S.W. Mitchell Capital LLP (“S.W. Mitchell Capital” or “we”) was founded in April 2005 as a limited liability partnership incorporated in England and Wales (registered no. OC312953) and has its principal place of business and registered office at Princes House, 38 Jermyn Street, London, SW1Y 6DN United Kingdom. Stuart Mitchell is the principal owner of, and controls, S.W. Mitchell Capital. S.W. Mitchell Capital is authorized and regulated in the United Kingdom by the UK Financial Conduct Authority (the “FCA”). S.W. Mitchell Capital provides investment management services and will perform, on behalf of its clients, other investment related duties and functions as may be agreed upon with the client. The specific services provided and fees charged by S.W. Mitchell Capital to a particular client depend upon the investment objectives and restrictions of the client, as set forth in the documents governing S.W. Mitchell Capital’s agreement with the client. Item 8 includes additional detail about our strategies, investments and related risks. S.W. Mitchell Capital currently advises a range of different clients, including private accounts, private funds and a registered investment company. Private Accounts S.W. Mitchell Capital provides investment supervisory services and discretionary and non- discretionary portfolio management to corporations, pension plans and non-profit organizations (“Private Accounts”). S.W. Mitchell Capital consults with, and formulates an investment program for each Private Account, and complies with limitations and guidelines established by each client, if any. This investment management program is set out in each respective Private Account’s investment management agreement

(each, an “Investment Management Agreement”). In the event of any inconsistency between this brochure (the “Brochure”) and a Private Account’s Investment Management Agreement, the Investment Management Agreement shall control. S.W. Mitchell also may accept non-discretionary client accounts referred to as “Emulation Accounts”, for which S.W. Mitchell provides information on a template portfolio to the client but does not affect transactions for the client account. Funds S.W. Mitchell Capital currently provides discretionary investment advice to private investment funds and other non-U.S. funds (the “Private Funds”). The investments of each Fund are managed in accordance with the Fund’s investment objectives, strategies and guidelines and are not tailored to any particular investor in the Fund (“Investor”) nor may any Investor direct a Fund’s investments. The investment objectives, strategies and guidelines are set out in each respective Fund’s offering memorandum, prospectus, organizational, governing and/or other related documents (together, the “Governing Documents”). In the event of any inconsistency between this Brochure and a Fund’s Governing Documents, the Governing Documents shall control. S.W. Mitchell Capital does not provide individualized investment advice to the Investors; therefore, Investors should consider whether a particular Fund meets their investment objectives and risk tolerance. As of March 31, 2023 we managed approximately $939,320,632.00 of client assets on a discretionary basis and $0.00 of client assets on a non-discretionary basis. These amounts were determined based upon the aggregate net asset value of the Funds and discretionary and non- discretionary Private Accounts as of such date.