Our Business GCMLP (including its predecessors) has been in business since 1971. GCMLP provides the following investment management and advisory services for hedge fund and alternative investments to investment vehicles and separately managed accounts (GCMLP Funds):
• Multi-investor GCMLP Funds managed or advised by GCMLP (Commingled GCMLP Funds)
We offer investment vehicles designed for multiple investors who seek ease of investment, diversification, and choice of strategy. Investors who wish to invest in our Commingled GCMLP Funds may currently choose from multi-strategy, credit- focused, equity-focused, macro-focused, commodity-focused, and other specialty portfolios.
• Single-investor GCMLP Funds managed or advised by GCMLP (Customized GCMLP Funds)
We offer customized investment vehicles and separate accounts designed for investors seeking a customized mandate, control over structure, and/or involvement in the investment process. We collaborate with investors to design, implement, and monitor customized portfolios tailored to the investor’s needs. Most GCMLP Funds invest primarily in hedge fund or alternative investment vehicles or accounts (Underlying Funds) managed by third-party investment managers (Investment Managers). Certain GCMLP Funds directly invest in trading and/or investment positions, portfolio companies, real assets, market exposures, debt, and/or various sources of risk premia (Direct Investments) or do so indirectly through investments in one or more managed accounts or limited liability vehicles, instruments, or investment structures managed by GCMLP or third-party firms (Co-Investments, collectively with Direct Investments, Strategic Investments). Although investors in the GCMLP Funds that are organized as legal entities are not, in their capacity as such, our clients for regulatory purposes, we sometimes refer to those investors as our clients. Advisory Services GCMLP offers clients who seek assistance in designing, building, and managing their hedge fund or alternative investment programs a wide range of tailored, non-discretionary services in the following areas: Program Design – We work with clients to design the framework of their hedge fund or alternative investment programs. We also help clients define and document policies for their overall programs and/or individual portfolios. Operational Infrastructure – We work with clients to design and implement the operational infrastructure for their hedge fund or alternative investment programs. To achieve their operational goals, clients may build in-house capabilities, leverage our administrative services, and/or engage third-party service providers. Due Diligence – Clients may access our research, due diligence, and views about Investment Managers and Underlying Funds through our due diligence reports and conversations with our staff. Investment Managers and Underlying Funds may be sourced by us or the client. We may conduct due diligence and monitoring jointly with the client’s staff. Structuring – We assist clients who are developing their hedge fund or alternative investment programs in assessing and selecting the appropriate structures for their hedge fund or alternative investments. Clients building direct investment programs and customized portfolios may under certain circumstances benefit from our experience negotiating advantageous terms with Investment Managers, which may include lower effective fees, improved terms, separate accounts, and/or other side letter provisions. In addition, we may permit clients to participate in investments that reflect customized structures or terms negotiated between us and certain Investment Managers. Portfolio and Risk Management – We offer clients advice on constructing and managing customized portfolios. Clients may under certain circumstances access our portfolio management tools to manage their portfolios with the assistance of our investment professionals. Our risk aggregation and analytical capabilities help clients measure, monitor, and stress test certain risks associated with investments in their hedge fund or alternative investment programs. Technology Solutions – We provide a range of technology solutions to assist clients in managing their hedge fund or alternative investment processes. Knowledge Transfer – We offer clients formal educational and training sessions to assist in the development of their in- house hedge fund or alternative investment knowledge and capabilities. Transition Services – We assist clients in managing the orderly liquidation or transfer of hedge fund or alternative investment portfolios previously managed by clients or other investment managers. Ancillary Information Provided as a Courtesy At a client’s request, GCMLP may provide information, advice, opinions, evaluations, recommendations, forecasts, or suggestions (Ancillary Information) that relate to matters outside the scope of GCMLP’s management of the client’s assets. Ancillary Information typically is general in nature and does not take into account a client’s particular circumstances or needs. Therefore, Ancillary Information is not, and should not be considered, advice with respect to the purchase, sale, holding, or management of securities or other assets. Unless we expressly agree otherwise with a client, we provide Ancillary Information solely as a courtesy, and do not assume any duties to the client other than the duty to act in good faith in connection with providing Ancillary Information to the client. Administrative Services GCMLP provides a broad range of accounting and financial reporting services, tax reporting services, administrative support services, and client services (collectively, Administrative Services) for GCMLP Funds, as well as for certain investment funds whose investment portfolios are managed or advised by parties other than us (Administered Funds). These services include, but are not necessarily limited to, the following: Accounting and Financial Reporting – maintaining the official books and records of certain GCMLP Funds and Administered Funds and reporting various financial information to investors on an interim and annual basis, including the preparation of annual financial statements and the coordination of the audits of such financial statements by an independent public accounting firm. Tax Reporting – preparing, in collaboration with an independent public accounting firm, required statutory tax filings and disclosures. Administrator Relationship Management – selecting, evaluating, coordinating, and monitoring the services of independent administrators for certain GCMLP Funds and Administered Funds. Treasury Operations – authorizing or executing the movement of funds directly or through the use of administrators, as well as managing short-term cash balances, negotiating and managing credit facilities, and monitoring counterparty risk for certain GCMLP Funds and Administered Funds. Investment Implementation – Evaluating and implementing investment decisions, including executing the appropriate investment documentation for subscriptions to and withdrawals from underlying funds in which GCMLP funds invest. Client Services – assisting clients in reviewing subscription documents and processing contribution or subscription and withdrawal or redemption requests, as well as distributing regular investment performance reporting and responding to periodic client inquiries and requests. Our Assets Under Management As of December 31, 2018, our assets under management were approximately $27.7 billion. The methodology used to calculate the net asset value of client accounts that we manage differs from the methodology used to calculate “regulatory assets under management” for purposes of responding to Item 5.f(2) of Part 1 of our SEC Form ADV. Additional detail concerning the methodology is available upon request. Additionally, we provide advice on a non-discretionary basis to clients separate from such client accounts. Our Principal Owner Our principal owner is Grosvenor Capital Management Holdings, LLLP (GCM Holdings), an Illinois (USA) limited liability limited partnership. Employees and former employees of companies associated with GCM Grosvenor, as well as certain other persons formerly associated with us, indirectly own a majority interest in GCM Holdings. Michael J. Sacks, our Chairman and Chief Executive Officer owns a controlling interest in GCM Holdings through several intermediate entities that he controls and of which he is the principal owner. please register to get more info

Fees in General Except as discussed herein, GCMLP charges one of, or a combination of, the following management fees or performance-based fees or allocations to a client in connection with managing or advising a GCMLP Fund:  a percentage of assets invested or committed, of up to 2% per annum, which: › may be on a sliding or tiered scale › may be subject to a minimum, expressed in dollars or as a percentage of assets under management  a percentage of capital appreciation or profits, of up to 20%, which may be subject to a hurdle, a high watermark and/or a preferred return or outperformance of a particular benchmark return, and that may be a fixed percentage or based upon a variable index rate  an agreed-upon fixed amount In the case of the GCMLP Funds (GCMLP Seed Funds) that primarily invest capital (Seed Capital) in Underlying Funds (each, a Seed Manager Fund) managed by Investment Managers (each, a Seed Manager) that either have not yet established investment advisory firms or that operate investment advisory firms that have yet to achieve a critical mass of assets under management, in addition to one or more of the fees and allocations described above, we participate, alongside investors in GCMLP Seed Funds, in the revenue or other economics of the Seed Managers with whom GCMLP Seed Funds invest. In certain instances, GCMLP Funds may be subject to a fee from which GCMLP Funds compensate both GCMLP and the Investment Managers of the Underlying Funds. Fees for Commingled GCMLP Funds Each Commingled GCMLP Fund sets forth its fee structure, including how and when fees are calculated, charged, and paid, in an offering document (together with private placement memorandum, investment management agreement or similar, GCMLP Fund Documents) provided to each prospective investor in the GCMLP Fund prior to the prospective investment in such fund. Management fees typically are payable monthly or quarterly, either in advance or in arrears, and typically are not negotiable. Certain investors, including seed or early investors, strategic partners, and persons associated or formerly associated with us, and members of their families, as well as certain friends of such persons, may invest in GCMLP Funds on a non-fee- paying basis or at fee rates that are lower than those charged to other investors in such GCMLP Funds, in our discretion. Fees for Customized GCMLP Funds Each Customized GCMLP Fund sets forth its fee structure—including how and when fees are calculated, charged, and paid— in the GCMLP Fund Documents provided to the prospective investor in the GCMLP Fund prior to the prospective investor’s investment in the GCMLP Fund. Fees and other terms for each Customized GCMLP Fund are negotiated on a case-by-case basis with the investors in such Customized GCMLP Fund. Management fees typically are payable monthly or quarterly, either in advance or in arrears. Fees for Advisory Services Fees for Advisory Services, which are discussed in Item 4 of this Brochure, are negotiated on a case-by-case basis and may depend upon the range of hedge fund or alternative investment program advisory services and other services that we provide to a client. Depending on the scope of such services and the overall size and nature of GCMLP’s relationship with a particular client, in our discretion, we may determine not to charge additional fees for certain additional services. Aggregation of Certain Accounts for Fee Purposes If a GCMLP Fund maintains a tiered fee structure, such that the fees payable by the investor in the GCMLP Fund vary depending on the amount of the investor’s investment in the GCMLP Fund, we may in our discretion, agree with an investor to treat investments by the investor, its affiliates, and/or certain other persons in one or more GCMLP Funds as a single investment for purposes of determining the effective fee rate for such investors in respect of the GCMLP Fund. Such aggregation of an investor’s assets will result in an overall fee that is lower than would be the case in the absence of such aggregation. Deduction of Fees from GCMLP Funds In the case of Commingled GCMLP Funds, GCMLP invoices GCMLP Funds for its fees, typically monthly or quarterly, and deduct such fees, or instruct that such fees be deducted, directly from the assets of such GCMLP Funds. In the case of Customized GCMLP Funds, depending on its agreement with the relevant investor, typically monthly or quarterly, GCMLP:  invoices the relevant GCMLP Fund and deduct its fees directly from the assets of such GCMLP Fund; or  invoices the relevant GCMLP Fund and, upon the investor’s approval of its invoice, receive its fees either from the relevant GCMLP Fund or directly from the investor. Fee Refunds In cases in which an investor in a GCMLP Fund pays fees in advance and the investor terminates its investment in such GCMLP Fund in accordance with the termination provisions governing such GCMLP Fund prior to the expiration of the period for which the advance fee was paid, except as otherwise agreed with the investor, we pay an appropriate pro rata refund to the investor, or provide a pro rata credit to the investor, designed to ensure that the investor pays a fee only for the portion of the period preceding the effectiveness of the termination. Expenses Each GCMLP Fund typically pays its organizational and initial offering costs out of the proceeds of the initial offering of its securities. Each GCMLP Fund typically pays such costs and expenses as are necessary, advisable, or convenient for the conduct of its business, including, without limitation:  all costs and expenses incurred in the identification, evaluation, selection, purchase, management, sale, or exchange of investments, whether or not ultimately consummated), including, without limitation, brokerage commissions, broken- deal costs, due diligence costs, investment banking fees, monitoring costs, sourcing or finder’s fees, and research terminals  expenses relating to any Underlying Fund (including, without limitation, organizational and offering expenses)  the interest expense, fees, and other expenses associated with any borrowing facility  profit participations or other compensation of the general partners, advisers, or managers of entities in which a GCMLP Fund invests or of advisers or managers of managed accounts  fees and expenses in connection with the custody of assets of a GCMLP Fund  legal, accounting, auditing, tax and financial statement preparation, consulting, and other professional fees and expenses (including out-of-pocket expenses of a third party engaged by a GCMLP Fund or by GCMLP itself for purposes of providing these services to one or more GCMLP Funds)  administrative expenses and costs, including the fees and out-of-pocket expenses of a GCMLP Fund’s administrator  computer software licensing, development, purchasing, programming, and operating costs  fees and expenses associated with reporting to clients  other operating or administrative fees and expenses related to accounting, research, due diligence, reporting, and portfolio management services  valuation fees and expenses  Third-Party Costs as defined herein  taxes and similar amounts (if any)  extraordinary expenses (if any), including any costs and expenses arising out of a GCMLP Fund’s litigation and indemnification costs and obligations  costs and expenses of consultants engaged by GCMLP or its affiliates in connection with services provided by GCMLP or its affiliates to the GCMLP Fund  regulatory or other governmental fees and charges, including regulatory or governmental fees and charges resulting from the offering or sale of a GCMLP Fund’s securities in a non-U.S. jurisdiction)  certain travel and entertainment expenses incurred in connection with a GCMLP Fund’s affairs, including in connection with investments, and potential investments, and meetings with investors or their representatives (to the extent permissible in such Fund’s governing documents and to the extent such expenses comply with GCMLP’s Travel and Expense Policy)  all other costs specifically described in the particular GCMLP Fund’s offering documents  all other costs related to a GCMLP Fund’s investment activities GCMLP does not charge and is not reimbursed for its own overhead or other internal costs except as agreed upon in connection with a particular GCMLP Fund. In accordance with our policies and procedures and the documents governing certain GCMLP Funds, payments made to independent third-party vendors, consultants, or professional advisers (including providers of outsourced accounting, administrative, or reporting services) that directly support the ongoing management, administration, and operations of such GCMLP Funds (Third-Party Costs) are borne by such GCMLP Funds. Third-Party Costs may include, among others:  insurance expenses, which consist primarily of premium payments made to third-party insurance underwriters and brokers related primarily to fiduciary liability coverage, professional liability coverage, ERISA fidelity bond if applicable, errors and omissions coverage, and directors’ and officers’ liability coverage  operational due diligence expenses, which consist primarily of legal expenses and professional fees paid to third-party investigation firms to conduct background investigations on existing and potential Investment Managers  technology expenses, which consist primarily of software and data licensing, development, programming and operating costs paid to third-party vendors to support the operating platforms of the GCMLP Funds, as well as costs related to the licensing, usage, and redistribution of data and performance benchmarks  risk-aggregation reporting expenses, which consist primarily of fees payable to organizations that collect and aggregate exposure data from Underlying Funds and provide related reports to us in connection with our risk management process  industry expert expenses, which consist primarily of fees payable to firms that source through their member networks professionals with expertise relevant to the GCMLP Funds’ investment activities Third-Party Costs, to the extent allocable, are generally allocated to the GCMLP Funds or related groups of GCMLP Funds (e.g., all GCMLP Funds pursuing a particular strategy) on a pro rata basis in accordance with their respective net asset values, unless we decide, in our discretion and as permitted by the various GCMLP Funds’ Documents, to specially allocate such expenses to a subset of GCMLP Funds to which such expenses more specifically relate, even though they may not benefit from such expenses on a strictly pro rata basis. All costs and expenses directly attributable to one or more GCMLP Funds, and not to any other GCMLP Fund, including the costs of background investigations directly attributable to such GCMLP Funds, are charged to those GCMLP Funds and are not allocated pro rata among other GCMLP Funds in the manner discussed above. In certain limited cases, GCM Grosvenor bears all or a portion of the Third-Party Costs that otherwise would be borne by a GCMLP Fund pursuant to the principles discussed above. As an investor in Underlying Funds, each GCMLP Fund typically bears its allocable share of the Underlying Funds’ respective organizational, offering, investment, and operating expenses, including taxes, interest due on borrowings, brokerage and other transaction costs, the fees, expenses, and profit participations of the Investment Managers and any extraordinary costs incurred. The advisory fees charged by Investment Managers vary in type, amount, and structure; for example, certain performance fees or allocations are paid or made only after achieving a hurdle rate of return and others are calculated period-to-period without a high water mark. Moreover, some performance fees or allocations may be calculated after investors have received a return of capital and a preferred return, or variations of such arrangements. Most GCMLP Funds are thus subject to two levels of fees and a potentially higher expense-to-equity ratio than would be associated with an investment fund that invests and trades directly in financial instruments under the direction of a single investment manager. please register to get more info

As discussed in Item 5 of this Brochure, GCMLP accepts performance-based fees, special allocations (i.e., carried interest) or other types of performance-based compensation from certain GCMLP Funds, in addition to or in lieu of other fees. Performance-based compensation is based on a share of:  the capital gains on, profits, or capital appreciation in the value of the GCMLP Fund, which may be subject to a hurdle, a high watermark and/or a preferred return; or  the outperformance of the GCMLP Fund relative to the performance of a particular benchmark, which may be a fixed percentage or based upon a variable index rate The receipt of performance-based compensation or special allocations rewards us for increases in the value of the assets of such GCMLP Fund or the outperformance of such GCMLP Fund relative to the performance of a particular benchmark, without directly penalizing us for losses or underperformance relative to a particular benchmark, creating an incentive for us to invest and reinvest the assets of such GCMLP Fund in a manner that may be riskier or more speculative than would otherwise be the case. GCMLP Funds may issue more than one class of securities, and, in some cases, certain classes of securities issued by a GCMLP Fund may bear performance-based compensation or special allocations while other classes do not. Because we manage the assets of a GCMLP Fund as a single pool of assets, all investors in such GCMLP Fund are subject to the risk discussed in the preceding paragraph and not just those investors who invest in classes of securities that bear performance- based compensation or special allocations. Similarly, in some cases, two or more feeder funds managed or advised by us may invest all or substantially all of their assets in a master fund managed or advised by us. In these cases, one or more of the feeder funds that invest in a particular master fund may pay performance-based compensation or special allocations to us while other feeder funds that invest in such master fund do not. In these cases, all investors in the feeder funds are subject to the risk discussed above—not just those investors who invest in the feeder funds that bear performance-based compensation or special allocations—because we manage the assets of such master fund as a single pool of assets. GCMLP may have an incentive to allocate certain investment opportunities to GCMLP Funds from which we receive performance-based compensation or special allocations, in preference to GCMLP Funds from which we do not receive performance-based compensation or special allocations, because we may stand to gain greater compensation from the former types of GCMLP Funds by allocating the best investment opportunities to them. We have adopted detailed investment allocation policies and procedures designed to provide fair and equitable allocation of investment opportunities in Underlying Funds among all eligible accounts. Additionally, Investment Managers of Underlying Funds may from time to time make us aware of opportunities to co-invest in specific underlying investments (i.e., investments other than investments in Underlying Funds). These co-investment opportunities may be allocated at our discretion, including to GCMLP Funds eligible to invest in such opportunities or to investors in GCMLP Funds. please register to get more info

GCMLP has three basic types of clients: Type 1: GCMLP Funds organized as legal entities. Some GCMLP Funds are privately offered and are not subject to registration under the Investment Company Act of 1940 (as amended, the ICA). Others are open-end or closed- end investment companies registered under the ICA and publicly offer their securities. Some are Commingled GCMLP Funds, while others are Customized GCMLP Funds. Some GCMLP Funds are feeder funds that invest all or substantially all of their assets in master GCMLP Funds. Feeder funds may be Commingled or Customized GCMLP Funds and may invest their assets in master GCMLP Funds that are Commingled or Customized GCMLP Funds. Type 2: Institutional investors, such as public or private pension plans or sovereign wealth funds, entering into discretionary or non-discretionary investment management agreements, investment advisory agreements or similar agreements with us rather than investing in GCMLP Funds organized as legal entities. Type 3: Institutional investors that we assist, on a non-discretionary basis, in designing, building, and managing their hedge fund or alternative investment programs. This service does not typically constitute continuous and regular supervisory or management services. GCMLP generally requires a minimum initial investment of $100,000,000 for launching or maintaining a Customized GCMLP Fund, but we have reduced and may in the future reduce this requirement in our discretion. The minimum initial investment for a particular Commingled GCMLP Fund is set forth in the GCMLP Fund Documents for such Commingled GCMLP Fund. please register to get more info

Our Investment Process Except as related to certain programs as described herein, Other Investment Management and Advisory Services, which may have different designated investment committees and investment processes that are described therein, GCMLP’s investment process is overseen by the Investment Committee and implemented by our Investments Department, which is comprised of three functional teams:  The Research Team is responsible for strategy research, investment due diligence, and monitoring of Investment Managers and Underlying Funds.  The Portfolio Management Team consists of investment professionals assigned to separate Portfolio Management Teams, each responsible for the day-to-day management of a set of GCMLP Funds assigned to such team. The Portfolio Management Team assigned to a GCMLP Fund constructs the initial portfolio (subject to approval by a Portfolio Committee, which consists of two senior investment professionals), evaluates such GCMLP Fund’s portfolio composition on an ongoing basis and proposes allocation changes for such GCMLP Fund to the Portfolio Committee. The Portfolio Management Teams communicate with clients to discuss performance, outlook and proposed portfolio changes.  The Risk Management Team works with GCMLP’s Research and Portfolio Management Teams to perform risk management assessments of investment strategies, Investment Managers, Underlying Funds, and GCMLP Funds. The Risk Management Team has three primary responsibilities: › conducting independent risk management due diligence and monitoring of Investment Managers and their Underlying Funds › performing risk management analytics on GCMLP Funds, Underlying Funds and clients’ full hedge fund or alternative investment programs › developing proprietary risk management tools The Investment Committee, with input from the Research, Risk Management, and Portfolio Management Teams, develops its outlook for investment strategies and underlying exposure categories based upon its evaluation of the risk/reward profiles of such investment strategy or underlying exposure category. The Investment Committee’s outlook for such investment strategies and underlying exposure categories determines guidelines specifying the target percentages of assets—usually determined as a range—that the Portfolio Management Teams generally follow in proposing portfolio allocations to particular investment strategies and underlying exposure categories. The Investment Committee, in connection with approving particular Underlying Funds and from time to time thereafter, determines guidelines specifying the target percentages of assets—usually determined as a range—to assist the Portfolio Management Teams in proposing initial and subsequent portfolio allocations to a particular Underlying GCMLP Fund or Underlying Funds managed by a particular Investment Manager. The Operations Committee oversees GCM Grosvenor’s operational risk framework. The Operations Committee also generally reviews and approves, from an operational perspective, prospective investments. The Operations Committee works collaboratively with, but is independent of, the Investment Department to ensure the separation of duties between investment and operational due diligence.  The Operational Due Diligence Team evaluates Investment Managers/Underlying Funds from an operational and legal perspective. The Operational Due Diligence Team’s responsibilities include: › evaluating the people, processes, and systems that support the Investment Manager’s infrastructure and operations › reviewing and analyzing relevant legal and regulatory documentation › utilizing independent third-party investigative firms to perform background checks of the Investment Manager, its key personnel, its target Underlying Funds, and the independent directors of such target Underlying Funds Due diligence  Investment Due Diligence If the co-heads of the Research Team authorize full due diligence with respect to a potential Investment Manager and Underlying Fund, we assign an Investment Due Diligence Team to that Investment Manager and Underlying Fund, which is responsible for assessing: › certain qualitative factors relating to the potential Investment Manager, such as its investment philosophy, investment mandate and investment decision-making structure, the skills and commitment of its key professionals, its depth and breadth of experience in the relevant investment strategy, its investment and risk management processes, and its organizational infrastructure and its stability › the quality of such potential Investment Manager’s and Underlying Fund’s historical returns  Risk Management Due Diligence The Risk Management Team performs due diligence separately from the Research Team to assess the risk management processes, both quantitatively and qualitatively, and systems of Investment Managers and to analyze the risk and exposure of the Underlying Funds managed by the Investment Managers.  Operational Due Diligence The Operational Due Diligence Team evaluates a potential Investment Manager’s operational infrastructure and the overall design of the Investment Manager’s internal control environment. This evaluation includes a review of the audited financial statements of the target Underlying Fund managed by such Investment Manager, if available, and evaluation of the audit firm engaged by such Investment Manager to audit such target Underlying Fund. The Operational Due Diligence team will also conduct background checks on Investment Managers and their key personnel using an external service provider. Investment Committee and Operations Committee Approval The Investment Committee currently has four members who are senior investment professionals and makes decisions by majority vote. The Chief Executive Officer has the authority to determine the outcome in the event of a tie and the authority to veto any affirmative decision made by the Investment Committee. However, if the Investment Committee rejects or terminates an Investment Manager or Underlying Fund, the Chief Executive Officer cannot override such rejection or termination. The Operations Committee currently has four members who are senior members of GCM Grosvenor and makes decisions by majority vote. Our Chief Executive Officer has the authority to veto any affirmative decision made by the Operations Committee. However, if the Operations Committee rejects or terminates an Investment Manager or Underlying Fund, our Chief Executive Officer cannot override such rejection or termination. The Investment Committee approves Underlying Funds from an investment and risk perspective, and the Operations Committee approves from an operational perspective, before we may invest the assets of any client or recommend to a client that it invest its assets in such Underlying Funds, except where expressly agreed upon with the particular client, or where the particular GCM Grosvenor Fund’s Documents state otherwise. Such approvals may be limited to a particular client’s or group of clients’ portfolios under certain circumstances rather than for all client portfolios. The Portfolio Committee reviews and approves initial and subsequent portfolio allocations proposed by each Portfolio Management Team for each GCMLP Fund assigned to such Portfolio Management Team. Our Chief Executive Officer has a veto right over portfolio management activity for the GCMLP Funds. The size and composition of the Investment Committee and Operations Committee may change from time to time. Allocation of Investment Opportunities We allocate investment opportunities among eligible GCMLP Funds and investment vehicles managed or advised by our affiliate GCM CFIG (GCM CFIG Funds, collectively with GCMLP Funds, GCM Grosvenor Funds) in a manner that we deem to be fair and equitable, and may take into account a variety of relevant factors. We may have an incentive to allocate certain investment opportunities to GCM Grosvenor Funds from which we receive performance-based compensation or special allocations, in preference to GCM Grosvenor Funds from which we do not receive performance-based compensation or special allocations, because we may stand to gain greater compensation from the former types of GCM Grosvenor Funds by allocating the best investment opportunities to them. We and GCM CFIG, have adopted global investment allocation policies and procedures designed to result in the fair and equitable allocation of investment opportunities in Underlying Funds among all eligible GCM Grosvenor Funds. Additionally, Investment Managers of Underlying Funds may from time to time make us aware of opportunities to co-invest in specific underlying investments (i.e., investments other than investments in Underlying Funds). These co-investment opportunities may be allocated at our discretion, including to GCMLP Funds eligible to invest in such opportunities or to investors in GCMLP Funds. Other Investment Management and Advisory Services  Strategic Investments Group Investment professionals organized as the Strategic Investments Group (SIG Professionals) focus on: (i) identifying, and performing investment due diligence with respect to, prospective investment ideas or investment themes; (ii) monitoring the investments or investment themes on an ongoing basis; and (iii) managing and adjusting position sizes, potentially on a daily basis. In addition to these responsibilities, the Strategic Investments Group manages the Special Opportunities Program, MAC Opportunities, and MAC Portfolios each as defined herein.  Special Opportunities Program The Special Opportunities Program seeks to provide exposure to Strategic Investments. For this program, SIG Professionals focus on: (i) identifying, and performing investment due diligence with respect to, prospective investment ideas or investment themes; (ii) monitoring the investments or investment themes on an ongoing basis; and (iii) managing and adjusting position sizes, potentially on a daily basis. There are generally no restrictions on the types of investments in which the Special Opportunities Program may invest, except as otherwise may be required or prohibited by applicable law or policy. In selecting investments for the Special Opportunities Program, the Special Opportunities Investment Committee (SOIC) relies on advice from the SIG Professionals. The SOIC considers factors in selecting investments for the Special Opportunities Program that may differ from the factors taken into consideration by the Investment Committee in selecting investments for other GCMLP Funds.  The Operations Committee generally will evaluate and approve Strategic Investments where it deems such evaluation appropriate, but does not evaluate and approve all Strategic Investments.  Private Equity, Real Estate, and Infrastructure Investments GCM Grosvenor invests assets of certain GCMLP Funds in long-term private equity, real estate, and infrastructure investments, which the PEREI Investment Committee and typically the Operations Committee must approve. These investments may include: › Investments in Underlying Funds acquired directly from Investment Managers at or near inception during the fundraising period (Primary Fund Investments) › Investments in Underlying Funds acquired in secondary market transactions (Secondary Investments) › Co-Investments › Direct Investments  Multi Asset Class Portfolios GCM Grosvenor invests assets of certain GCMLP Funds across multiple asset classes (MAC Portfolios), including hedge funds, private equity, real estate, and infrastructure (MAC Opportunities). With respect to MAC Portfolios, SIG Professionals focus on: (i) identifying, and performing investment due diligence on prospective MAC Opportunities, and (ii) monitoring the MAC Opportunities on an ongoing basis. In selecting investments for the MAC Portfolios, the MAC Investment Committee (MAIC) relies on advice from the SIG Professionals. The factors taken into consideration by the MAIC in selecting investments for MAC Portfolios may differ from the factors taken into consideration by the Investment Committee in selecting investments for other GCMLP Funds, or by factors taken into consideration by GCM CFIG in selecting investments for GCM CFIG Funds. The Operations Committee generally will evaluate and approve MAC Opportunities where it deems such evaluation appropriate, but does not evaluate and approve all MAC Opportunities. GCMLP may involve one or more affiliates of GCMLP in evaluating investments for the MAC Portfolios.  Labor Impact Program The Labor Impact Infrastructure Program (Labor Impact Program) seeks to originate and execute infrastructure investments (Labor Impact Investments) that leverage GCM Grosvenor’s relationships with, understanding of, and experience in organized labor, government, and finance. The Labor Impact Program’s mandate requires that an investment meet a risk/return standard and utilize value-additive union labor. The Labor Impact Program will consider investments across core, core-plus, and opportunistic infrastructure assets, and businesses through direct investments and partnerships with other financial market participants, as well as partnerships/joint ventures with operators, construction firms and governmental entities. The Labor Impact Program seeks to selectively invest across various subsectors of infrastructure in both greenfield, and brownfield investments and will also opportunistically invest in certain real estate assets that have infrastructure-like characteristics. The Labor Impact Fund Investment Committee (LIFIC) is responsible for the selection of the transactions in which the Labor Impact Program participates. GCMLP may involve one or more affiliates of GCMLP in evaluating investments for the Program. In selecting investments for the Labor Impact Program, the LIFIC incorporates information and advice from the SIG Professionals, among others.  Seeding Transactions GCMLP Funds, as well as GCM Grosvenor acting for its own accounts, may enter into agreements under which GCMLP Funds or GCM Grosvenor invest in Seed Manager Funds and/or provide capital or debt financing to Seed Managers in exchange for certain benefits, referred to as Seeding Transaction Benefits (Project Agreements). Typically, the only consideration for receiving Seeding Transaction Benefits is the investment for a specified period of time by the participating GCMLP Fund or GCM Grosvenor proprietary capital in the Seed Manager Fund managed or advised by the Seed Manager. In certain cases, however, a GCMLP Fund or GCM Grosvenor may provide capital or debt financing to a Seed Manager in exchange for Seeding Transaction Benefits. GCMLP currently manages one GCMLP Seed Fund that has entered into Project Agreements and invested in Seed Manager Funds as a principal part of its business. We may manage additional GCMLP Seed Funds of this type in the future and other GCMLP Funds may invest Seed Capital with Seed Managers on an ad hoc basis. The Seed Fund Investment Committee (SFIC) is responsible for the selection of the Seed Capital transactions in which the GCMLP Seed Funds will participate. The Investment Committee, or other investment committees, rather than the SFIC, may be responsible for the selection of Seed Capital transactions for GCMLP Funds that are not GCMLP Seed Funds. In evaluating prospective Seed Capital transactions, the SFIC relies on advice from certain investment professionals focused on the Seed Fund (Seed Fund Investment Professionals), as well as members of the Operational Due Diligence Team. The Operations Committee must approve all Seeding Transactions proposed to be made by a GCM Seed Fund from an operational perspective.  Placing Assets Under the Management of Seed Managers We may invest the assets of GCMLP Funds, as well as GCM Grosvenor proprietary assets, directly or indirectly by investing in a GCMLP Seed Fund or other GCMLP Fund in: (i) Seed Manager Funds and/or Seed Managers; and/or (ii) investment opportunities made available by Seed Managers, but which they consider to be outside the scope of their respective investment mandates. Except as otherwise provided in the operative documents of a GCMLP Fund or agreed between an investor and us: › we have no obligation to make available to any GCMLP Fund, or to any investor, any opportunity to enter into a Project Agreement, or to invest in any Seed Manager Fund or Seed Manager › Subject to the GCMLP Funds’ Documents, the requirements of applicable law and such policies, if any, as we may from time to time adopt, and retain sole discretion to determine: – the extent to which any GCMLP Fund enters into Project Agreements and invests in Seed Manager Funds or Seed Managers – the terms on which such GCMLP Fund will do so Investments in Seed Manager Funds or Seed Managers may be made available to GCMLP Funds notwithstanding the fact that one or more GCMLP Seed Funds or other GCMLP Funds have entered into Project Agreements involving such Seed Manager Funds or Seed Managers. In certain cases, a Project Agreement may entitle a GCMLP Seed Fund, as well as investors in such GCMLP Seed Fund, to invest in a Seed Manager Fund on terms that are more favorable than those available to the Seed Manager Fund’s other investors, typically with discounts from a standard fee schedule. Accordingly, if other GCMLP Funds invest in such Seed Manager Fund, they may do so on terms that differ from, and may be less favorable than, those available to the applicable GCMLP Seed Fund. GCM Grosvenor may provide back-office and administrative services to Seed Managers pursuant to service level agreements at what we believe to be arm’s-length prices. While GCM Grosvenor will have the opportunity of entering into such service level agreements with Seed Managers only because of the Seed Capital provided by the applicable GCM Seed Fund, such GCM Seed Fund will not share in any of the revenues GCM Grosvenor receives under any such service level agreement.  Temporary Investments and Hedging Transactions Except to the extent that the governing documents relating to a GCMLP Fund expressly provide otherwise, we may from time to time: › invest, for cash management purposes, cash held by such GCMLP Fund (pending investment by such GCMLP Fund or distribution to its investors) directly in securities and other financial instruments such as: – U.S. government and agency securities – bank demand deposit accounts—which may or may not be interest bearing—and certificates of deposit – commingled investment products (such as money market mutual funds) › cause such GCMLP Fund to engage in hedging transactions by purchasing or selling securities or derivative instruments with the intent of reducing certain exposure—for example, by: – purchasing or selling securities or derivatives with the intent of reducing certain exposures – entering into foreign currency forward contracts to hedge currency risk on behalf of such GCMLP Fund if such GCMLP Fund is denominated in a currency other than U.S. Dollars (e.g., Japanese yen, euro, Swiss franc), but invests primarily in U.S. dollar-denominated Underlying Funds, or if such GCMLP Fund is denominated in U.S. dollars and invests in Underlying Funds or individual securities that are denominated in currencies other than the U.S. dollar These temporary investments and hedging transactions are ancillary to the primary hedge fund or alternative investment program of the affected GCMLP Funds. Modifications of Our Investment Process The discussion herein summarizes the investment process, investment services, and strategies in effect as of the date of this Brochure. We have previously modified the investment process, investment services, and strategies and expect to continue to modify investment process, investment services, and strategies from time to time. We may make substantive modifications to our investment process, investment services, and strategies without notice to clients. Investment Strategies GCMLP currently manages or advises portfolios that pursue the following investment strategies:  broadly diversified, multi-strategy  global long/short equity  U.S. long/short equity  global macro  commodities  global credit  completion (weighted toward strategies under- represented in clients’ portfolios)  hedge fund seeding  multi-asset class  private equity, real estate, and infrastructure  labor impact  opportunistic (a blend of several of the strategies herein)

GCMLP classifies each Underlying Fund approved by the Investment Committee into a specific strategy and sub-strategy category based upon such Underlying Fund’s primary investment strategy. The current strategy and sub-strategy categories are as follows:  Credit Strategies › Fundamental credit › Structured credit › Long-short credit › Distressed credit › Emerging market credit › Specialist credit  Relative Value Strategies › Convertible arbitrage › Fixed income arbitrage › Option volatility arbitrage › Diversified relative value  Equity Strategies › Directional equity › Low-net equity › Fundamental market neutral equity › Activism › Event driven › Emerging market equity › Specialist equity  Quantitative Strategies › Directional quantitative strategies › Non-directional quantitative strategies  Multi-Strategy  Macro Strategies › Diversified macro › Emerging market macro › Specialist macro  Commodities Strategies › Diversified commodities › Specialist commodities  Portfolio Hedging Strategies › Dedicated short equities › Dedicated short credit › Volatility protection › Opportunistic hedging  Strategic Investments Group Strategies › Direct investments › Co-investments  Private Markets Strategies › Private equity › Real estate › Infrastructure › Co-investment opportunities › Secondary investments

Our broadly diversified, multi-strategy portfolios pursue a broad range of the various strategies. Our global long/short equity portfolios focus primarily on investing and trading in equity securities of both U.S. and non-U.S. issuers, our U.S. long/short equity portfolios focus primarily on investing and trading in equity securities of U.S. issuers (see Equity Strategies). Our global credit portfolios primarily pursue the types of strategies discussed under Credit Strategies. While certain portfolios may primarily pursue a single strategy, all portfolios may pursue one or more of the various strategies discussed herein. GCMLP may from time to time change its strategy classification framework, or reclassify the particular strategy or sub- strategy pursued by an Underlying Fund, in either case without notice to clients, using reasonable discretion. Further, we may classify or re-classify a particular Underlying Fund as pursuing a particular strategy or sub-strategy even though such Underlying Fund may not invest all of its assets in accordance with such strategy or sub-strategy. Credit Strategies Credit strategies include directional and hedged investments in debt securities, credit derivatives, and related instruments. The primary investment approaches include long/short credit, fundamental credit, specialist credit, distressed credit and structured credit. Credit strategies, although diverse, can exhibit highly correlated losses during certain market periods. Fundamental credit consists primarily of diversified credit portfolios that may engage in a wide range of investment approaches including, but not limited to distressed investing, high-yield credit, and direct lending. Investment managers assigned to this category typically have a net credit exposure greater than 50% net long.  Distressed investing consists primarily of long and short directional investments in securities of companies that are in various stages of financial difficulty, including bankruptcy. The goal of the strategy is to earn an attractive absolute rate of return through investing in specific events with limited exposure to broad market fluctuations. Investment managers seek to capitalize on market opportunities resulting from a lack of information, illiquidity, excessive selling pressure, and complexity of capital structures or securities.  High-yield credit involves taking long positions in levered loans or high-yield bonds. The positions in this sub-strategy are motivated primarily by fundamental credit views that also may consider technical market factors such as short-term supply/demand imbalances. An investment manager may be long an issuing company’s credit either by investing directly in bonds or loans or by establishing a synthetic long position or short position through a credit default swap (CDS).  Direct lending investments are primarily in debt securities of issuers that require capital for growth, acquisitions, recapitalizations, or changes of control. Such securities include first and second lien loans, as well as subordinated debt, which may include an associated equity component such as warrants, preferred stock, or other similar securities. The investment manager directly originates these loans, which typically include relatively high coupons and generous structuring fees. In order to compensate for the less liquid nature of the instruments and other inherent risks of direct lending, direct financing arrangements often will be collateralized with assets, include restrictive covenants and provide upside equity participation. Structured credit consists of investments in residential mortgage-backed securities, commercial mortgage-backed securities, asset-backed securities, and corporate credit-related structured credit instruments such as collateralized debt obligations (CDO). Trade selection is based on fundamental analysis of the underlying assets as well as analysis of the structured credit vehicle, including such vehicle’s cash flow waterfall. Long-short credit consists primarily of long-short credit, correlation trades, and credit volatility arbitrage.  Long-short credit involves taking long and short positions that reflect relative-value views between, or among, different credits, groups of credits, sectors, or indices. The positions in this sub-strategy typically are motivated by fundamental credit views with an appreciation for market technicals. One example of a long/short credit trade is a pairs trade in which the investment manager may be long a company’s CDS and short a competitor’s CDS. Not all positions entail related credits; for example, an investment manager may construct a portfolio that is long a basket of telecom credits via a CDS and short a basket of financial services credits via a CDS.  Correlation trades involve arbitraging perceived mispricings in baskets or portfolios of credits versus the individual components of the basket, an index, or a highly-correlated derivative of the basket. Frequently, the trade is structured to be neutral to credit spread movements in the broad market. The securities used in the arbitrage may include CDOs, synthetic CDOs, bespoke CDS baskets, credit indices and individual CDSs. Synthetic CDOs are similar to CDOs, except that the credits are included in the pool via CDS contracts instead of cash bonds. Bespoke CDS baskets represent a collection of credits that are selected individually to create a customized hedge of specific portfolio risks. These instruments are less liquid due to their customized nature.  Credit volatility arbitrage typically involves buying and selling options on credit spreads of individual companies or on traded indices. An investment manager also may buy and sell volatility across various asset classes. For example, an investment manager may sell volatility via options on credit spreads and buy volatility on the same company via the equity markets. Distressed credit consists of underlying funds that are explicitly focused on capturing opportunities in distressed situations primarily in corporate capital structures and at times within sovereign credits. This may range from buy-and-hold fundamental value identification to distressed activism, capital structure arbitrage within stressed or distressed capital structures, or various forms of documentation arbitrage. Emerging market credit consists of underlying funds that opportunistically investing in stressed, distressed, and other value- oriented investments in emerging markets on a dedicated basis. Such investments may extend across the corporate capital structure and could periodically include more junior claims. Additionally, emerging market credit investments may at times include sovereign credit or rate positions, both long and short, either as value investment opportunities or as portfolio hedging tools. Specialist credit consists of a variety of underlying strategies that tend to focus on niche subsets of global credit and fixed income markets. These will typically seek to exploit idiosyncratic mispricings or structural return premia available within the identified market segment. Examples of specialist credit strategies include, but are not limited to, aviation finance, litigation finance, origination platforms, and trade finance. Relative Value Strategies Relative value strategies include diversified relative value, convertible arbitrage, fixed income arbitrage, and option volatility arbitrage. Diversified Relative Value Diversified relative value strategies consist primarily of highly diversified multi-asset class portfolios that may engage in a wide range of investment approaches including, but not limited to convertible arbitrage, fixed income arbitrage and option volatility arbitrage, as well as a range of other strategies. Diversified relative value strategies will typically exhibit a low beta and correlation profile to traditional equity and fixed income benchmarks. Convertible Arbitrage Convertible arbitrage strategies include a variety of strategies involving investments in convertible securities that investment managers perceive to be undervalued from a fundamental or volatility perspective. The primary convertible arbitrage strategies include, but are not limited to: long volatility or gamma trading, catalyst or event driven investing and credit sensitive investing. In general, a position in each particular strategy involves taking a long position in convertible bonds or convertible preferred shares and short positions in the underlying common stock into which the convertible securities are exchangeable, in order to isolate the aspect of the security that the investment manager believes is mispriced and largely eliminate the effect of directional moves in the underlying stock price.  Long volatility or gamma trading primarily involves taking positions where the investment manager perceives that the volatility level of the underlying security implied by the price of the convertible security is too low relative to historical or expected future volatility of the security. The investment manager typically will fully hedge the long convertible position by shorting the appropriate amount of the underlying security and generally will make a profit if the underlying security exhibits high volatility. In the trades, the investment manager typically seeks to hedge interest rate and credit risk by using interest rate futures or swaps and credit derivatives.  Catalyst or event driven investing involves taking positions where the investment manager expects that a catalyst or event will cause the implied volatility of the convertible bonds or the actual volatility of stock price changes to increase. Such catalysts may include new product announcements, litigation, management changes, or regulatory approval of a new drug. The investment manager typically will seek to hedge interest rate and credit risk by using interest rate futures or swaps and credit derivatives.  Credit sensitive investing involves taking positions where the investment manager expects that the financial condition of the underlying company will improve and credit spreads of the convertible bond will narrow. Such a view may be based on improved trends in earnings, refinancing of existing debt or the selling of assets. The credit risk of such a position typically will be largely unhedged. Fixed Income Arbitrage Fixed income arbitrage includes a variety of strategies involving investments in fixed income instruments designed to: (i) eliminate or reduce exposure to changes in the level of interest rates; (ii) profit from perceived dislocations (e.g., anomalous yield differences) between related sets of fixed income securities. Examples of types of fixed income arbitrage trades include the following: yield curve arbitrage, swap spreads versus government yield spreads, cash versus futures basis trades, U.S. government agency debt versus U.S. Treasuries and the trading of agency mortgage derivatives. Option Volatility Arbitrage Option volatility arbitrage strategies trade volatility as an asset class. Exposures may be long, short, or neutral to the direction of implied volatility. Option volatility arbitrage strategies may be either directional or relative value in nature. Specifically, directional volatility arbitrage strategies seek to express a view on the likely trend of implied volatility across various asset classes including equities, foreign exchange, interest rates, and commodities, whereas relative value volatility arbitrage strategies seek to exploit mispricings between multiple options, or instruments containing implied volatility. Option volatility arbitrage managers typically invest in liquid instruments including options and variance swaps. Multi-Strategy Multi-strategy investment involves the combination of one or more of the strategies described herein in an effort to reduce volatility and mitigate strategy and market risks. Equity Strategies Equity strategies generally focus on the purchase or short sale of equity and equity-linked instruments in global markets. An equity investment manager may focus on a particular capitalization range (e.g., small cap versus large cap) or a particular industry sector (e.g., healthcare, technology, or consumer), may employ a specific investment style (e.g., value versus growth) or may pursue a broad mandate, investing in securities without specific regard for their issuers’ capitalization, sector or geography. Some investment managers may employ an activist approach whereby they attempt to influence company management to take specific measures to maximize shareholder value, while others may utilize top-down macroeconomic analysis to guide capital-allocation strategies and fundamental security selection. An equity investment manager typically seeks to capitalize on discrepancies between such investment manager’s own evaluation of the intrinsic value of an equity security and assessment of the forward-looking prospects of the issuer of such security and the consensus view reflected in the market price of such security. Some investment managers also may seek to extract value by being more trading-oriented or catalyst-driven. To the extent that GCMLP Funds invest with equity investment managers, we focus and expect to continue to focus on investment managers that primarily employ hedged equity investment strategies. A hedged equity investment manager typically implements its particular investment strategy by establishing long and short positions in equity or equity-linked instruments. However, while hedged equity investment managers typically focus on establishing both long and short positions, some of these investment managers may focus exclusively on establishing long or short positions. In addition to selling securities short, an equity investment manager may seek to hedge portfolio exposure by using instruments such as exchange-traded funds, equity-linked options, index options, and futures. Additionally, an investment manager may at times hold a portion of the portfolio in non-equity securities, including, but not limited to, preferred or convertible securities, equity options or at times fixed income instruments, though it is expected these exposures will represent a relatively minor portion of the portfolios’ overall exposure. An equity investment manager also may seek to manage risk by adopting top-down constraints on leverage, limits on net market exposure, net regional exposure and net sector exposure, position size limits, position stop-loss limits and parameters relating to the number of its positions. Equity sub-strategies include directional equities, low-net equities, fundamental market neutral equities, activism, and specialist equity. Directional equity Directional equity strategies consist primarily of diversified generalist equity portfolios that may engage in a wide range of equity investment approaches. Investment managers assigned to this category will often have net long equity exposure in excess of 50%. Low-net equity Low-net equity strategies consist primarily of diversified generalist equity portfolios that may engage in a wide range of equity investment approaches. Investment managers assigned to this category typically have a net equity exposure greater than 50% net long in most market environment and may at times have net short portfolio exposure. Fundamental market neutral equity Fundamental market neutral equities consist primarily of portfolios that exercise a multi-portfolio manager investment approach and maintain a closely beta and factor hedged portfolio in most market environments, with underlying investment decision primarily based on fundamental security analysis (as opposed to various forms of quantitative analysis). Investment managers assigned to this category typically have a risk adjusted net equity exposure that will average close to zero over a full market cycle. Activism Within the equity strategy, activism primarily entails relies on the ability of a manager to acquire a significant economic stake that will most frequently be held in the voting equity instruments of the company in order to influence management and corporate decisions in such a way as to increase the value of the holdings. Examples include seeking management changes, selling business units, securing special dividends and influencing financial restructurings. Event driven strategies Event driven strategies include investing in spin-offs, stub-trades, post-restructuring equities, post-bankruptcy equities, risk (merger) arbitrage, litigation equity trades, and recapitalizations. A post-restructuring equity investment involves purchasing the equity of a company that has completed a recent restructuring, most commonly as part of a bankruptcy plan. Spin-offs are subsidiaries of large public companies that are distributed to investors as a means of enhancing shareholder value. Risk arbitrage is a strategy that seeks to capitalize on perceived pricing discrepancies, or spreads, in the equity securities of two companies involved in announced corporate transactions, such as mergers, tender or exchange offers, reorganizations, liquidations and recapitalizations. For merger transactions, the strategy typically entails buying the security of the company being acquired, while simultaneously selling short the security of the acquirer. When a merger deal is pending, uncertainty about the outcome typically creates a pricing disparity; the stock of the target company typically sells at a discount to the expected acquisition price. Investment managers investing in merger arbitrage seek to capture the spread between the current stock price and the price upon the completion of the deal. In a cash or tender transaction, the investment manager seeks to capture the spread between the tender price and the price at which the target company’s stock is trading. Emerging market equity Emerging market equity strategies consist of funds focused specifically on investing in emerging markets. This may include a variety of portfolio construction methodologies and underlying investment techniques. Emerging market investing may differ in the risk/return, liquidity, legal infrastructure and accounting profile of underlying corporate reporting as compared to similar portfolio construction techniques deployed in developed equity markets. Specialist equity The specialist equity strategy consists largely of niche sector, regional and market focused funds across a range of portfolio construction approaches. These strategies will typically seek to leverage a narrow, focused investment approach to isolate uncorrelated return streams within a particular sub-set of global equity markets, or generate attractive risk adjusted exposure to a specific market opportunity. Examples of specialist equity strategies include, but are not limited to, healthcare, energy, and other sector focused funds, as well as regionally focused equity strategies. Macro Strategies Global macro includes a variety of strategies involving investments based on analysis, expectations and forecasts of macroeconomic trends; government and central bank policies; various macroeconomic or geopolitical events; and overall themes impacting regions, countries, sectors, or specific companies and the resulting impact on global capital markets. Specifically, trades within these strategies are typically based on analysis of broad factors including: governmental and central bank policies, political changes, deficit trends, trade imbalances, interest rate trends, commodity price trends, global investor sentiment and inter-country government relations. Global macro strategies may be diversified in nature trading across a wide range of asset classes globally or may be specialized to focus on particular regions, or sub-sets of tradeable macroeconomic asset classes, such as currencies or rates. Commodity Strategies Investing in commodities includes a variety of strategies involving investments based on the evaluation of market data and relationships as they pertain to commodity markets, including, but not limited to, energy, agriculture, resources, and metals. Managers pursuing these strategies analyze a number of factors including supply and demand, legislative and environmental policy changes, trends in growth rates and resource consumption, changes in global monetary and trade policy, geopolitical events, and technical factors. GCMLP considers and evaluates commodity investment managers that perform fundamental research and make discretionary trading decisions as well as managers that employ systematic investment processes designed to make investment decisions based on mathematical, algorithmic, or technical models. Commodity investment managers generally seek to anticipate changes in market fundamentals and prices or identify situations where prices do not properly reflect fundamentals. Quantitative Strategies Quantitative strategies include funds that primarily use quantitative mathematical models to identify and implement underlying portfolio investments. Such quantitative mathematical models rely on patterns inferred from historical prices and other financial data in evaluating prospective investments. These formulas and models are typically developed and implemented using high-powered computers that may generate buy or sell indications to assist the manager in identifying securities and other financial instruments which appear mispriced based on the underlying models, furthermore, these systems will often implement buy or sell orders directly to brokers. The models used are often highly complex and rely on quantitative (and to a lesser extent, technical) analysis of large amounts of real-time and historic data with a view towards identifying pricing discrepancies, inefficiencies and/or anomalies. In addition to the models described above, quantitative strategies may also employ models that focus more on fundamental analysis and research conducted by analysts (rather than computer-based quantitative and technical analysis) and models that combine two or more types of analysis in varying degrees. Fundamental analysis and research explores, among other things, issuers, industries, current market and financial conditions and an understanding of the drivers of change within these areas. Such fundamental analysis and research is expected to be generated by substantial numbers of external investment professionals, data vendors, market participants and/or other consultants and may be augmented by a manager’s internally generated fundamental analysis. The investment manager may apply systematic mathematical formulas to such analysis and research, or, may use such analysis and research alone, without further quantitative analysis to assist in developing their quantitative investment decision-making process. Portfolio Hedging Strategies If conditions warrant, GCMLP may employ four primary hedging strategies: dedicated short equity, dedicated short credit, volatility protection, and opportunistic hedges. Dedicated Short Equity Short equity strategies involve the short sale of equity and equity-linked instruments in global markets that would profit in the event of a decrease in the price of such securities. A dedicated short equity investment manager may focus on a particular capitalization range (e.g., small cap versus large cap) or a particular industry sector (e.g., healthcare, technology, or consumer), may employ a specific investment style or may pursue a broad mandate (e.g., selling securities short without specific regard for their issuers’ capitalization, sector or geography). Some investment managers may employ a top-down macroeconomic analysis to guide their capital-allocation strategies or fundamental security selection. Investment managers that pursue this strategy typically seek to capitalize on discrepancies between such investment manager’s own evaluation of the intrinsic value of an equity security and assessment of the forward-looking prospects of the issuer of such security and the consensus view reflected in the market price of such security. Some investment managers also may seek to extract value by being more trading-oriented or catalyst-driven. Dedicated Short Credit Dedicated short credit involves shorting individual investment-grade or high-yield credits that exhibit either perceived anomalous pricing relative to similar credits or perceived weakening fundamentals with a high probability of credit deterioration. The short position typically is established using a credit default swap (CDS). In addition to using a single-name CDS to short specific issuers, an investment manager also may use specific indices to short credit markets or specific sectors in aggregate. Volatility Protection Volatility protection strategies are portfolio hedging strategies that are designed to provide convex payoffs during extreme market crises. Volatility protection strategies generally invest in highly liquid financial derivatives and other securities that are expected to be profitable when global capital markets decline precipitously and volatility rises sharply. The generic types of volatility protection trades include, but are not limited to, the following: equity index puts and put spreads at various strike points, credit index protection positions at various strike points, volatility based securities such as variance swaps and Chicago Board of Trade Volatility Index options, directional currency positions and directional commodity positions. While volatility protection strategies are expected to provide positive returns when global capital markets decline significantly, they are a form of portfolio insurance and, as such, are expected to perform poorly, and could potentially lose all or substantially all capital allocated to them, when global capital markets are stable or upward-trending while providing positive returns when global capital markets decline significantly. Opportunistic Hedging Opportunistic hedging strategies may include a variety of short-term positions that have a positive expected rate of return in an environment where GCMLP would expect traditional equity or credit market risk factors to perform poorly. Relative to the other portfolio hedging strategies outlined herein, opportunistic hedges are more likely to target discrete trades or risk factors, rather than shorting market benchmarks or purchasing derivative protection on such benchmarks. Strategic Investments Group Strategies GCMLP may invest GCMLP Fund capital in Strategic Investments Group Strategies. Direct Investments Direct Investments include directly investing in trading and/or investment positions, portfolio companies, real assets, market exposures, debt, and/or various sources of risk premia, which may be included in certain GCMLP Funds, including Strategic Investments Funds. A GCMLP Fund may also obtain a direct investment by receiving a portfolio security distributed to it by an Underlying Fund as an in-kind distribution. In these cases, GCMLP generally seeks to liquidate direct investments received as in-kind distributions after the receipt by the relevant GCMLP Fund, as promptly as reasonably practicable subject to the liquidity of such direct investments. Co-Investment Opportunities Co-Investment Opportunities include opportunities in which an investor invests alongside a fund directly in an investment opportunity. Such investments will typically fall into one of the Investment Strategies mentioned previously. Potential advantages of co-investments may include investing alongside managers with deep domain expertise, ability to determine investment pace and portfolio composition on a portfolio company level, investing in selective high quality deal flow at reduced fees thereby enhancing potential overall returns for the private equity portfolio, and achieving quicker drawdowns and returns of capital. Private Markets Strategies GCMLP may invest GCMLP Fund capital in private markets strategies. In providing services to a GCMLP Fund that invests in private markets strategies, GCMLP may involve one or more affiliates of GCMLP. Private Equity Any investment strategy that involves the purchase of securities in a private transaction, including, but not limited to, leveraged buyouts, venture capital, private credit, real estate and infrastructure may be considered private equity. Real Estate Real estate investments include private investment in unlisted real estate assets. Real estate fund managers provide equity and attain debt financing to purchase assets and then work closely with local operating partners to implement an active asset management strategy. Investment strategies are typically designated as core, core plus, value-add or opportunistic; they vary significantly in risk, return and cash flow characteristics based on asset type, sector and geography. Infrastructure Infrastructure investments include investments in large-scale projects focused on transportation (e.g., airports, toll roads), communications (e.g., satellites, cable towers), energy production (e.g., renewables, dams, and pipelines), utilities (e.g., phone, electric generation), or social services (e.g., hospitals, schools, prisons, waste facilities). Infrastructure assets vary significantly in risk, return, and cash flow characteristics based on strategy, sector, stage, and geography. Co-Investment Opportunities Co-Investment Opportunities include opportunities in which an investor invests alongside a fund directly in a portfolio company, generally at reduced fee levels. Such deals can include buyout, venture capital, distressed debt, mezzanine, infrastructure, or real estate investment strategies. Potential advantages of co-investments may include investing alongside managers with deep domain expertise, ability to determine investment pace and portfolio composition on a portfolio company level, investing in selective high quality deal flow at reduced fees thereby enhancing potential overall returns for the private equity portfolio and achieving quicker drawdowns and returns of capital. Secondary Transactions in Investments On occasion we may consider the sale of some or all of the investments within a GCMLP Fund or of a group of investments, which may be the same or different, among a group of GCMLP Funds (each, a Secondary Sale). We may consider a Secondary Sale of an investment on behalf of certain GCMLP Funds but not others. Reasons for a Secondary Sale can vary depending on the facts and circumstances associated with each GCMLP Fund. For example, a Secondary Sale could be considered at the specific request of a client, because a particular GCMLP Fund is approaching the end of its term, because GCMLP receives an unsolicited offer, or because the sponsor of a particular investment proposes a restructuring or other liquidity event. We may also consider the purchase of Underlying Funds for one or more GCMLP Funds (each, a Secondary Purchase). Typically, a Secondary Purchase will be made opportunistically to the extent the Investment Committee believes the pricing is attractive or in respect of an Underlying Fund that is otherwise not available for primary investment (i.e., closed). In all cases, the Investment Committee and Operations Committee will approve Underlying Funds for which Secondary Purchases are made. Risks and Other Special Considerations An investment in a GCMLP Fund is speculative and involves substantial risk, including the possible loss of the entire amount invested, due to, among other factors:  the nature of our investment programs  the significant continuing uncertainty in the global financial markets  significant fees and costs—including advisory, transaction and opportunity costs—associated with an investment in a GCMLP Fund  the restrictions applicable to withdrawals/redemptions from a GCMLP Fund, as well as a GCMLP Fund’s dependence on its ability to withdraw or redeem capital from Underlying Funds in order to satisfy withdrawal/redemption requests from its investors
There can be no assurance that any GCMLP Fund will achieve its investment objectives or avoid significant losses. Past
performance is not necessarily indicative of future results, and the performance of the GCMLP Funds could be volatile.
You should not invest in a GCMLP Fund unless: you have no need for liquidity with respect to the investment, you are fully able to bear the financial risks of the investment for an extended period of time, and you are fully able to sustain the possible loss of the entire investment. You should consider an investment in a GCMLP Fund as a long-term investment that is appropriate only for a limited portion of your overall portfolio. Set forth herein are the general categories of risk that apply to investing in the GCMLP Funds. These risks are discussed in greater detail in the relevant GCMLP Fund Documents. Certain of these risks may be exacerbated in the case of GCMLP Funds with concentrated portfolios. These risks are not intended to be all-inclusive. Market Risks Generally, the risks that economic and market conditions and factors may materially adversely affect the value of the GCMLP Fund’s investments. Adverse Market Conditions All investments in securities and other financial instruments involve a substantial risk of volatility and loss arising from any number of general economic and market conditions as well as other factors, all of which are beyond the control of GCMLP and the Investment Managers—for example: changes in market sentiment; industrial conditions; competition and technology; inflation; exchange rates; interest rates; U.S. or international economic or political conditions or events; tax laws and governmental regulation; and governmental trade, fiscal, monetary or exchange control programs or policies. Conditions and factors such as these, as well as innumerable other conditions and factors, often are unforeseeable, rendering it difficult or impossible to predict future market movements. Unexpected volatility, illiquidity or “market shocks” in the markets in which the GCMLP Fund directly or indirectly holds positions could impair a GCMLP Fund’s ability to achieve its investment objectives and cause the GCMLP Fund to incur losses. Strategy Risks Generally, the risks associated with:  the possible failure of GCMLP’s asset allocation methodology, including the possible failure of a multi-Underlying Fund approach;  the possible failure of the investment strategies, techniques and practices employed by one or more Investment Managers;  possible inefficient or inaccurate trade execution by GCMLP or an Investment Manager;  GCMLP’s inability to gauge and react (due to Underlying Funds’ restrictive withdrawal or redemption provisions) on a real time basis to the specific strategy-related and/or position-level risks associated with positions held by the Underlying Funds in which a GCMLP Fund invests. Possible Failure of GCMLP’s Asset Allocation Methodology, Including the Possible Failure of a Multi-Underlying Fund Approach GCMLP’s methodology for selecting investment strategies and Investment Managers, developing portfolios of multiple Investment Managers and actively allocating a GCMLP Fund’s assets among them may prove unsuccessful in generating profits and/or avoiding losses. In addition to the inherent opportunity costs of allocating assets across different strategies (which are, among other things, likely to have periods of offsetting profits and losses), there can be no assurance that:  a GCMLP Fund’s strategy will not be more volatile than, or will not underperform, either or both an investment in a single Underlying Fund or a static allocation among a fixed group of Underlying Funds;  an investment strategy that has been profitable in the past will not incur material losses in the future; or  GCMLP will not allocate assets of a GCMLP Fund to Underlying Funds that are entering into unprofitable cycles and away from those entering into profitable cycles. Since a GCMLP Fund may allocate its assets to multiple Investment Managers, each of which trades independently of the others, there can be no assurance that the use of multiple Investment Managers will not effectively result in:  losses by certain Underlying Funds that offset, or more than offset, gains (if any) achieved by others. The adverse effect on a GCMLP Fund’s performance of certain Underlying Funds’ losses offsetting the gains (if any) recognized during the same period by other Underlying Funds is exacerbated by the fact that each Investment Manager receives performance/incentive fees or other performance/incentive compensation based on such Investment Manager’s individual performance, irrespective of a GCMLP Fund’s overall performance. Consequently, a GCMLP Fund may pay substantial performance/incentive fees or other performance/incentive compensation to those Investment Managers that recognize gains, irrespective of contemporaneous losses incurred by other Investment Managers, and even during periods when a GCMLP Fund is incurring significant overall losses (i.e., where the losses incurred by a GCMLP Fund’s investments in unprofitable Underlying Funds, together with a GCMLP Fund’s expenses, exceed the profits recognized by a GCMLP Fund’s investments in profitable Underlying Funds);  Underlying Funds managed by different Investment Managers holding economically offsetting positions. As long as Underlying Funds hold offsetting positions, a GCMLP Fund as a whole will be unable to recognize any gain or loss on such open positions, while at the same time incurring transaction costs and paying advisory fees; and/or  various Investment Managers competing from time to time for the same positions for their respective Underlying Funds, potentially affecting the value of such positions in a manner adverse to a GCMLP Fund. If a GCMLP Fund receives additional capital contributions from its investors during periods when certain Underlying Funds are “closed”—i.e., no longer accepting additional capital from GCMLP Funds (as well as possibly other investors)—such additional capital will have to be allocated to Underlying Funds that are then accepting additional funds, even if GCMLP otherwise would have maintained the respective percentage allocations between the “open” and “closed” Underlying Funds. Accepting such additional capital contributions will dilute investors’ exposure to “closed” Underlying Funds (which may be among the most successful Underlying Funds). GCMLP seeks preferred terms for a GCMLP Fund from the Underlying Funds in which a GCMLP Fund invests. GCMLP may not always be successful in negotiating such preferred terms and may select Underlying Funds for investment by a GCMLP Fund that provide such preferred terms in preference to other Underlying Funds that do not provide such preferred terms. GCMLP’s investment approach for a GCMLP Fund is typically designed to achieve broad diversification across global capital markets (e.g., equities, fixed-income, commodities, non-U.S. currencies and physical commodities, traded in numerous markets worldwide), limiting a GCMLP Fund’s exposure to any single market. Despite the apparent diversification among the strategies used by the different Investment Managers, these strategies generally tend to be dependent on market liquidity and the general availability of dealer and prime broker financing on reasonable and customary terms. As a result of these and other factors, multiple markets could from time to time move in tandem against a GCMLP Fund’s positions (e.g., concurrent declines in the global equity and fixed-income markets), and a GCMLP Fund could suffer substantial losses—as happened in 2008. Significant changes in the volatility of market price levels can adversely affect many alternative investment strategies by potentially disrupting historical price relationships. As a result, during periods of market stress, when the potential diversification benefits of an investment in a GCMLP Fund might otherwise be the most important in terms of protecting an overall portfolio against major losses, a number of Underlying Funds may incur material losses at or about the same time, resulting in a GCMLP Fund augmenting rather than mitigating overall portfolio losses. Possible Failure of the Investment Strategies, Techniques and Practices Employed by One or More Investment Managers A GCMLP Fund is subject to the risks associated with the investment strategies and investment techniques and practices employed by the Investment Managers. The Investment Managers may not be successful in attempting to generate profits or avoid losses. Underlying Funds employing alternative investment strategies are subject to a “risk of total loss”—the risk that a previously low volatility and apparently comparatively low risk strategy will incur sudden and dramatic losses—at a level of severity to which investment funds employing traditional strategies (which may be less dependent on the availability of financing or market liquidity) may not be subject. Strategy-specific losses may result from any number of factors, including excessive concentration by a GCMLP Fund to multiple Investment Managers in the same investment and/or market sector, general market events or conditions that adversely affect particular strategies (e.g., illiq please register to get more info

We are required to disclose to you all legal and disciplinary events relating to us or to our personnel that are material to your evaluation of our advisory business or the integrity of our management. To the best of our knowledge, there are no legal or disciplinary events relating to us or our personnel that are material to your evaluation of our advisory business or the integrity of our management. please register to get more info

GCMLP is registered with the Commodity Futures Trading Commission as a commodity pool operator and a commodity trading advisor, and is a member of the National Futures Association. Affiliated Registered Investment Adviser GCMLP is under common control with GCM CFIG, an investment adviser registered as such with the SEC. GCMLP manages a number of investment vehicles, including closed-end investment companies, unit investment trusts, private investment companies, and offshore funds. Similar to the investment advisory services we provide our clients, GCM CFIG offers customized and commingled investment funds and accounts that invest primarily in private equity, real estate, infrastructure, and venture capital investments. While GCMLP shares certain operational infrastructure with GCM CFIG, GCMLP generally maintains separate investment teams and investment processes. However, investment and non-investment personnel are encouraged to collaborate with their colleagues at GCM CFIG, and investment opportunities sourced by us or by GCM CFIG may be allocated pursuant to GCM Grosvenor’s policies across the enterprise. Affiliated Investment Managers GCM Investments UK LLP (GCM UK), an affiliate of GCM Grosvenor, is a UK based firm that provides certain services to GCM Grosvenor. GCM UK is authorized and regulated by the UK Financial Conduct Authority to provide investment advisory and arranging services to professional investors. GCM UK seeks to obtain information on and access to UK and Europe based investment managers and to furnish GCM Grosvenor advice with respect to such managers. In addition, employees of GCM UK meet with existing and prospective clients of GCM Grosvenor in the UK and Europe and assist employees of GCM Grosvenor when they are present in the UK. As compensation for the services GCM UK performs, GCM Grosvenor pays GCM UK a service fee based on a percentage mark-up over the cost of providing such services. GCM UK has an incentive to introduce GCM Grosvenor Funds to GCM UK’s clients because additional investments in such products will result in additional investment management or advisory fees for GCM Grosvenor. In cases where GCM UK provides investment advisory or arranging services to investors, such investors will be informed of the affiliation between GCM Grosvenor and GCM UK, and thus will be aware of this incentive prior to the time they invest in a GCM Grosvenor Fund. GCM Investments Hong Kong Limited (GCM HK), an affiliate of GCM Grosvenor, is located in Hong Kong. GCM HK is licensed to deal in securities (Type 1) and advise on securities (Type 4) by the Hong Kong Securities and Futures Commission. It seeks to obtain information on and access to Asia-based investment managers and provides GCM Grosvenor advice with respect to such managers. In addition, employees of GCM HK provide ongoing client service to GCM Grosvenor clients in Asia and assistance to employees of GCM Grosvenor when they are traveling in Asia. As compensation for the services GCM HK performs, GCM Grosvenor pays GCM HK a service fee based on a percentage mark-up over the cost of providing such services. GCM Japan (as defined herein) may act as a discretionary investment manager on behalf of clients in Japan and, in that connection, may allocate client assets to one or more investment vehicles managed or advised by GCMLP or GCM CFIG. Affiliated Placement Agents/Distributor GCMLP’s affiliate, GRV Securities LLC (GSLLC), serves as placement agent or distributor for certain GCM Grosvenor Funds. GSLLC is registered as a broker-dealer with the SEC under the U.S. Securities Exchange Act of 1934 and with 53 U.S. state and territorial jurisdictions and is a member of the U.S. Financial Industry Regulatory Authority, Inc. GSLLC’s sole functions are to:  act as a private placement agent for certain securities (including interests in certain GCM Grosvenor Funds)  provide wholesaling and distribution services to closed-end RICs sponsored and advised or managed by us  provide certain support services to third-party selling agents that market the RICs  provide wholesaling services to open end RICs advised or sub-advised by us Pursuant to a Master Placement Agent Agreement, we and GCM CFIG compensate GSLLC on a flat annual fee basis for the placement agent and distribution services provided by GSLLC, regardless of the success of GSLLC’s services. GSLLC has no employees. However, certain of our employees, including many of our executive-level employees, are registered as representatives of GSLLC so that they may engage in private placement activities on behalf of certain GCM Grosvenor Funds. We are exclusively responsible for compensating such employees, and neither we nor GSLLC pays any sales commissions to any such employees in connection with the private placement activities they perform on behalf of the GCM Grosvenor Funds. GCM Investments Japan K.K. (GCM Japan), an affiliate of GCM Grosvenor, is located in Tokyo, Japan. GCM Japan is registered as a securities company in Japan with the Kanto Local Finance Bureau. GCM Japan may act as placement agent for certain GCM Grosvenor Funds that are privately offered in Japan to Japanese investors, provide ongoing services to Japanese investors in such vehicles and provide research services to GCM Grosvenor. GCM Grosvenor may compensate GCM Japan for such placement agent services with an asset based fee and may compensate GCM Japan for ongoing client and research services based on a percentage mark-up over the cost of providing such services. GCM Japan is exclusively responsible for compensating its employees, and neither GCMLP or GCM CFIG, nor GCM Japan, pays any sales commissions to such employees in connection with the private placement activities they perform. GSLLC and GCM Japan have an incentive to introduce GCM Grosvenor Funds to prospective investors, because additional investments in such products will result in additional investment management or advisory fees for GCM Grosvenor. However, all prospective investors are informed of the affiliation between GCM Grosvenor and GSLLC or GCM Japan, as applicable under the circumstances, and are thus aware of this incentive prior to the time they invest funds in a GCM Grosvenor Fund. Other Affiliates GCM Investments (Korea) Co. Ltd. (GCM Korea), an affiliate of GCM Grosvenor, is located in Seoul, South Korea. The activities of GCM Korea are not regulated in South Korea. GCM Korea provides ongoing services to Korean clients in investment vehicles or accounts managed by GCM Grosvenor. In addition, employees of GCM Korea provide assistance to employees of GCM Grosvenor when they are present in South Korea. GCM Grosvenor may compensate GCM Korea for ongoing client services based on a percentage mark-up over the cost of providing such services. GCM Korea does not introduce GCM Grosvenor Funds to prospective Korean clients. please register to get more info

Personal Trading Code of Ethics GCM Grosvenor has adopted a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act and Rule 17j-1 under the ICA (Code of Ethics). The Code of Ethics outlines the Firm’s duties of care and loyalty; the standards of conduct required of all covered persons; and the requirements applicable to outside business activities, conflicts of interest, and personal trading. GCM Grosvenor personnel have several basic obligations under the Code of Ethics: (1) act consistently with our fiduciary duties to our clients (2) comply with applicable federal securities and commodities laws (3) understand and adhere to the Firm’s compliance policies and procedures (4) periodically submit certain statements or certifications to us (5) obtain pre-clearance from us in connection with certain types of activities and transactions (Pre-Clearance Transactions), including (under certain circumstances) investments in securities issued in private placements or in initial public offerings (6) refrain from engaging in certain types of prohibited transactions and activities Compliance may deny an employee’s request to engage in a Pre-Clearance Transaction or revoke approval of a previously approved Pre-Clearance Transaction if they determine:  such employee is delinquent in filing reports required to be filed by such employee pursuant to the Code of Ethics  such transaction or activity involves a company on the Restricted List  such employee may unfairly benefit from such transaction or activity at the expense of our or our affiliate’s clients  such employee may benefit from such transaction or activity as a result of information that is proprietary to us, any of our affiliates or any of our affiliates’ clients  such transaction or activity involves, or appears to involve, a conflict between the interests of such employee or us and those of any of our or our affiliates’ clients  such transaction or activity involves undue litigation, regulatory, enforcement or reputational risk to us  such transaction or activity is otherwise prohibited or conflicts with the terms and conditions of the Code of Ethics In applying the foregoing criteria, Compliance may take such facts and circumstances into account as appropriate. GCM Grosvenor will provide investors and clients a copy of our Code of Ethics upon their request. Our Ability to Invest in the Same Securities in which the GCM Grosvenor Funds Invest GCM Grosvenor may for its own account invest in GCM Grosvenor Funds for its own account alongside investors who are not related to us. When GCM Grosvenor does so, GCM Grosvenor participates in the investment opportunities in which such GCM Grosvenor Funds participate, alongside the other investors in such GCM Grosvenor Funds. In addition, GCM Grosvenor may for its own account place assets under the management of (or otherwise procure investment advisory or investment management services from) any Investment Manager directly or indirectly used by one or more GCM Grosvenor Funds. For example, GCM Grosvenor may invest in an Underlying Fund for its own account in which one or more GCM Grosvenor Funds invest. Further, GCM Grosvenor may invest in an Underlying Fund at or about the same time one or more GCM Grosvenor Funds invest in such Underlying Fund. GCM Grosvenor for its own account and one or more GCM Grosvenor Funds that place assets under the management of, or otherwise procure investment advisory or investment management services from, any Investment Manager directly or indirectly used by one or more other GCM Grosvenor Funds may do so on terms (including terms relating to fees, liquidity and transparency) that are the same as or more advantageous than those applicable to the investments that may be made by such other GCM Grosvenor Funds with such Investment Manager. To the extent that GCM Grosvenor invests for its own account with a given Investment Manager on terms that are more advantageous than those on one or more GCM Grosvenor Funds may invest with such Investment Manager, GCM Grosvenor may have an incentive to maintain or increase the investment by such GCM Grosvenor Funds with such Investment Manager in order to obtain or maintain such advantageous terms for the benefit of GCM Grosvenor. please register to get more info

Our Brokerage Practices In respect of transactions in Underlying Funds, except in the very limited case of secondary market transactions in interests in Underlying Funds, when the GCMLP Funds invest in Underlying Funds—which typically constitutes their principal business activity—the GCMLP Funds contract directly with the Underlying Funds without the involvement of a financial intermediary such as a broker-dealer. Commissions are not payable in connection with such investments. To the extent that GCMLP Funds managed on a discretionary basis purchase or sell investments other than investments in Underlying Funds, GCMLP has the authority to determine the financial intermediaries to be used in connection with such purchases or sales and to negotiate the commissions or other transactional compensation to be paid to such intermediaries in connection with such purchases or sales—which commissions or other compensation are borne by the affected GCMLP Funds. In determining which intermediaries to use, to effect purchases and sales of securities on behalf of the GCMLP Funds, GCMLP focuses on the quality of the execution-related services provided by the intermediaries, often called best execution. Best execution generally includes a variety of factors such as price quotes, including the applicable spread or commission and commission rates among brokers, the extent to which the broker-dealer makes a market in the securities involved or has access to such markets, and the broker-dealer’s ability to accommodate any special execution or order handling requirements that may surround the particular transaction. Best execution does not necessarily mean always obtaining the best price for any single transaction. GCMLP does not necessarily select those that charge the lowest commissions or other transactional costs. GCMLP may recommend trades in the same security for several different GCMLP Funds. Rather than placing trades individually, GCMLP will seek to aggregate trades together for multiple GCMLP Funds to reduce commission rates, fulfill best execution, and ensure fair and equitable pricing. To fulfill its fiduciary duty, GCMLP reasonably ensures that the aggregation of trades does not purposely favor one client over others, treats clients fairly over time, it accurately maintains records of trades, allocations and positions and identifies potential conflicts related to trading and takes reasonable steps to address those conflicts. To the extent that the GCMLP Funds advise on a non-discretionary basis engage in transactions in investments other than investments in Underlying Funds, GCMLP does not have the authority to determine the financial intermediaries used in connection with such transactions or to negotiate the commissions or other transactional compensation to be paid to such intermediaries in connection with such transactions, unless the client expressly confers that authority on us and GCMLP agrees to accept such authority. In all such cases, the commissions or other compensation are borne by the client. We do not separately compensate financial intermediaries for the provision of non-execution related services and we do not believe that we pay up for such services. However, we may from time to time use financial intermediaries that provide research-related products or services to most or all of their customers, and—although we do not request research-related products or services from such financial intermediaries—we may on occasion receive and use research provided by such intermediaries. In this situation, we receive a benefit because we do not have to produce or pay for the research. Accordingly, we may have an incentive to select financial intermediaries based on our interest in receiving the research or other products or services rather than on our clients’ interest in receiving the most favorable execution. However, since the research provided is not material in nature and quantity and is provided without our request, we believe that our receipt of such research does not have a material effect on our selection of financial intermediaries. GCM Grosvenor may in the future select service providers that furnish GCM Grosvenor with proprietary or third-party brokerage and research services that provide, in GCM Grosvenor’s view, appropriate assistance to GCM Grosvenor in its investment advisory process. GCM Grosvenor may pay for such brokerage and research services with “soft” or commission dollars. To the extent that the GCMLP Funds engage in secondary market transactions in interests in Underlying Funds, we generally have limited ability to select the financial intermediaries involved in connection with any proposed transaction or to negotiate the commissions or other transactional compensation to be paid to such intermediaries in connection with such transactions. The commissions charged by such intermediaries may vary significantly from intermediary-to-intermediary, and from transaction-to-transaction. Brokerage Practices of Investment Managers of Underlying Funds Investment Managers of the Underlying Funds in which the GCMLP Funds invest select the financial intermediaries that execute transactions for their respective Underlying Funds and negotiate the related brokerage commissions and other transactional costs paid to such intermediaries. In selecting financial intermediaries and/or in negotiating commissions and other compensation with them, such Investment Managers, subject to their overall duty in seeking to obtain best execution of all transactions for the Underlying Funds they manage:  have authority to and may consider the full range and quality of the services and products provided by the intermediaries, including factors such as the ability of the intermediaries to execute transactions efficiently, their responsiveness to instructions, their facilities, reliability and financial responsibility and the value of any research or other services or products they provide  do not necessarily select intermediaries that charge the lowest transaction costs. In this regard, Investment Managers may engage in the practice known as “paying up,” whereby the Investment Managers cause their Underlying Funds to pay higher transaction costs than they would otherwise pay so that the Investment Managers may receive certain non- execution related products and services provided by or through the intermediaries, so-called soft dollar benefits The practices discussed above create conflicts between the interests of an Investment Manager and the interests of the Underlying Funds managed by such Investment Manager. This is because an Investment Manager that receives soft dollar benefits receives a benefit that it does not have to purchase out of its own resources. This benefit, in turn, may create an incentive to utilize particular intermediaries based not on the interest of the Underlying Funds in seeking to obtain best execution of their transactions, but on the Investment Manager’s interest in receiving benefits for which it does not have to pay out of its own resources. Further, an Investment Manager may cause an Underlying Fund managed by such Investment Manager to pay transaction costs to a financial intermediary even though such Investment Manager and/or clients of such Investment Manager other than such Underlying Fund are the exclusive beneficiaries of soft dollar benefits provided by the intermediary. GCMLP is ordinarily authorized to consent—on behalf of GCMLP Funds that GCMLP manages on a discretionary basis—to practices in which the Investment Managers of the Underlying Funds in which such GCMLP Funds invest receive soft dollar benefits from the financial intermediaries selected by such Investment Managers to effect transactions in securities or other financial instruments for such Underlying Funds (subject to the Investment Managers’ overall duty to seek to obtain best execution of all transactions for the Underlying Funds they manage). This is the case regardless of whether such Investment Managers’ soft dollar practices conform to the requirements of the so-called “safe harbor” provided by Section 28(e) of the Exchange Act (except where regulatory considerations do not permit such Investment Managers to engage in such practices). However, most of the Underlying Funds in which the GCMLP Funds invest either do not engage in soft dollar practices or do so within the safe harbor provisions of Section 28(e) of the Exchange Act. In those cases where the Investment Manager of an Underlying Fund indicates that it may engage in soft dollar practices outside of the safe harbor, we—as part of our due diligence review and ongoing monitoring of Underlying Fund investments—obtain information concerning such soft dollar practices and make an assessment as to whether such practices are appropriate and reasonable under the circumstances. please register to get more info

Account Reports and Reporting Packages Basic Account Reports Except where GCMLP expressly agrees otherwise with a client, GCMLP delivers or causes to be delivered—no less frequently than quarterly—to each person who was an investor in a GCMLP Fund, or their designated representative, at any time during the relevant reporting period a written report setting forth:  an unaudited statement of the estimated return of the GCMLP Fund for the period covered by the report (except in the case of GCMLP Funds that are RICs)  the estimated value of the investor’s investment in the GCMLP Fund as of the end of such period  such other financial reports and information as we may deem appropriate For each GCMLP Fund that is an entity, and for which GCMLP has custody (as further described in Item 15 – Custody), as soon as reasonably practicable after the end of such GCMLP Fund’s fiscal year, and in no event not more than 180 days after the end of such fiscal year or 60 days, in the case of the RICs, GCMLP delivers or causes to be delivered to each person who was an investor in such GCMLP Fund at any time during such fiscal year a written report containing audited financial statements of the GCMLP Fund for such fiscal year. Such audited financial statements generally include or are accompanied by:  a statement of assets, liabilities and investors’ capital (including a condensed schedule of investments in the case of GCMLP Funds that are not RICs, and a schedule of investments for GCMLP Funds that are RICs)  a statement of operations  a statement of changes in investors’ capital  a statement of cash flows  the financial statements of any GCMLP Fund in which such GCMLP Fund invests Clients or their designated representatives generally access reports and, where available, analytical tools online via our client web portal or a designated third-party client web portal. The types of information that may be available in a secure and easy-to-use format include portfolio, investment manager, and industry information. Reporting may vary by investment size, structure, and investment vertical. Exceptions to Investment Constraints To the extent that a monthly review by the Portfolio Management Team indicates an exception to a GCMLP Fund’s compliance with applicable investment constraints, the Portfolio Management Team assigned to such GCMLP Fund and certain other members of the Investments Department review the exception to determine what action, if any, is required to remedy the exception. Investment Committee Changes in Strategy and/or Allocation Guidelines If the Investment Committee changes one or more strategy and/or allocation guidelines, manager allocation guidelines or the approval status of certain Investment Managers, the assigned Portfolio Management Team and certain other members of the Investments Department or Investment Committee review the changes to determine what action, if any, is required to adjust the portfolios of the GCMLP Funds in light of the changes. Capital Inflows/Outflows To the extent there are capital inflows or outflows with respect to a GCMLP Fund, the Portfolio Management Team assigned to such GCMLP Fund reviews the portfolio of such GCMLP Fund to determine what changes are required to accommodate such capital flows. Portfolio Management Team Proposed Changes in Allocations If the Portfolio Management Team assigned to a GCMLP Fund decides to propose changes to the portfolio allocations of such GCMLP Fund based on its assessment of specific Investment Manager opportunities or market opportunities, certain members of the Investments Department review such GCMLP Fund to determine whether the proposed changes would be consistent with such GCMLP Fund’s investment constraints. The personnel who are responsible for the reviews discussed above include persons who may be at levels including Analysts, Associates, Principals, Executive Directors, or Managing Directors. However, primary responsibility for such reviews rests with the Portfolio Management Team assigned to the relevant GCMLP Fund. Different Reporting Packages Different investors, including different investors in the same GCMLP Fund, as well as certain other persons, including (i) persons to whom GCMLP provides investment advisory services on a non-discretionary basis and (ii) persons who currently have, or who previously have had, an interest in us or who otherwise currently are, or who previously have been, associated with us, receive oral and/or written reports from us that differ in form, substance, level of detail, timing and/or frequency. Recipients of oral and written reports should be aware that:  GCM Grosvenor does not permit such recipients to copy, transmit or distribute such reports, or any data or other information contained therein, in whole or in part, or authorize such actions by others, without our express prior written consent, and any such action taken without our express prior written consent may constitute a breach of contract and applicable copyright laws  by their receipt of such reports, such recipients will be deemed to have acknowledged that: (i) the data and/or other information contained therein may include data and/or information that, under applicable law, may be deemed to be material, non-public information regarding particular securities and/or the issuers thereof; (ii) under certain circumstances, United States securities laws prohibit the purchase and sale of securities by persons or entities who are in possession of material, non-public information relating to such securities and/or the issuers thereof; (iii) securities laws of other jurisdictions may contain a similar prohibition; and (iv) as a result, it is possible that trading in securities that are the subject of data and/or information contained in such reports may be prohibited by law If you are a recipient of our oral or written reports, we strongly urge you to review your own policies and procedures relating to the possible receipt of confidential or material, non-public information to ensure that any information that you receive from us relating to particular securities and/or the issuers thereof will not be used in any manner that conflicts with applicable laws. please register to get more info

Receipt of Payments from Third Parties We serve as a sub-adviser to certain investment vehicles that are managed by independent third parties. These independent third parties compensate us, either directly out of the investment management fees they receive from such investment vehicles or otherwise, out of their own resources or indirectly from the relevant investment vehicles, for the sub-advisory services we provide to such investment vehicles. Payment of Compensation for Investor Referrals As discussed in greater detail in Item 10 of this Brochure under the heading Affiliated Placement Agents, we compensate certain affiliated entities for referring prospective investors to certain GCMLP Funds. In addition, we or one of our affiliates may pay compensation or commissions from our own resources, either at the time of sale or on an ongoing basis, to intermediaries for sales by such intermediaries of interests to investors in the RICs, as well as for ongoing investor servicing. Such payments, sometimes referred to as “revenue sharing,” may be made:  from the investment advisory fees we receive from the RICs  for the provision of sales training, product education and access to sales staff, the support and conduct of due diligence, balance maintenance, the provision of information and support services to investors, inclusion on preferred provider lists and the provision of other services The receipt of such payments could create an incentive for the intermediaries to offer or recommend a GCMLP Fund instead of similar investments where such payments are not received. Such payments may be different for different intermediaries. We may from time to time compensate unaffiliated third parties in connection with our participation in investor introduction conferences sponsored by such third parties in which we meet with prospective investors introduced to us by such third parties. Payment of Compensation for Client Referrals From time to time, we may make cash payments for client referrals to persons other than our employees and our affiliates pursuant to applicable laws, including Rule 206(4)-3 under the Advisers Act, when applicable. These payments may differ by referrer and are negotiated based on a range of factors, including but not limited to: target markets; nature and size of potential client relationships; quality of service and industry reputation. In general, a referrer may be compensated based (i) on a fixed periodic fee that is not contingent upon any person referred to us by such referrer becoming a client of ours; or (ii) on a percentage of the amount of the referred client’s investment with us over some set period of time. Some referrers or their affiliates may receive a retainer amount against which future payments are offset. Referrers may also receive reimbursement for certain expenses related to their activities associated with referring clients to us. Any such payments will be disclosed in accordance with Rule 206(4)-3 and relevant guidance. We are also referred clients by unaffiliated consultants that are retained by clients or prospective clients. While we do not make payments to these consultants for client referrals, we may pay to participate in investment advisory searches conducted by certain consultants on behalf of their clients as well as in conferences and other events sponsored by certain consultants. We may also purchase products and services from such consultants or their affiliates. Our participation in conferences and other events sponsored by consultants, or by industry-related organizations to which we pay a fee for membership, helps us interact with investment industry participants and develop an understanding of industry trends and the points of view and challenges of industry participants. Conference and other event participants may include trustees, fiduciaries, consultants, administrators, state and municipal personnel and other clients or prospective clients. Non-Affiliated Placement Agents From time to time, we engage non-affiliated placement, distribution, or similar agents to assist us in marketing interests in our investment products. If you acquire an interest in any of our investment products as a result of a recommendation made by any such placement, distribution or similar agent, you should not view such recommendation as being disinterested, as we generally will pay the agent for the introduction. Also, you should regard such an agent as having an incentive to recommend that you retain your interest in our investment products, since such agent may be paid a portion of our fees for all periods during which you do so. To the extent that such agent is compensated by GCM Grosvenor, such compensation will be separately disclosed to investors. please register to get more info

Pursuant to the Advisers Act—which imposes certain requirements on SEC-registered investment advisers that have custody of client funds or securities—GCMLP is deemed to have custody of the funds and securities of certain GCMLP Funds even though:  subject to certain SEC-permitted exceptions, we and our affiliates do not physically hold the funds or securities of such GCMLP Funds  the funds and securities of such GCMLP Funds are not held or registered in GCMLP’s name or in the name of any of its affiliates Although GCMLP or its affiliates are deemed, under applicable rules, to have custody of the funds and securities of certain GCMLP Funds that are entities, GCMLP is generally excepted from many of the provisions of the custody rule because we undertake to deliver to the investors, within 180 days after the end of the fiscal year of such GCMLP Fund, financial statements that are:  prepared in accordance with Accounting Standards Generally Accepted in the United States (U.S. GAAP), or with accounting principles other than U.S. GAAP under certain circumstances  audited by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board please register to get more info

GCMLP manages most GCMLP Funds on a discretionary basis, which means that GCMLP has the authority to decide which securities to purchase and sell for such GCMLP Funds. GCMLP considers a GCMLP Fund to be managed by us on a discretionary basis if GCMLP has been granted legal authority in GCMLP Fund Documents to invest and reinvest the assets of such GCMLP Fund without receiving prior authorization from any investor in such GCMLP Fund or any other person to engage in particular investment activities for such GCMLP Fund. In certain cases where GCMLP has been granted discretionary investment authority over GCMLP Funds, the investors or participants in those GCMLP Funds have informally reserved the right to approve or not approve its investment decisions for those GCMLP Funds prior to the implementation of such decisions. GCMLP manages, on a discretionary basis, many GCMLP Funds that are designed for multiple investors. In these cases, we determine the particular Investment Guidelines that will apply to management of the GCMLP Fund. These restrictions typically do not include restrictions on the GCMLP Fund’s ability to make investments in particular securities or particular types of securities. Further, investors in the GCMLP Fund are not afforded the opportunity to place restrictions on the GCMLP Fund’s ability to make particular investments or particular types of investments, or otherwise to place any additional material limitations on GCMLP’s exercise of discretionary authority over such GCMLP Fund. We re-evaluate Investment Guidelines from time to time based on various factors, including its assessment of market conditions, and may amend or modify the Investment Guidelines from time to time based on such re-evaluations. Such modifications may be made without notice to investors in such GCMLP Funds. We also manage, on a discretionary basis, many GCMLP Funds that are designed for single investors or groups of related investors. In these cases, prior to the launch of the GCMLP Fund, we propose to the single investor or group of investors the Investment Guidelines that will apply to our management of the GCMLP Fund, and the investor is afforded the opportunity to review and suggest changes to such guidelines, including restrictions on the GCMLP Fund’s ability to make particular investments or particular types of investments. If we agree to be bound by any such changes, we will follow them in connection with managing such GCMLP Fund. please register to get more info

Background GCMLP’s Proxy Voting Policies and Procedures (Proxy Voting Policy) set forth the policies and procedures by which GCMLP exercises its authority to vote on or make recommendations on how to vote on proxy requests relating to securities held by GCMLP Funds (Proxy Requests). GCMLP Funds receives Proxy Requests from Underlying GCMLP Funds, public companies, and other issuers. GCMLP seeks to take action on Proxy Requests in the best economic interests of the GCMLP Funds for which it has the authority to vote or to which it makes voting recommendations. The Policy establishes standards for the proxy voting process, identification and management of related conflicts of interest, and client disclosure obligations. Investors can request a copy of the Proxy Voting Policies and Procedures, which are summarized herein, or request an opportunity to review the proxy voting records, by contacting the Investor Relations Team (telephone: +1.855.426.9321; e- mail: client.services@gcmlp.com). Authority to Vote and Make Recommendations GCMLP’s authority to vote on or make voting recommendations on Proxy Requests for GCMLP Funds is based on regulatory requirements, any arrangements made with the client and whether GCMLP has investment discretion. For some GCMLP Funds, GCMLP must notify the client, or obtain affirmative or negative consent from the client, before responding to certain Proxy Requests or inform the client, after responding to certain Proxy Requests, of what actions have been taken. Discretionary Investment Authority GCMLP has the authority to vote on Proxy Requests in connection with GCMLP Funds over which it has investment discretion, with some exceptions. GCMLP does not vote on Proxy Requests if the GCMLP Fund is a single investor or single participant fund and GCMLP has agreed in writing with the investor that GCMLP is not required to vote on Proxy Requests for the fund. However, in the case of a GCMLP Fund that is subject to ERISA:  Where the authority to manage the assets of the GCMLP Fund has been delegated to GCMLP pursuant to Section 403(a)(2) of ERISA, no person other than GCMLP has authority to vote on Proxy Requests on behalf of the GCMLP Fund, except to the extent a named fiduciary of the ERISA investor in the GCMLP Fund has reserved to itself or to another named fiduciary so authorized by the ERISA investor’s governing documents the exclusive right to direct a plan trustee of the ERISA investor regarding the voting of proxies.  A named fiduciary of an ERISA investor, in delegating investment management authority to GCMLP, could reserve to itself the exclusive right to direct a trustee of the ERISA investor with respect to the voting of all proxies or reserve to itself the exclusive right to direct a trustee as to the voting of only those proxies relating to specified assets or issues.  If the governing documents relating to the GCMLP Fund or the plan documents relating to the ERISA investor in the GCMLP Fund provide that GCMLP is not required to vote on Proxy Requests, but does not expressly preclude GCMLP from voting on proxies, GCMLP has exclusive authority to vote on Proxy Requests on behalf of the GCMLP Fund. GCMLP ordinarily does not consult with clients prior to taking action. However, in certain cases, clients that grant investment discretion to GCMLP may make arrangements to reserve the right to approve or disapprove, or simply receive notice, of GCMLP’s decisions with respect to voting on Proxy Requests that affect their account. Non-Discretionary Investment Authority When GCMLP does not have authority to vote on Proxy Requests on behalf of a GCMLP Fund, depending on its agreement with the GCMLP Fund, it may have an obligation to make recommendations to the GCMLP Fund on how to vote on Proxy Requests. In certain cases, GCMLP may not have the authority to vote on Proxy Requests on behalf of a GCMLP Fund, or have any obligation to make recommendations to the GCMLP Fund on how to vote on Proxy Requests, but may from time to time, at the request of the investor in the GCMLP Fund, make recommendations to the investor on how to vote on Proxy Requests In the case of a GCMLP Fund subject to ERISA, GCMLP will not make recommendations if an authorized fiduciary of the fund has agreed in writing with GCMLP that GCMLP is precluded from making recommendations and that a party associated with the GCMLP Fund, such as the plan sponsor, has reserved in writing the authority and right to take actions in response to Proxy Requests. When GCMLP does not have authority to vote on Proxy Requests on behalf of a GCMLP Fund, the client’s custodian or an Underlying Fund may provide Proxy Requests to the client directly. However, if GCMLP receives a Proxy Request, it will forward the information to the client. Upon client request and subject to ERISA considerations, GCMLP will vote on Proxy Requests in accordance with the client’s voting instructions. Reasonable Best Efforts to Vote and Abstentions GCMLP uses its reasonable best efforts to vote on or make voting recommendations on Proxy Requests in a timely manner. However, there may be circumstances in which GCMLP abstains from taking action. Timeliness of Receipt of Materials GCMLP may abstain from voting on or making voting recommendations on a Proxy Request when GCMLP does not receive the Proxy Request with sufficient time prior to the voting cut-off date to consider the impact of the proposals and complete its evaluation procedures. Lack of Adequate Information GCMLP may abstain from voting on or making voting recommendations on a Proxy Request when GCMLP does not believe that the Proxy Request provides sufficient detail to support a decision. Abstentions Where Cost of Consideration Outweighs Benefit GCMLP may abstain from voting on or making voting recommendations on a Proxy Request when GCMLP believes that the expected cost or administrative burden of giving due consideration to the proposal does not justify the potential benefits to the affected GCMLP Fund that might result from adopting or rejecting the proposal in question. Public Companies – Share Blocking and Re-Registration In certain countries, shareholders that vote on an issuer’s proxy must deposit their shares with a designated depositary prior to the date of the meeting. The owner may not sell its shares until after the meeting when the shares are returned to the custodian. In countries that require shares to be blocked, GCMLP will consider the potential benefit of taking action on Proxy Requests to determine if it will consider voting and the resulting share blocking of the security. In certain countries, an owner of a company’s shares must re-register the shares in order to take action on a proxy. Similar to share blocking, re-registration temporarily prevents a shareholder from selling shares. In countries that require re- registration, GCMLP will consider the potential benefit of taking action on Proxy Requests to determine if it will consider voting and re-registering the security. Conflicts of Interest GCMLP takes measures to identify and address conflicts of interest with respect to Proxy Requests. The test for determining whether circumstances present a conflict of interest is if it can reasonably be argued that the circumstances give GCMLP or a Proxy Principal a meaningful incentive to respond to a Proxy Request in a manner that:  places the interests of GCMLP or the Proxy Principal over the interest of a GCMLP Fund even if there is no apparent detriment to the GCMLP Fund  places the interests of one GCMLP Fund over the interests of another GCMLP Fund The Proxy Voting Coordinator evaluates the circumstances of a potential conflict of interest based on the test described above to determine whether or not there is a conflict of interest. GCMLP will not make a final decision with respect to a Proxy Request until the Proxy Voting Coordinator performs the following:  identifies whether GCMLP is subject to a conflict of interest in taking action in response to the Proxy Request  addresses the conflict in a manner designed to serve the best economic interests of the affected GCMLP Funds Identifying Conflicts of Interest Generally, the Investment Committee may identify conflicts of interest and notify the Global CCO or the Proxy Voting Coordinator. In addition, GCMLP identifies conflicts of interest by taking the following actions:  Each Proxy Principal notifies the Proxy Voting Coordinator of any potential conflicts of interest they have with respect to a Proxy Request on which they are considering action.  Regularly, generally quarterly, Compliance provides the Proxy Voting Coordinator with a list of all private securities held by each Proxy Principal as well as other GCMLP personnel covered under the reporting requirements of the Code of Ethics. Based on a review of the list of private placements, the Proxy Voting Coordinator assesses whether there is a potential conflict of interest with respect to a Proxy Principal taking action on a Proxy Request. Addressing Conflicts of Interest If the Proxy Voting Coordinator receives information indicating that GCMLP, its senior management, or a Proxy Principal is subject to a conflict of interest in taking action with respect to a Proxy Request, the Proxy Voting Coordinator will not instruct or make a recommendation on a vote until the conflict is mitigated. The Proxy Voting Coordinator documents any conflicts of interest and the means by which any conflicts are addressed. The Proxy Voting Coordinator, together with the Global CCO, determines the actions to be taken to address any conflicts of interest, which may include:  excluding a conflicted party from the decision making process  for GCMLP Funds for which GCMLP makes voting recommendations on Proxy Requests, disclosing the conflicts to the appropriate parties  for GCMLP Funds for which GCMLP has the authority to take action on Proxy Requests, disclosing the conflict to the appropriate parties and obtaining consent to take specific action on the proposals  engaging an independent third party to recommend or determine the actions to be taken in response to the Proxy Request For GCMLP Funds subject to ERISA, if a conflict relates to the Proxy Principal or a voting member of a committee involved in the proxy voting process, the affected employees will recuse themselves from the process if feasible and not detrimental to the GCMLP Fund. If the impact of the conflict goes beyond specific employees who can reasonably be recused from the action, GCMLP must engage an independent third party to recommend a response to the Proxy Request. In the case of a GCMLP Fund for which GCMLP does not have investment discretion, the independent third party could be the fiduciary for the client if the fiduciary agrees in writing to assume full fiduciary responsibility for the response without advice from GCMLP. Voting GCMLP Fund Interests Where a GCMLP Fund has issued a Proxy Request and GCMLP has the discretionary authority to vote on the Proxy Request on behalf of other GCMLP Funds that invest in such GCMLP Fund, to the extent that there are other investors in such GCMLP Fund—including GCMLP Funds where GCMLP does not have discretionary authority to vote proxies, or investors other than GCMLP Funds—GCMLP typically will vote the Proxy Request in the same manner that such other investors vote on the Proxy Request. Alternatively, the Global CCO or General Counsel may decide to engage an independent third party to recommend or determine the actions to be taken in response to the Proxy Request or to vote on the Proxy Request by other appropriate means. Independent Third Party Prior to engaging an independent third party, the Proxy Voting Coordinator and the Global CCO must first determine that the independent third party:  has the capacity and competency to analyze the proxy issues in question  can make recommendations in an impartial manner and in the best economic interests of the affected GCMLP Funds please register to get more info

GCMLP is required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients. GCMLP does not have any financial condition that impairs or is reasonably likely to impair its ability to meet its contractual commitments to its clients, and GCMLP has never been the subject of any bankruptcy petition. please register to get more info