loans, participations and related exposures held by the Master Fund and structure collateralized loan obligations backed by such exposures (each, a “CRE CLO”). The VSOF Funds seek attractive risk-adjusted total returns by acquiring and actively managing portfolios of loans, leases and other financial assets originated by various types of specialty finance companies, banks or non-bank lenders. In executing its investment program for the VSOF Funds (and similarly designed closed-end successor funds), Varadero may seek to invest in a variety of assets, including small business loans, merchant cash advances, small and medium ticket equipment leases, commercial real estate mortgages, transitional residential real estate loans, residential mortgages, student loans, consumer loans, auto loans and other forms of collateralized and uncollateralized exposures. With respect to the VMF Funds and VSOF Funds (and similarly designed closed-end successor funds), Varadero may seek to effectuate investments in whole loans,

leases or other financial assets directly or may seek to gain such exposures indirectly through certain aggregation vehicles, special purpose vehicles or other alternative investment vehicles. Varadero may seek to participate directly or indirectly in joint ventures with unaffiliated loan originators, real estate developers, operating partners, mortgage loan originators and other real estate investors. Varadero also may seek to gain broad exposures to certain asset classes by negotiating structured finance arrangements with originators of financial assets. Participation as an investor in the VMF Funds and VSOF Funds is generally restricted to investors that are “qualified clients” pursuant to the requirements under Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended (the “Securities Act”), and “qualified purchasers” as defined under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Interests in the Private Funds are privately offered pursuant to Regulation D under the Securities Act. The Private Funds currently rely on an exemption from registration under the Investment Company Act. Varadero advises private investment funds in an attempt to achieve the applicable fund’s investment objectives (consistent with any guidelines and/or restrictions that may be imposed thereon) and does not tailor its advice to the individual needs of any investor in such fund. Private investment fund investors generally may not impose any restrictions on the way in which Varadero provides advice to the applicable fund. Varadero’s management of a private investment fund is subject to, and the terms of any investor’s investment in any such fund and all other terms of a fund are governed by, the terms of the fund’s limited partnership agreement (as applicable), memorandum and articles of association (as applicable), the investment management agreement and subscription agreement, as each may be amended, supplemented or modified from time to time (the “Governing Documents”). Investors and other recipients should be aware that, while this Brochure includes information about private investment funds, including the VMF Funds and VSOF Funds, it is not a complete description of the terms, risks or conflicts associated with an investment in any such fund. More complete information about private investment funds, including the VMF Funds and VSOF Funds, is included in the applicable fund’s offering memorandum and Governing Documents, which may be provided to eligible prospective investors by Varadero or another authorized party. The information contained in this Brochure is qualified in its entirety by reference to disclosures made in an applicable private investment fund’s offering memorandum and Governing Documents, which should be carefully reviewed prior to making an investment decision. In no event should this Brochure be considered an offer to sell or a solicitation of an offer to buy interests in any VMF Fund or any other private investment fund or relied upon in determining to invest in any such fund. This Brochure is designed solely to provide information about Varadero for purposes of complying with certain obligations under the Advisers Act and, as such, responds to relevant regulatory requirements under the Advisers Act that may differ from the information required to be provided in an offering memorandum and other related documents. In the event of any inconsistency between a private investment fund’s offering memorandum and/or Governing Documents and this Brochure, such offering memorandum and/or Governing Documents, as the case may be, shall control. Separate Accounts Varadero’s management of separate account assets is based on the individual objectives of each separate account. At the onset of a separate account relationship, Varadero will identify specific investment objectives and/or restrictions of the client and related account. Separate accounts may impose restrictions with respect to specific securities and security type, among other things. All objectives and restrictions shall be contemplated in the investment management agreement relating to such separate account between Varadero and the applicable client. Similar to the VMF Funds, the separate accounts generally utilize strategies that seek attractive risk- adjusted total returns for investors by acquiring and actively managing a portfolio of debt securities, however, the assets underlying the separate accounts generally have shorter maturity horizons. Furthermore, in executing such investment program, Varadero generally may allocate assets among investment-grade RMBS, ABS, CDO, CMBS, and CLO, below investment-grade interests (equity-tranches and residuals) in RMBS, ABS, CDO, CMBS and CLO, performing/non-performing/reperforming mortgage loans, commercial real estate loans, tax liens, consumer loans, small business loans and asset-based investments typically secured by physical, financial and/or tangible assets, including portfolios of receivables, mezzanine and equity investments in esoteric securitizations and special situation financing. In addition, from time to time, the separate accounts also may invest in other types of investments.