ADVISORY BUSINESS A. General Description of Advisory Firm. The Adviser, Mudrick Capital Management, L.P., a Delaware limited partnership, commenced operations in 2009 and has its office in New York, New York. Mr. Jason Mudrick, as a limited partner of the Adviser and as the managing member of the general partner of the Adviser, Mudrick Capital Management, LLC, a Delaware limited liability company, is the principal owner of the Adviser and controls the Adviser. The general partner of the Adviser has ultimate responsibility for the management, operations and the investment decisions made by the Adviser. B. Description of Advisory Services. 1. Advisory Services. The Adviser serves as the investment manager to a number of investment funds (the “Funds”) and separately managed accounts and may, from time to time, serve as the investment manager to additional funds or products. The interests in the Funds are generally offered on a private placement basis, in compliance with the exemption provided by Section 3(c)(7) of the Investment Company Act of 1940, as amended (the “Investment Company Act”) to persons who are “accredited investors” as defined under the Securities Act of 1933 and “qualified purchasers” (or “knowledgeable employees”) as defined under the Investment Company Act, and subject to other conditions, that are set forth in the offering documents for the Funds. The Adviser has incorporated Mudrick Capital Management (UK), Ltd. (the “UK Affiliate”) in the United Kingdom, which is a limited liability partnership formed under the UK Limited Liability Partnerships Act 2000. The UK Affiliate was formed for purposes of conducting regulated activities in the UK, including investment or research activities, marketing activities or performing other functions. Mudrick Capital Management (UK) Ltd is as an Appointed Representative of Kroll Securities Ltd. (FCA Number: 466588), which is authorized and regulated by the UK Financial Conduct Authority (the “FCA”). As previously communicated to applicable Fund investors on November 15, 2023, the Mudrick Distressed Opportunity Fund implemented certain modifications to Fund terms, which will be effective April 1, 2024. In particular, for Mudrick Distressed Opportunity Fund these modifications include closing the previously offered Class A, Class B, and Class C shares/interests and only offering Class D shares/interests which are subject to a 1.5% management fee, a 20% incentive allocation and a 25% quarterly investor-level withdrawal gate. Existing investors in the Mudrick Distressed Opportunity Fund would be entitled to retain their existing class of shares/interests with no changes to their existing liquidity terms (which do not have an investor- level gate but do have a fund-level gate), though they will not be entitled to acquire additional interests of their existing classes (i.e., Class A, Class B or Class C) as of April 1, 2024. In addition, the side pockets terms were modified such that all investors will be required to participate in side pocket investments beginning on this date. In addition, Mudrick Stressed Credit Fund, Ltd. and Mudrick Stressed Credit Fund, L.P. implemented certain changes to their Fund terms, which will be effective April 1, 2024. The more meaningful changes include that the Funds would be no longer offering Class A shares/interests and instead only offering Class B shares/interests, which are subject to a 25% quarterly investor- level withdrawal gate. While existing Class A investors would be entitled to retain their existing classes of interests with no change to their existing liquidity terms (which do not have an investor- level gate but do have a fund-level gate), they will not be entitled to acquire additional Class A interests/shares in the Fund as of April 1, 2024. In addition, the key person event trigger for the Funds was updated beginning on this date. As used herein, the term “clients” generally refers to the Funds and/or the Adviser’s separately managed account clients, as applicable. This brochure generally includes information about the Adviser and its relationships with its clients and affiliates. While much of this brochure applies to all of those clients and affiliates, there is information included herein that only applies to specific clients or affiliates. 2. Investment Strategies and Types of Investments. The descriptions set forth in this brochure of specific advisory services that the Adviser offers to clients, and investment strategies pursued and investments made by the Adviser on behalf of its clients, should not be understood to limit in any way the Adviser’s investment activities. The Adviser may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this brochure, that the Adviser considers appropriate, subject to each client’s investment objectives and guidelines. The investment strategies the Adviser pursues are speculative and entail substantial risks. Investors should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. The investment objectives and strategy of the Funds are set forth in confidential private offering memoranda and are summarized below. In the case of variations in investment strategies pursued by certain Funds, those differences are noted below where applicable. The Adviser also provides investment advisory services to separately managed accounts. The investment objectives and strategy of the separately managed accounts are generally consistent with the following, though certain differences are noted below where applicable. Investment Objectives The principal objective of the Funds is to seek capital appreciation from a portfolio of distressed debt and equity investments which generate attractive and asymmetric risk-adjusted total returns over the long term with significant downside protection. The Funds will focus on event-driven value investments in companies with overlooked or distressed capital structures, characterized by their income-profile, due to an actual or perceived balance sheet event. Certain of the Funds and separately managed accounts have been set up (i) to co-invest in only a specific subset of opportunities or companies or (ii) to generate attractive total returns on capital throughout the credit cycle by employing an opportunistic strategy targeting event-driven situations in leveraged corporate capital structures, as in the case of the Stressed Credit Fund, and the objectives of those Funds and separately managed accounts (as well as the investment strategies and types of investments as described herein) are modified accordingly. There are also certain separately managed accounts that have been set up to generate stable, income driven returns through primarily passive investments in senior secured securities of distressed issuers, such as secured term loans, secured bonds and debtor-in-possession (“DIP”) financing (the “Senior Secured Strategy”). The Stressed Credit Fund and Senior Secured Strategy Clients generally trade pari passu subject to certain parameters and restrictions in the investment guidelines of the offering memorandum or investment management agreement (as applicable), or other considerations in accordance with the Adviser’s allocation policies. The securities held by co-investment clients are also held by certain Funds and separately managed accounts in their portfolios. Investment Strategy Overview The Funds will primarily invest in distressed debt and equity in the middle-market space (defined as companies with an enterprise value of less than US $5 billion, measured at the time of investment), across North America and Western Europe, predominantly through the following investment strategies: “Pull to Par” Distressed Debt. The Funds will seek to purchase the stressed or distressed debt of companies that the Adviser believes are trading significantly below their intrinsic value primarily for attractive yield, which includes a combination of current income and “pull to par” capital appreciation. Investments in stressed or distressed debt are typically made by purchasing debt instruments on the secondary market. Debt for Equity Swaps. The Funds will seek to invest in the distressed debt of companies that the Adviser believes are trading significantly below their intrinsic value with an aim of taking an active role in debt restructuring negotiations or other processes to influence the outcome. This typically will involve the Funds purchasing debt instruments on the secondary market that may convert to new debt instruments, post-reorganized equity or a combination thereof through active influence via creditors’ committees, steering committees, ad hoc groups and/or participation on the board of directors. To a lesser extent, the Funds may also seek to make investments using the strategies set out below: Special Situations. The Funds may seek to purchase the debt or equity of companies that the Adviser believes are trading significantly below their intrinsic value due to a market dislocation or idiosyncratic company-specific situation. Capital Solutions. The Funds may provide rescue financing, structured equity solutions and liability management solutions to companies that are unable to access traditional markets. These transactions are privately originated and directly negotiated by the Adviser, bespoke for each company. The above strategies are non-exhaustive and the Funds may invest in financial instruments through other investment strategies as adopted from time to time, to the extent this is deemed to be in the interests of the Fund investors by the Adviser. The Funds may make investments across the capital structure of companies in both the private and public markets. Investments may comprise long or short positions in both publicly traded equity and debt securities and obligations and private securities and obligations, however, the Funds are predominantly long-biased on the positions they hold and the Adviser expects this to continue to be the case in the long-term. In the case of the Stressed Credit Fund, the Fund expresses its strategy largely through investments in stressed and performing credit instruments, including loans and bonds, select distressed instruments and equities and episodic hedges or short positions. The Adviser uses fundamental credit research to seek to identify the most compelling total return opportunities in the global corporate credit markets (with an emphasis on the North American and European markets) and will focus primarily on investing the Fund’s capital in loans and bonds (in cash and synthetic form) of speculative grade companies, but may also invest in certain convertible bonds and preferred securities, equity (including equity-linked) and structured finance securities. The Adviser applies fundamental credit analysis and a proactive management style to manage investment and portfolio risk. In the case of the Senior Secured Strategy, its investments will generally focus primarily on the following strategies: (1) purchasing the senior secured distressed debt of companies that the Adviser believes are trading below their intrinsic values due to a potential restructuring event; (2) purchasing interests in DIP loans of companies going through bankruptcy, in secondary market transactions; and (3) purchasing senior secured debt of post-bankruptcy companies. Types of Securities (Applicable to Funds other than the Stressed Credit Fund) The below describes the types of securities in which the Funds, other than the Stressed Credit Fund, will invest. The types of securities in which the Stressed Credit Fund will invest are described further below. The Funds make investments across the capital structure of companies in both the private and public markets. Investments may comprise long or short positions in both publicly traded equity and debt securities and obligations and private securities and obligations, at original issuance and/or on the secondary market. The equity securities may include common and preferred equity or such other securities as the Adviser may determine from time to time, and the debt securities and obligations may include all types of debt securities and obligations, such as corporate bonds, debentures, notes, municipal bonds, equipment lease certificates, equipment trust certificates and, to the extent permitted by applicable laws and regulations, securities issued by troubled foreign issuers, including foreign governments. The private securities and obligations may include bank debt, trade claims of bankrupt companies and other privately traded securities and obligations. In addition, as described in more detail below, certain Funds may (and have in the past) hold an investment in the sponsor of a special purpose acquisition vehicle formed to pursue an initial business combination with a post-bankruptcy or post-reorganized target company (though such vehicle may target a company in any stage of its corporate evolution). As a consequence of their purchase of private claims from banks and other financial institutions, the Funds may be required to perform certain lending functions, such as funding issued but undrawn letters of credit in the course of the restructuring of a troubled company or providing debtor-in-possession financing to the troubled company in the event that it seeks relief under Chapter 11 of the Bankruptcy Code. Upon the completion of a restructuring, the Funds’ distributions may be in the form of obligations arising under an amended credit facility made available to the troubled company. The Funds’ performance of these traditional lending functions may often be essential to their ability to consummate purchases of private claims. The Funds’ decisions to undertake such lending functions are determined by the overall projected return for the private claim investment. The Funds will be authorized to fund, participate in the funding of or otherwise sponsor the plan of reorganization of a debtor-in-possession or an out-of-bankruptcy restructuring. This activity typically involves formulating or participating in the formulation of a plan of reorganization and the funding of such plan in return for the acquisition of assets of the debtor and/or a debt and/or equity interest in the reorganized entity. The Adviser believes that there are several factors that might create opportunities to invest in this manner at attractive prices. First, companies exiting bankruptcy often have difficulty raising new capital, particularly new equity. Permanent capital may be a necessary component of the company’s plan of reorganization or management or creditors may prefer a plan that provides for new equity capital. Second, creditors may undervalue the securities to be received through a plan of reorganization. Third, creditors may be willing to accept a lower payout if that payout is in cash rather than securities of the reorganized company. Trade Claims of Companies in Bankruptcy. Trade claims are unpaid accounts receivables held by a creditor of a company in a Chapter 11 or a Chapter 7 bankruptcy proceeding. Trade claims are general unsecured debt obligations. The United States bankruptcy laws allow a company to avoid payment on its pre-petition accounts receivable during the pendency of a bankruptcy case. Therefore, a trade creditor must generally wait until a Chapter 11 plan of reorganization or a Chapter 7 plan of liquidation is confirmed by the bankruptcy court before it can receive

any distributions from the company on account of a trade creditor’s pre-petition accounts receivable. Although Wall Street dealers are active in trading larger trade claims in major cases, there is less liquidity in the broader trade claims market. The Adviser believes that significant opportunities exist in the trade claims market because many overlooked bankruptcies contain trade claims, and because holders of trade claims may not possess the skillset for properly valuing distressed debt. Purchasing trade claims of bankrupt companies may be a means of obtaining post-reorganized equity at a significant discount to its perceived inherent value. Short Sales and Derivative Securities. The Funds, in the discretion of the Adviser, may engage in short sales and in options transactions with respect to securities and other obligations. The Funds may purchase and write covered and uncovered put and call options on individual securities or on securities indices both as independent investment opportunities and as hedging devices as deemed appropriate by the Adviser. The Funds may also purchase or sell warrants or other derivative instruments. Short positions may also be taken in securities that the Adviser believes are relatively overvalued or are about to decline in price due to impending financial distress. Short positions generally are intended to serve as a degree of protection against a declining market but may also be independently viewed by the Adviser as profit opportunities for the Funds. Certain clients do not engage in short sales or derivatives transactions in accordance with those clients’ investment guidelines. Futures. The Funds, in the discretion of the Adviser, may purchase, hold, sell or otherwise deal in commodities, commodity contracts, commodity futures, financial futures or options thereon. Types of Securities (Applicable to the Stressed Credit Fund) Loans. The Stressed Credit Fund invests a significant portion of the Fund’s capital in the loans of speculative grade companies, both domestically and internationally. The Fund may invest in revolving, first, second and third lien loans, unsecured loans and any other loans. Senior loans (i.e., first lien loans) are typically ranked at the most senior level of the capital structure, and are often secured by specific collateral, including but not limited to, accounts receivable, inventory, equipment, buildings, real estate, franchises, trademarks, patents, and common and preferred stock of the obligor and its subsidiaries. High-Yield Bonds. High-yield bonds are issued by companies that do not qualify for “investment-grade” ratings by one of the leading credit rating agencies—Moody’s Investors Service, Standard & Poor’s Ratings Services and Fitch Ratings. Credit rating agencies evaluate issuers and assign ratings based on their opinions of the issuer’s ability to pay interest and principal as scheduled. Those issuers with a greater risk of default—not paying interest or principal in a timely manner—are rated below investment grade. These issuers must pay a higher interest rate to attract investors to buy their bonds and to compensate them for the risks associated with investing in organizations of lower credit quality. The Adviser relies on the expertise of its credit analysts who will use bottom up and industry analysis in order to identify high-yield bonds with the potential to generate attractive returns through current income and capital appreciation. Convertible Securities. The Fund may invest in convertible securities, which are bonds, debentures, notes, preferred stocks or other securities that may be converted into or exchanged for a specified amount of common stock of the same or different issuer within a particular period of time at a specified price or formula. A convertible security entitles the holder to receive interest that is generally paid or accrued on debt or a dividend that is paid or accrued on preferred stock until the convertible security matures or is redeemed, converted or exchanged. Structured Finance Securities. Structured finance securities are typically non-recourse or limited-recourse debt securities issued by a special purpose vehicle and secured solely by the assets thereof (including, without limitation, mortgage-backed securities, asset backed securities, collateralized bond obligations or collateralized loan obligations). Such securities are typically rated by one of the leading rating agencies. Equity Investments. The Investment Manager seeks to use its knowledge of credit and capital structures to identify securities within the same capital structure that are mispriced, including equities. The leveraged nature of speculative grade companies often implies a publicly traded market capitalization of less than 50% of the company’s enterprise value. The Adviser believes that these so-called “leveraged” equities can often present attractive investments because a small move in valuation multiples can have a disproportionate impact on the equity. The Adviser aims to use its knowledge of credit and high-yield industries to identify those equities that may present a compelling opportunity relative to the loans and/or bonds. Types of Securities (Applicable to the Senior Secured Strategy) The Senior Secured Strategy expects to invest in senior secured debt securities and obligations of issuers before an expected or actual restructuring, during bankruptcy and post- bankruptcy. The senior secured debt securities and obligations may include all types of debt securities and obligations, such as corporate bonds, term loans, and DIP loans, as well as private securities and obligations that may include trade claims of bankrupt companies and other privately traded securities and obligations. The clients following the Senior Secured Strategy generally may hold or trade: (i) all forms of publicly and non-publicly traded securities and other financial instruments of U.S. and non-U.S. issuers, including, without limitation, bonds, debt, notes, debentures (whether subordinated, convertible or otherwise), loans (including but not limited to term loans, DIP loans and “frozen” revolving loans), trade claims, preferred stock, common stock, rights, units, certificates of beneficial interests, warrants, put and call options on equity securities, loan participations and assignments, joint ventures, notes and accounts receivable and other obligations and instruments or evidences of indebtedness of whatever kind or nature of any person, corporation or entity whatsoever, foreign or domestic, foreign currency transactions for the purpose of either acquiring foreign currencies to purchase foreign securities or hedging portfolio positions in foreign securities against exchange rate fluctuations and derivative securities hedging against or otherwise utilizing any of the foregoing; (ii) money market funds, obligations of the United States, commercial paper, certificates of deposit, banker’s acceptances, trust receipts; or (iii) instruments that hedge the foregoing. In addition, the Senior Secured Strategy may perform certain limited lending functions, such as providing DIP financing to a distressed company that is seeking relief under Chapter 11 of the Bankruptcy Code. While the Senior Secured Strategy intends to take a primarily passive investment approach, to protect its position with respect to an investment in a debt obligation of a troubled company, it may occasionally be required to take an active role in negotiating the plan of reorganization of a debtor-in-possession or an out-of-bankruptcy restructuring. This activity typically involves formulating or participating in the formulation of a plan of reorganization, and may involve the performance of limiting lending functions as described above, in each case in return for the acquisition of assets of the debtor and/or a debt and/or equity interest in the reorganized entity. The Senior Secured Strategy, in the discretion of the Adviser, may purchase and sell derivative instruments, both as independent investment opportunities (i.e., to gain exposure to certain senior secured debt securities or obligations) and as hedging devices. In particular, the Senior Secured Strategy may invest in total return swaps as a means of gaining exposure to securities and obligations in which the Senior Secured Strategy could otherwise directly invest. The Investment Process The investment process at the Adviser typically includes the following stages: (i) sourcing potential investments; (ii) research and due diligence on potential investments; (iii) investment selection and execution; (iv) portfolio and risk management; and (v) investment exit. Each stage of the investment process is set out in detail below. Sourcing. The research team and the trading team work collaboratively to source investment opportunities. Ideas are primarily sourced by price – the trading team monitors the price of debt in both the public and private markets trading below par and flags these debt instruments for the research team to evaluate. The Adviser may use other channels for idea generation as well. Distressed situations tend to attract media attention, with coverage of companies’ deteriorating financing conditions in industry publications. While less common, the investment team may also leverage sell side research and relationships for idea generation. Lastly, the investment team’s extensive network may provide opportunities for idea sourcing as well. Research & Due Diligence. Once potential investments are identified, the Adviser will generally engage in rigorous industry research and company-specific due diligence in order to have a fully informed view of the financial condition of a company prior to making an investment decision. To understand the inherent risks and rewards of an investment, the Adviser will typically conduct the following analysis and due diligence, as appropriate:
• Evaluate a company’s senior management team, including onsite company and management team visit
• Industry fundamentals review
• Capital structure review
• Historical and projected financial performance analysis
• Liquidity and cash flow analysis
• Sponsor conversations
• Competitor conversations and analysis
• Customer and supplier conversations
• Conversations with relevant experts in law, tax, regulatory or industry-specific areas, including those in professional networks of personnel of the Adviser
• Document review
• Exit strategies and recovery analysis This diligence process is typically an iterative approach that typically involves extensive input from the broader research team. The Adviser’s investment process is constructed to: (i) foster dialogue and debate around the team’s top investment opportunities; (ii) encourage healthy competition for investment opportunities; and (iii) drive ongoing re-underwriting of the pipeline of new investment opportunities. Investment Selection and Execution. The portfolio managers ultimately decide whether an investment is appropriate for the portfolio, including entry cost and position sizing, subject to final approval by the Adviser’s Chief Investment Officer. The Chief Investment Officer also has the authority to make portfolio investment decisions independent of this process. Portfolio Risk Management The Adviser engages in active portfolio and risk management on an ongoing basis. Importantly, the analyst on the research team that led the underwriting and due diligence on the investment generally will continue to cover the company post-investment. Additionally, the ratio of investments to analysts is relatively low, such that each analyst can thoroughly and actively monitor their coverage list of investments on an ongoing basis. Risk Management Guidelines. As part of its general risk management framework, the Adviser seeks to adhere to certain targeted guidelines for a disciplined approach to portfolio construction and management. In addition, certain clients have their own specific portfolio investment guidelines that the Adviser adheres to. Investment Exit. The portfolio managers and Chief Investment Officer, in consultation with the research team and trading team, will determine their view of the optimal timing for exit generally based on valuation, a particular catalyst, and/or efficient trade execution. Borrowing. The Funds may employ leverage, including margin borrowing, to seek to enhance investment returns or for any other reason. The Adviser believes that, in certain situations, the use of borrowing can significantly enhance returns with an acceptable increase in risk. Ongoing Monitoring. The Adviser will conduct ongoing monitoring of relevant portfolios with focus on the understanding of the fundamental and technical elements of the investments in order to manage the portfolio proactively rather than reactively. This involves refreshing of information on current portfolio issuers and across the database to assist the Adviser to make accurate, time-sensitive investment decisions. Side Pockets Investors in certain of the Funds may be subject to side pocket investments (each, a “Side Pocket Investment”); provided that the Adviser is permitted to designate an investment as a Side Pocket Investment only if, immediately after giving effect to such designation, no more than 20% of the carrying value of such Funds’ assets would consist of Side Pocket Investments and “new issues.” As of April 1, 2024, the offering documents of these Funds will be amended such that all investors generally will participate in any designated Side Pocket Investments. Unless the Adviser determines otherwise in its sole discretion, an investor will participate in any Side Pocket Investment if, and only if, such investor is an investor on the date as of which the Adviser designates such investment as a Side Pocket Investment. Until a Side Pocket Investment has been sold or has otherwise become readily marketable, no gain or loss on such Side Pocket Investment will be ordinarily allocated, and investors will not be permitted to redeem or withdraw the portion of their interest in the Funds that is attributable to such Side Pocket Investment. Other Investment Vehicles The clients may participate in all or part of an investment through special-purpose vehicles (such as a corporation, a limited liability company, a business trust or a combination thereof) formed to address tax, legal, regulatory or other considerations or to aggregate multiple accounts, in each case as determined by the Adviser in its discretion. The descriptions contained herein of specific investment strategies that are or may be engaged in by the Funds should not be understood as in any way limiting the Funds’ investment activities as determined by the Adviser to be in the best interests of the Funds, whether or not described in this brochure. The Funds may engage in investment strategies not described herein that the Adviser considers appropriate. C. Availability of Customized Services for Individual Clients. Unless otherwise agreed to in writing, the Adviser does not generally tailor its advisory services to the individual needs of its clients, and clients generally may not impose restrictions on investing in certain securities or types of securities. D. Assets Under Management. The Adviser has regulatory assets under management (“RAUM”) of approximately $3,323,192,025 as of December 31, 2023. All of the Adviser’s assets are managed on a discretionary basis, and does not manage any assets on non-discretionary basis.