ADVISORY BUSINESS Firm Overview Cephei Capital was founded in 2006. Cephei Capital manages a concentrated portfolio of China-based companies that may be traded on any exchange in the world. Cephei Capital’s principal owner is Cephei Capital Management Company Limited which wholly owns Cephei Capital (i.e. 100%). Cephei Capital has obtained the Renminbi Qualified Foreign Institutional Investor (“RQFII”) license issued by the China Securities Regulatory Commission (“CSRC”) and China’s State Administration of Foreign Exchange (“SAFE”) in 2014. Cephei Capital’s Advisory Services Cephei Capital’s primary business is providing investment advisory services to pooled investment vehicles (the “Private Funds”) and single investor managed accounts (the “Managed Accounts,” together with the Private Funds, the “Clients,” and each a “Client”) in their investments in the publicly-traded securities of issuers that have a substantial portion of their operating assets located in the People’s Republic of China (the “PRC”) or that derive a large portion of their revenues or earnings from activity connected to the PRC. Customized Services for Institutional Clients Impose Restrictions As described above, Cephei Capital provides discretionary investment advisory management services to Managed Accounts, which, unlike the Private Funds described above, are generally formed for the specific purpose of managing the assets of a single institutional investor. The investment strategies for the Managed Accounts may, and generally do, parallel all or a portion of the investment strategies

of the Private funds, but there are, on occasion, differences between the investment strategies of a Managed Account and any other Cephei Capital Client. Cephei Capital enters into agreements to advise Managed Accounts only under limited circumstances and the advisory services provided to each such Client, and the related terms and fees, are negotiated on a case-by-case basis. The investment objectives and strategy for the Clients are described in the Client’s offering documents/ client agreements. Cephei Capital provides investment management services to the Clients, pursuant to the Investment Management Agreement/ client agreement, based on the specific investment objectives and strategies of the Clients. Cephei Capital does not provide services individually to investors in the Private Funds (the “Investors”). Since Cephei Capital does not provide tailored advice to the Investors, the Investors should consider whether the Private Fund’s or Managed Accounts investment strategies are in line with their risk tolerances. Some Clients may from time to time impose restrictions on certain security names and non-ESG industries which Cephei Capital complies with. The Private Funds may from time to time enter into side letter agreements or other similar agreements (“Side Letters”) providing Investors with additional and/or different rights and benefits. Wrap Fee Program Cephei Capital does not participate, sponsor, or act as a portfolio manager for any wrap fee programs.
Assets Under Management Cephei Capital manages Client’s assets on a discretionary basis. As of December 31, 2023 Cephei Capital had more than USD $5,069,216,691 million assets under management.