SCM is a Delaware limited partnership that was formed in April 2002 by Matthew S. Tewksbury. Mr. Tewksbury serves as SCM’s Chief Executive Officer. SCM is registered as an investment adviser with the SEC under the Investment Advisers Act of 1940 (the “Advisers Act”); such registration does not imply a certain level of skill or training. SCM is registered as a commodity pool operator since January 2009 and a commodity trading advisor since June 2003 with the U.S. Commodity Futures Trading Commission (the “CFTC”) and is a member of the National Futures Association (the “NFA”), a U.S. self-regulatory organization supervised by the CFTC. SCM currently employs 64 professional and administrative staff in its office located at 201 King of Prussia Road, Suite 400, Radnor, Pennsylvania, 19087. SCM is the investment, portfolio and administrative manager for four clients: Tewksbury Investment Fund ("TIF"); Hamilton Fund Ltd. (“HFL”), a Bermuda company that invests all of its capital into TIF; Tewksbury Futures Fund Ltd. ("TFF"); and Tewksbury Futures Fund, LP ("TFFLP"), a Delaware limited partnership that invests all of its capital into TFF. HFL does not hold any portfolio investments other than the shares of TIF. TFFLP does not hold any portfolio investments other than the shares of TFF (TIF and TFF may be referred to individually as a “Fund” and collectively as the "Funds". HFL and TFFLP may be referred to individually as a “Feeder Fund” and collectively as the "Feeder Funds". TIF, HFL, TFF and TFFLP may be referred to collectively as the “Clients”.). TIF is an open-ended Bermuda company that trades and invests in a wide and substantially unrestricted variety of financial markets and instruments. TFF is an open-ended Bermuda company that pursues substantially similar trading strategies to those employed by SCM on behalf of TIF in global futures and commodities markets as well as in a number of common stocks and exchange-traded products traded as part of TIF's futures trading strategies (“F-Desk Strategies”). In managing the trading for the Funds' portfolios, SCM will employ proprietary investment strategies, based on quantitative analysis as well as fundamental research, taking both long and short positions,

combined with proprietary risk management and trade execution methodologies and strategies. In addition, SCM allocates significant assets to external investment advisers and commodity trading advisors. SCM has committed, on behalf of the Funds, a substantial portion of the Funds' assets to “outside” investment managers unaffiliated with TIF, TFF or SCM through its Outside Traders Investment Program (“OTIP”), a department within SCM that selects outside investment managers. SCM is the principal adviser and trader for the Funds and has overall responsibility for all of the Funds' trading activities. SCM delegates investment discretion to a number of internal traders and in the case of OTIP, to external traders as well. SCM has a sub-advisory and contractual services agreement with Waterfront International Ltd. (“Waterfront”), a company based in Toronto, Canada, as further described under Item 8 and Item 10. SCM’s staff includes technical support personnel and a team of financial analysts to support its investment advisory and trading activities. SCM is also responsible for certain aspects of the administrative operations for the Clients, which broadly include: (1) administrative, legal and regulatory compliance; and (2) development and implementation of accounting systems, procedures and policies. Other than serving as the investment, portfolio and administrative manager of the Clients (and certain of their respective subsidiaries), SCM currently does not offer any other financial or advisory services. The general partner of SCM is Adams Holdings LLC (“Adams”), a company owned by Matthew Tewksbury and his family. Mr. Tewksbury is the Managing Member of Adams. SCM's limited partners are Mr. Tewksbury and Adams. SCM has full discretion in investment decisions made on behalf of the Funds, including the decision as to which external managers to allocate capital to as part of OTIP. Investment advice is provided directly to the Funds according to their particular investment objectives and not individually to the Funds’ shareholders As of December 31, 2023, SCM manages, on a discretionary basis, U.S. $2,496,405,124 in Client assets. SCM does not manage any client assets on a non-discretionary basis.