ADVISORY BUSINESS
A. General Description of Advisory Firm
AHL Partners LLP (the “Investment Manager”) is a limited liability partnership established in England with its principal place of business in London, England. AHL Partners LLP is authorized and regulated by the Financial Conduct Authority in the United Kingdom, and primarily offers investment advisory or sub advisory services to pooled investment vehicles, commodity pools, registered investment companies and institutional separately managed accounts on a discretionary basis. AHL Partners LLP provides discretionary investment advice and/or management services according to the stated investment objectives, restrictions and policies of each client. AHL Partners LLP is a member of Man Group plc, which is listed on the London Stock Exchange and is a component of the FTSE 250 Index. Man Group plc, through its investment managers (collectively, "Man"), is a global alternative investment management business and provides a range of fund products and investment management services for institutional and private investors globally. As of March, 31 2019, Man had approximately $112.3 billion of funds under management.

AHL Partners LLP has full discretionary advisory investment management authority with respect to investment decisions for U.S. and non-U.S. pooled investment vehicles, including private funds and commodity pools (the "Funds"). AHL Partner LLP’s advice with respect to the Funds is provided in accordance with the investment objectives and guidelines as set forth in the applicable Fund's offering memorandum or the managed account's investment management agreement. AHL Partners LLP may manage a Fund’s assets through separately managed portfolios or through investments in other pooled investment vehicles, which may include pooled investment vehicles managed by AHL Partners LLP. AHL Partners LLP or an affiliate may act as general partner or managing member of such Funds. Proprietary assets of AHL Partners LLP or affiliates of AHL Partners LLP also may be directly or indirectly invested in the Funds. “Funds” include one or more funds that AHL Partners LLP, affiliates or employees have seeded or invested over 25% of the capital of such Funds. Important information regarding each Fund and managed account, which includes investment objectives, risks, strategy, fees and other material information, including applicable conflicts of interest is contained in each Fund’s offering documents and in each managed account's investment management agreement, as the case may be. As used herein, the term "client" generally refers to each Fund and each beneficial owner of a managed account. Certain affiliated advisory firms are considered to be “Participating Affiliates” of AHL Partners LLP(as that term is used in relief granted by the staff of the Securities and Exchange Commission (“SEC”)) allowing investment advisers registered with the SEC to use portfolio management, operations, and trading resources of advisory affiliates and personnel subject to the supervision of an SEC-registered adviser. Professionals from such Participating Affiliates may render portfolio management, valuation, operations, research, risk management, trading or other related services to AHL Partners LLP clients and/or AHL Partners LLP as affiliated “associated persons” of AHL Partners LLP and are subject to supervision by AHL Partners LLP. In addition, AHL Partners LLP may provide portfolio management, risk management, research, trading or other related services to the Participating Affiliates under separate services agreements. Fees may be paid by and received from the parties under these arrangements.

AHL Partners LLP complies with applicable U.S. securities regulations only with respect to its U.S. clients. Man provides a number of centralized functions to AHL Partners LLP, which includes trading, risk management, operations, middle office accounting, finance, proxy voting, class actions, human resources, facilities, tax, legal, compliance, information technology, among other such services. In addition, AHL’s affiliates may utilize certain of AHL’s investment management, research and trading services in providing services to their clients.

While much of this brochure applies to all of AHL Partner LLP’s U.S. clients, certain information applies to specific U.S. clients only. Important information regarding each fund and managed account, which includes investment objectives, risks, strategy, fees and other material information, including applicable conflicts of interest regarding relationships with affiliates, is contained in each fund’s offering documents and in each managed account's investment management agreement, as the case may be.
B. Description of Advisory Services
Please see Item 8 herein. This Brochure generally includes information about AHL Partners LLP and its relationships with its clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only. This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Funds which are “private funds” are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended (the "Securities Act"), and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. In the U.S., shares in the Funds are generally offered on a private placement basis to U.S. persons, and outside the U.S., in accordance with Regulation S of the Securities Act with respect to non-U.S. persons, and subject to certain other conditions, which are fully set forth in the offering documents for the Funds. The interests in the Funds are generally offered in the U.S. on a private placement basis, pursuant to Section 3(c)(7) of the Investment Company Act of 1940 as amended (the “Company Act”), to persons who are "accredited investors" as defined under the Securities Act and "qualified purchasers" as defined under the Company Act, and subject to certain other conditions, which are set forth in the offering documents for the Funds. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of an offering memorandum.
C. Availability of Customized Services for Individual Clients
AHL Partners LLP’s investment decisions and advice with respect to each Fund are subject to the relevant Fund's investment objectives and guidelines, as set forth in its offering documents. Similarly, AHL Partners LLP’s investment decisions and advice with respect to each managed account are subject to each client's investment objectives and guidelines, as set forth in the client's investment management agreement/trading advisor agreement, as well as any written instructions provided by the beneficial owner to AHL Partners LLP. An existing Fund may issue other classes, sub-classes, tranches, sub-tranches and/or series (or sub-series) of shares or interests, as applicable, in the future (or enter into "side letter" agreements with certain investor(s) that alter, modify or change the terms of the shares or interests, as applicable, held by the investor(s)), which may differ and may be more favourable from the shares or interests, as applicable, currently offered by the Fund in terms of, among other things, performance compensation, management fee, redemption rights (including redemption dates and notice periods), currency denomination, minimum and additional subscription amounts, informational rights and other rights. New classes, sub-classes, tranches, sub-tranches and/or series (or sub-series) of shares or interests, as applicable, may be issued (or "side letter" agreements may be entered into) by a Fund's board of directors and/or managing member, in its sole discretion, on behalf of the Fund, in consultation with AHL Partners LLP, without providing prior notice to, or receiving consent from, existing investors. The terms of such classes, sub-classes, tranches, sub-tranches and/or series (or sub-series) or "side letter" agreements will be determined by the board of directors and/or managing members, in its sole discretion, in consultation with AHL Partners LLP. In general, a Fund will not be required to notify investors of any such "side letter" agreements or any of the rights and/or terms or provisions thereof, nor will a Fund be required to offer such additional and/or different rights and/or terms to any or all of the other investors.
D. Wrap Fee Programs
AHL Partners LLP does not participate in wrap fee programs.
E. Assets Under Management
AHL Partners LLP manages approximately $44.2 billion in regulatory assets under management on a discretionary basis as of March 31, 2019. please register to get more info

FEES AND COMPENSATION
A fee schedule is omitted because this Brochure is being delivered only to qualified purchasers, as defined in section 2(a)(51)(A) of the Company Act. AHL Partners LLP does not maintain a basic fee schedule. The following is a general overview of the types of fees AHL Partners LLP charges its clients:
A. Advisory Fees and Compensation
AHL Partners LLP does not have a standardized fee schedule. For those private funds as disclosed herein AHL Partners LLP generally receives an annual management fee of up to 2% of a Fund's assets under management, payable monthly in arrears. AHL Partners LLP may receive incentive or performance-based compensation of up to 20% of net profits, realized and unrealized, generally payable annually in arrears. As applicable, AHL Partners LLP performance-based compensation complies with SEC Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). AHL Partners LLP’s fees and compensation may be shared with its affiliates providing services to the Fund. Certain of the Funds also charge their investors a services management fee on a monthly basis which generally ranges from .06% to .15% per annum of the Fund’s assets under management with a minimum charge of USD 20,000 per annum which is paid to an affiliate for their services with regards to the selection and appointment of service providers to the Funds. The Funds have different share classes which may have different fee schedules. Fees may be negotiable or waivable depending upon a variety of factors, including, among other things, type and extent of advisory services offered, amount of assets under management, the overall relationship with the investor and other services offered to the Fund or investor. AHL Partners LLP reserves the right to charge a discounted management fee or performance-based fee in its sole discretion as well as provide rebates on part or all of its fees to some or all investors or to intermediaries. AHL Partners LLP’s fees and compensation will be shared from time to time with its affiliates. Allocations may be made by investing in investment funds, managed accounts and other investment vehicles managed by AHL Partners LLP or its affiliates. No additional investment management fees will be charged by any affiliates of AHL Partners LLP. However, further operating expenses are likely to be incurred at the level of such investment funds, managed accounts and other investment vehicles. Such expenses will be borne indirectly by the relevant Fund. Generally, the investment management agreements with clients may be terminated by either party in accordance with the terms and notice period described in each investment management agreement. AHL Partners LLP’s investment management agreements are generally terminable with prior written notice, without penalty, or upon a breach, and/or also may be automatically renewed.
B. Payment of Fees
Fees and compensation paid to AHL Partners LLP or its affiliates by the Funds are generally paid by the Fund from its assets. With regards to the Funds, the fees are calculated by the Fund’s administrator and are paid directly from the Fund’s assets. Management fees are generally paid on a monthly or quarterly basis in arrears, services management fees are generally paid on a monthly basis in arrears, and the performance compensation is generally deducted on a monthly or annual basis, or at the time of a redemption or withdrawal, as applicable, further described in the Fund’s governing documents or managed account’s investment management agreement. With regards to managed accounts, fees are negotiated and agreed upon with the client directly and may include a management fee or a combination of management fee and performance compensation. Management fees and performance-based compensation may be pro-rated for partial periods. AHL Partner LLP’s employees may invest in one or more Funds. AHL Partner LLP’s employees may or may not be subject to a management fee and performance based compensation by these Funds. AHL Partner LLP reserves the right to charge employees a discounted fee or allocation in its sole discretion. In addition, AHL Partner LLP’s employee investments may or may not be subject to the same liquidity terms or fees as those of other investors in such funds.
C. Additional Fees and Expenses
Each class or series of Shares shall pay, directly or indirectly, all reasonable expenses incidental to AHL Partners LLP’s operations and business, the cost of which may vary, including, without limitation; (a) all investment expenses; (b) all fees and expenses of transactional, risk, market data and trade-related services (e.g., brokerage commissions and transaction costs, all fees for investment research and/or trade ideas, currency hedging costs, listing and audit costs, clearing and settlement charges, custodial fees, prime broker fees, interest expense, consulting, investment banking and any other professional fees or compensation relating to particular investments or contemplated investments and research- related expenses, including, without limitation, news and quotation equipment and services (including fees for data and software providers)); (c) the costs of AHL Partners LLP’s service providers including, without limitation, external accounting, legal, custodial, audit, tax preparation, paying agent and AHL Partners LLP’s secretarial fees and expenses (other than the costs of the Administrator which are borne by the Services Manager); (d) Directors fees, expenses and all of the costs of insurance for the benefit of the Directors (if any); (e) promotional and marketing expenses; (f) all entity-level taxes and corporate fees payable to governments or agencies; (g) all communication expenses with respect to investor services, of preparing, printing and distributing financial and other reports, proxy forms, prospectuses and similar documents to Shareholders and all expenses of meetings of Shareholders; (h) all interest on borrowings; (i) liquidation costs; (j) out-of-pocket costs and expenses suffered or incurred by the Services Manager for the benefit of AHL Partners LLP including expenses, if any, incurred by the Service Providers and charged to them and paid on behalf of the Investment Manager by the Services Manager; (k) external legal and compliance expenses (which include, without limitation, responding to formal and informal inquiries, subpoenas, investigations and other regulatory matters, indemnification expenses and expenses associated with regulatory filings relating to AHL Partners LLP; and (l) all administrative expenses. Such expenses will be borne on a pro-rata basis by each class or series of Shares. AHL Partners LLP may, in the absolute discretion of the Directors, also bear expenses, the cost of which may vary, incurred with respect to addressing the legal, tax and/or regulatory requirements of a particular class or series of shares or individual shareholders. In implementing the Investment Strategies, AHL Partners LLP may invest part or all of its assets in regulated or unregulated collective investment schemes or other pooled vehicles managed by AHL Partners LLP and/or other members of the Man Group. No additional investment management fees and performance fees will be charged at the level of the underlying investment vehicles managed by any members of the Man Group other than those set out in this Offering Memorandum. However, further operating expenses are likely to be incurred at the level of such underlying investment vehicles. Such expenses will be borne indirectly by AHL Partners LLP. AHL Partners LLP or its affiliates may pay certain of the aforementioned expenses and may therefore be entitled to be reimbursed by a Fund in respect of such expenses.
Allocation of Expenses
A Fund may incur an expense which forms part of a larger aggregate expense (“Expense”) relating to a number of investment entities for which AHL Partners LLP or its affiliates provide services. Such Expense will normally be allocated between the relevant investment entities, including the Fund, pro rata to the value of the net assets of the relevant investment entity, in conjunction with a flat fee per investment entity for a portion of the Expense, where possible and appropriate. The relevant Fund’s Directors shall liaise with AHL Partners LLP in order for the aforementioned Directors to determine the basis on which the Expense shall be allocated to the Fund and in doing so will seek to ensure that all expenses borne by the Fund are equitable. Costs may be amortised over time to ensure that large expenses are borne in an equitable manner. Each managed account may bear certain of the fees and expenses described above. The expenses borne by a managed account are set forth in the managed account's investment management agreement or as otherwise agreed with the managed account. please register to get more info

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
AHL Partners LLP accepts performance-based fees for some, but not all clients to which it provides investment advisory services. AHL Partners LLP may face a conflict of interest by managing accounts that are subject to a performance-based fee or allocation and accounts that are not subject to a performance-based fee or allocation, including that AHL Partners LLP may have an incentive to favour accounts for which it receives performance-based fees or allocations. AHL Partners LLP may also have an incentive to favour accounts from which AHL Partners LLP will receive a performance fee calculated at a higher rate over accounts from which AHL Partners LLP will receive a performance fee or allocation calculated at a lower rate. Furthermore, performance-based fee compensation may create an incentive for AHL Partners LLP to make riskier or more speculative investments than would be the case in the absence of such performance fees. Generally, AHL Partners LLP addresses these conflicts of interest through the adoption of conflicts of interest policies and procedures that are designed to ensure that the services provided or activities conducted are carried out with integrity and an appropriate degree of independence to protect the interests of clients. In addition, AHL Partners LLP addresses these conflicts of interest by utilizing an allocation of investment opportunity policy designed to treat all accounts fairly and equitably regardless of the types of fees or fee rates paid. Please see Items 11.B.2 and 11.D below for more information. please register to get more info

TYPES OF CLIENTS
AHL Partners LLP provides advisory or sub advisory services primarily to the Funds and institutional managed accounts on a discretionary basis. The securities of these Funds are not registered under the Securities Act. In addition, the Funds are not registered under the Company Act, and may or may not be continuously offered. In addition, AHL Partners LLP provides sub-advisory services to a registered investment company on a discretionary basis. Redemption rights with respect to each Fund are set forth in the offering memorandum for each Fund. Termination rights with respect to each managed account are set forth in the investment management agreement for each managed account. Investments in the Funds may be subject to certain qualifications and a minimum investment requirement which under certain conditions may be waived as set forth in the Fund’s offering memorandum. please register to get more info

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. Methods of Analysis and Investment Strategies
The descriptions set forth in this Brochure of specific advisory services that AHL Partners LLP offers to clients, and investment strategies pursued and investments made by AHL Partners LLP on behalf of its clients, should not be understood to limit in any way the Investment Manager’s investment activities. AHL Partners LLP may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that AHL Partners LLP considers appropriate, subject to each client's investment objectives and guidelines. The investment strategies AHL Partners LLP pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. AHL Partners LLP manages investment strategies (hereinafter, “AHL Programmes”), each of which employs sophisticated computerized processes to identify trading opportunities across a wide range of markets around the world. These systematic trading opportunities generally fall into three broad categories: momentum, fundamental, and technical strategies. AHL Partners LLP primarily uses proprietary quantitative models to implement the AHL Partners LLP Programmes and underlying investment strategies. Trading signals are generated and executed via a trading and implementation infrastructure. This process is quantitative, meaning that investment decisions are entirely driven by mathematical models based on quantitative analysis of historical relationships. It is underpinned by rigorous risk control, ongoing research, diversification and the constant quest for efficiency. Trading takes place around the clock and real-time price and non-price information is used to adjust positions across a diverse range of global markets. AHL Programmes may invest in a varied portfolio of financial instruments including, but not limited to, futures, options, forward contracts, swaps, CFDs, cash bonds, cash equities, securitized products and other financial derivatives both on and off exchange. AHL Partners LLP may, where possible, take short positions with respect to any or all investments. AHL Partners LLP may also systematically choose to hold derivative contracts (such as futures) through to cash or physical delivery. Sectors may be accessed directly or indirectly and include, without limitation, stocks, rates, bonds, debt, currencies, credit, energies, commodities, volatility and insurance risks. Sectors may also be accessed through direct or indirect investment in registered or unregistered collective investment schemes, funds or other pooled vehicle(s). In line with the principle of diversification, AHL Partners LLP’s approach to portfolio construction and asset allocation is premised on the importance of deploying investment capital across a full range of sectors and markets. Particular attention is paid to the correlation of markets and sectors, expected returns, market access costs and market liquidity. Portfolios are regularly reviewed and, when necessary, adjusted to reflect changes in these, and other, factors. A systematic process for adjusting market risk exposure in real time to reflect changes in the volatility of individual markets is also in place. Through AHL Partners LLP's ongoing investment in research and technology, the number and diversity of markets and strategies traded directly or indirectly by the AHL Programmes may change over the life of the investment, and may also be subject to specific legal, regulatory or investor specific restrictions. It should also be noted that the implementation of the AHL Programmes for certain AHL managed Funds may differ from the way in which similar AHL Programmes are implemented by other investment products managed by AHL Partners LLP or its affiliates. These differences may include, among other things, differences in the types of financial instruments, markets and asset classes traded which arise out of legal structuring, applicable law and other restrictions and/or considerations with respect to such investment products. Important information regarding each Fund, including investment objectives, strategy, and other material information, are contained in such Fund's offering memorandum.
B. Material, Significant or Unusual Risks Relating to Investment Strategies
The investment strategies AHL Partners LLP pursues are speculative and entail investment and market-related risks. There can be no assurance that client's investment objectives will be achieved. The client's activities could result in substantial losses under certain circumstances. Investing in securities involves risk of loss that clients should be prepared to bear. The following risk factors do not purport to be a complete list or explanation of all risks involved in an investment in a Fund or managed account managed by AHL Partners LLP. A Fund’s offering memorandum may include additional risks not included herein. The following risk factors may not be applicable to all clients. Investments in a Fund are speculative and involve a substantial degree of risk, including the risk that an investor could lose some or all of its investment in a Fund. Prospective investors should carefully consider the risks of investing, which include, without limitation, those set forth below which are more fully described in the applicable Fund's offering documents. These risk factors include only those risks AHL Partners LLP believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by AHL Partners LLP and do not purport to be a complete list or explanation of the risks involved in an investment in a Fund or to clients advised by AHL Partners LLP. Limited Regulatory Oversight AHL Partners LLP is registered with the SEC as an investment adviser under the Advisers Act. AHL Partners LLP is also registered with the CFTC as a CPO and CTA and is a member of NFA. AHL Partners LLP’s SEC and CFTC registrations and NFA membership do not indicate any level of expertise or qualification, nor has the SEC, CFTC or NFA in any respect approved AHL Partners LLP. Speculative investment There can be no assurance that the Fund will achieve its investment objective. An investment in a Fund is not guaranteed or subject to principal or capital protection and investors could lose some or all of their investment. Both an investment in the Fund and the investments which the Fund proposes to make are speculative. Furthermore, the Fund's investments may be subject to sudden, unexpected and substantial price movements (which may be influenced by factors such as changes in interest rates, currency exchange rate and economic and political events which are beyond the control of, and not predictable by, the Investment Manager). Unexpected and substantial price movements may lead to substantial fluctuations in the Net Asset Value of the Fund within a short period of time. Accordingly, an investment in the Interests should be made only by those persons who could afford to sustain a loss in such an investment. Regardless of the fact that the Investment Manager intends to manage the Fund diligently in pursuit of the Fund's investment objective, no guarantee or representation can be made that the Fund's investment program will be successful, that the various investment strategies and trading strategies utilized will have low correlation with each other or that the Fund's returns will exhibit low correlation with an investor's traditional investment portfolio. The Fund may utilize a variety of investment techniques, each of which can involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Fund's investment portfolio may be subject. In order to meet its investment objective, the Fund may invest in financial instruments of all kinds including various, non-standard, complex, thinly-traded and/or novel financial instruments in relation to their structure, operation and underlying exposure. By their very nature, investment in such financial instruments carries a greater risk than that of more common investment products, which may result in a complete or partial loss of investor capital. Investors unable or unwilling to bear such risks should not invest. Performance history There can be no assurance that information on the Investment Manager or the investment strategies set out in a Fund’s offering memorandum or elsewhere, including information on past performance, will be indicative of how the Interests will perform (either in terms of profitability or low correlation with other investments) in the future. Dependence on the Investment Manager The success of the Funds is significantly dependent upon the ability of AHL Partners LLP to develop and implement effectively the Fund's investment objective. Except as otherwise discussed herein, investors will be relying entirely on AHL Partners LLP to conduct and manage the affairs of the Fund. Subjective decisions made by the Investment Manager may cause the Funds to incur losses or to miss profit opportunities on which it could otherwise have capitalized. The performance of the Investment Manager is largely dependent on the talents and efforts of the personnel of AHL Partners LLP. The success of the Funds depends on AHL Partners LLP's ability to identify and willingness to provide acceptable compensation to attract, retain and motivate talented investment professionals and other personnel. There can be no assurance that AHL Partners LLP's investment professionals will continue to be associated with AHL Partners LLP throughout the life of one or more of the Funds and there is no guarantee that the talents of AHL's investment professionals could be replaced. The failure to attract or retain such investment professionals could have a material adverse effect on the Funds. Lack of negotiation The Investment Manager and the Manager have a common ownership structure and therefore the agreements between those parties have not been negotiated in the way in which agreements between arms-length parties may have been negotiated. Operational risk The Company depends on the Manager and the Investment Manager to develop appropriate systems and procedures to control operational risk. These systems and procedures may not account for every actual or potential disruption of their operations. The Manager’s and the Investment Manager’s respective businesses are dynamic and complex. As a result, certain operational risks are intrinsic to their operations, especially given the volume, diversity and complexity of transactions that the Investment Manager is expected to undertake daily on behalf of its clients. Disruptions in the Manager’s or the Investment Manager’s operations may cause the Company to suffer, among other things, financial loss, the disruption of its businesses, liability to third parties, regulatory intervention or reputational damage. Breaches in information technology security The Investment Manager maintains global information technology systems, consisting of infrastructure, applications and communications networks to support the Fund's as well as its own business activities. These systems could be subject to security breaches such as 'cyber- crime' resulting in theft, a disruption in the Investment Manager's ability to close out positions and the disclosure or corruption of sensitive and confidential information. Security breaches may also result in misappropriation of assets and could create significant financial and/or legal exposure for the Fund. The Investment Manager seeks to mitigate attacks on its own systems and those of the Fund but will not able to control directly the risks to third-party systems to which it may connect. Any breach in security of the Investment Manager's systems could disrupt the Fund's and the Investment Manager's business and may cause the Fund to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Performance fees Performance fees may create an incentive for the Investment Manager to make investments which are riskier than would be the case in the absence of a fee based on performance. In addition, performance fees may be calculated and paid based on unrealized gains which may subsequently not be realized. Substantial expenses payable regardless of profit The Funds will incur obligations to pay brokerage commissions, option premiums and other transactional costs to the brokers. The Funds will also incur obligations to pay a monthly management fee to the Investment Manager and pay the Fund's and its share of the operating, legal, accounting, auditing, Directors' and other fees and expenses including the costs of the offering of the Fund. These expenses will be payable regardless of whether the Fund makes a profit. Transaction costs The investment approach may involve a high level of trading and turnover of a Fund's investments which may generate substantial transaction costs which will be borne by the respective Fund and its investors. Lack of secondary market An investment in the Funds provides limited liquidity since a secondary market for shares is not usually expected to develop and shareholders have limited redemption rights. Limited liquidity An investment in one or more of the Funds, managed by the Investment Manager, provides limited liquidity since an active secondary market is not always expected to develop. The Interests are not freely transferable and are subject to limitations on withdrawals as provided herein. There is no public market for the Interests, and it is not expected that a public market will develop. A Fund may compulsorily withdraw all or any portion of a Member's Interest at any time in the interests of the Fund. A Fund also has broad powers to suspend the determination of Net Asset Value and/or withdrawals at the option of the Managing Member in a number of circumstances including any period during which the Managing Member so determines, all as more fully described elsewhere in the Fund’s offering memorandum. Use of Estimates for Subscriptions and Redemptions The Net Asset Value of the Fund holdings may be based in part on estimated valuations which may prove to be inaccurate or valuations which contain significant discretionary factors. Where subscription and/or redemption prices are based on estimated Net Asset Values, it should be noted that such prices may not be revised if such estimates prove to be inaccurate. In the case that any subscriptions or redemptions are effected at prices based wholly or partly on estimates then, to the extent that these estimates are too high, net new subscriptions at this price will provide a benefit to continuing investors, to the detriment of new investors, and net new redemptions will cause continuing investors to suffer a dilution in the value of their shares, to the benefit of redeemers. If these estimates are too low, net new subscriptions at this price will cause continuing investors to suffer a dilution in the value of their shares, to the benefit of new investor and net new redemptions will provide a benefit to continuing investors, to the detriment of redeemers. Effect of Substantial Redemptions Several factors cause substantial redemptions to be a risk factor for investors. The Investment Manager will pursue a variety of Investment Strategies that will take time to develop and implement. Subject to the applicable investment objective and Investment Strategies, a portion of the Fund’s portfolio may be comprised of financial instruments that are OTC and which may experience reduced liquidity. The Investment Manager may not be able to dispose of such financial instruments readily. Substantial redemptions could be triggered by a number of events, including, for example, unsatisfactory performance, significant change in personnel or management of the Investment Manager, a decision by the investors to liquidate the Fund’s assets by redeeming shares, investor reaction to redemptions from the Investment Manager's Other Accounts, legal or regulatory issues that investors perceive to have a bearing on the Fund or the Investment Manager, or other factors. Actions taken to meet substantial redemption requests from the Fund (as well as similar actions taken simultaneously in the Investment Manager's Other Accounts) could result in prices of financial instruments held by the Fund decreasing and in Fund expenses increasing (e.g., transaction costs and the costs of terminating agreements). The overall value of the Fund also may decrease because the liquidation value of certain assets may be materially less than their mark-to-market value. The Fund may be forced to sell its more liquid positions which may cause an imbalance in the portfolio that could adversely affect the remaining Shareholders. Substantial redemptions could also significantly restrict the Fund’s ability to obtain financing or derivatives counterparties needed for its investment and trading strategies, which would have a further material adverse effect on the Fund’s performance. Service Provider Risks The Investment Manager and certain of the service providers will not be liable, or have limited their liability, to the Fund under certain circumstances. Discretion to Employ New Strategies and Techniques The Investment Manager has considerable discretion in the types of markets which AHL Programmes may trade, and may trade in any issuer or group of related issuers, country, region and sector that it believes will help AHL Programmes achieve their investment objectives and, subject to investment objective and policies of the AHL Programmes, has the right to modify the investment strategies and hedging techniques of AHL Programmes without the consent of investors. Both new and modified investment strategies as well as hedging techniques may not be thoroughly tested in production trading before being allocated to the Funds and may have operational or theoretical shortcomings which could result in unsuccessful trades and, ultimately, losses to the Funds. In addition, any new investment strategy and hedging technique deployed by an AHL Programme may be more speculative than earlier techniques and may increase the risk of an investment in the Funds. Ramp-up periods There may be a limited amount of suitable investment opportunities for the Funds, especially during a "ramp-up period," with regard to each investment strategy pursued by each of the Funds. This could cause a Fund to hold significant cash from Member subscriptions, which may be invested in a variety of financial instruments, including, without limitation, money market funds, US treasury securities or any other instruments deemed appropriate by the Investment Manager. Long "ramp-up periods" and/or holding excess cash and investments in cash equivalent financial instruments may reduce the overall performance of a Fund. It may, therefore, be some time, due to market conditions, bid/ask prices, execution opportunities or other factors affecting the availability or attractiveness of investment opportunities, before a Fund is able to locate suitable investment opportunities. Therefore, the overall performance of a Fund may be reduced. Risk Relating to Investments General Economic and Market Conditions The success of the Investment Manager’s investment decisions on behalf of its investors will be impacted by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the Investment Manager’s investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of a financial instruments price as well as the liquidity of the totality of a Fund’s investments. Volatility and/or illiquidity could impair the Funds profitability or result in losses. The Funds may maintain substantial positions that can be adversely impacted by the level of volatility in the financial markets — the larger the positions, the greater the potential for loss. The economies of some countries may differ favourably or unfavourably from the US and Western European economies in such respects as growth of gross domestic product, rate of inflation, currency depreciation, asset reinvestment, resource self-sufficiency and balance of payments position. Further, certain economies are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. The economies of certain countries may be based, predominantly, on only a few industries and may be vulnerable to changes in trade conditions and may have higher levels of debt or inflation. Model and Data Risk The Investment Manager relies heavily on proprietary mathematical quantitative models (each a “Model” and collectively, “Models”) and data developed both by the Investment Manager and those supplied by third parties (collectively, “Data”) rather than granting trade-by-trade discretion to the Investment Manager’s investment professionals. In combination, Models and Data are used to construct investment decisions, to value both current and potential investments (including, without limitation, for trading purposes, and for the purposes of determining the Net Asset Value of the Funds), to provide risk management insights and to assist in hedging the Fund’s positions and investments. Models, Data and the processes supporting these components are known to have errors, omissions, imperfections and malfunctions (collectively, “System Events”). The Investment Manager seeks to reduce the incidence and impact of System Events, to the extent feasible, through a combination of internal testing, simulation, real-time monitoring, use of independent safeguards in the overall portfolio management process and often in the software code itself. Despite such testing, monitoring and independent safeguards, System Events will result in, among other things, the execution of unanticipated trades, the failure to execute anticipated trades, delays in the execution of anticipated trades, the failure to properly allocate trades, the failure to properly gather and organise available data, the failure to take certain hedging or risk reducing actions and/or the taking of actions which increase certain risk(s)—all of which may have materially adverse effects on the Funds. System Events in third- party provided Data are generally entirely outside the control of the Investment Manager. The research and modelling processes engaged in by the Investment Manager on behalf of the Funds are extremely complex and involve the use of financial, economic, econometric and statistical theories, research and modelling; the results of this investment approach must then be translated into computer code. Although the Investment Manager seeks to hire individuals skilled in each of these functions and to provide appropriate levels of oversight and employ other mitigating measures and processes, the complexity of the individual tasks, the difficulty of integrating such tasks, and the limited ability to perform “real world” testing of the end product, even with 12 simulations and similar methodologies, raise the chances that Model code may contain one or more coding errors, thus potentially resulting in a System Event and further, one or more of such coding errors could adversely affect the Fund’s investment performance. The Investment Strategies of the Investment Manager are highly reliant on the gathering, cleaning, culling and performing of analysis of large amounts of Data. Accordingly, Models rely heavily on appropriate Data inputs. However, it is impossible and impracticable to factor all relevant, available Data into forecasts, investment decisions and other parameters of the Models. The Investment Manager will use its discretion to determine what Data to gather with respect to each Investment Strategy and what subset of that Data the Models take into account to produce forecasts which may have an impact on ultimate investment decisions. In addition, due to the automated nature of Data gathering, the volume and depth of Data available, the complexity and often manual nature of Data cleaning, and the fact that the substantial majority of Data comes from third-party sources, it is inevitable that not all desired and/or relevant Data will be available to, or processed by, the Investment Manager at all times. Irrespective of the merit, value and/or strength of a particular Model, it will not perform as designed if incorrect Data is fed into it which may lead to a System Event potentially subjecting the Funds to a loss. Further, even if Data is input correctly, “model prices” anticipated by the Data through the Models may differ substantially from market prices, especially for financial instruments with complex characteristics, such as derivatives, in which the Funds may invest. Where incorrect or incomplete Data is available, the Investment Manager may, and often will, continue to generate forecasts and make investment decisions based on the Data available to it. Additionally, the Investment Manager may determine that certain available Data, while potentially useful in generating forecasts and/or making investment decisions, is not cost effective to gather due to, among other factors, the technology costs or third -party vendor costs and, in such cases, the Investment Manager will not utilise such Data. The Investment Manager has full discretion to select the Data it utilises. The Investment Manager may elect to use or may refrain from using any specific Data or type of Data in generating forecasts or making trading decisions with respect to the Models. The Data utilised in generating forecasts or making trading decisions underlying the Models may not be (i) the most accurate data available or (ii) free of errors. The Data set used in connection with the Models is limited. The foregoing risks associated with gathering, cleaning, culling and analysis of large amounts of Data are an inherent part of investing with a quantitative, process-driven, systematic adviser such as the Investment Manager. When Models and Data prove to be incorrect, misleading or incomplete, any decisions made in reliance thereon expose the Funds to potential losses and such losses may be compounded over time. For example, by relying on Models and Data, the Investment Manager may be induced to buy certain investments at prices that are too high, to sell certain other investments at prices that are too low, or to miss favourable opportunities altogether. Similarly, any hedging based on faulty Models and Data may prove to be unsuccessful and when determining the Net Asset Value of the Funds, any valuations of the Fund’s investments that are based on valuation Models may prove to be incorrect. In addition, Models may incorrectly forecast future behaviour, leading to potential losses on a cash flow and/or a mark-to-market basis. Furthermore, in unforeseen or certain low-probability scenarios (often involving a market event or disruption of some kind), Models may produce unexpected results which may or may not be System Events. Errors in Models and Data are often extremely difficult to detect, and, in the case of Models, the difficulty of detecting System Events may be exacerbated by the lack of design documents or specifications. Regardless of how difficult their detection appears in retrospect, some System Events may go undetected for long periods of time and some may never be detected. When a System Event is detected, a review and analysis of the circumstances that may have caused a reported System Event will be completed and is overseen by an Escalation Committee made up of appropriate senior personnel. Following this review, the Investment Manager in its sole discretion may choose not to address or fix such System Event, and the third party software will lead to System Events known to the Investment Manager that it chooses, in its sole discretion, not to address or fix. The degradation or impact caused by these System Events can compound over time. When a System Event is detected, the Investment Manager generally will not, as part of the review of circumstances leading to the System Event, perform a materiality analysis on the potential impact of a System Event. The Investment Manager believes that the testing and monitoring performed on Models and the controls adopted to ensure processes are undertaken with care will enable the Investment Manager to identify and address those System Events that a prudent person managing a quantitative, systematic and computerised investment programme would identify and address by correcting the underlying issue(s) giving rise to the System Events, however there is no guarantee of the success of such processes. Shareholders should assume that System Events and their ensuing risks and impact are an inherent part of investing with a process-driven, systematic investment manager such as the Investment Manager. Accordingly, the Investment Manager does not expect to disclose discovered System Events to the Funds or to Shareholders. The Funds will bear the risks associated with the reliance on Models and Data including bearing all losses related to System Events other than in relation to losses arising from the Investment Manager’s wilful default, fraud or Gross Negligence or breach of fiduciary duty under ERISA, if applicable. Obsolescence Risk The Investment Manager is unlikely to be successful in the deployment of its quantitative, systematic, investment strategies unless the assumptions underlying the Models are realistic and either remain realistic and relevant in the future or are adjusted to account for changes in the overall market environment. If such assumptions are inaccurate or become inaccurate and are not promptly adjusted, it is likely that the Models will not generate profitable trading signals. If and to the extent that the Models do not reflect certain relevant factors, and the Investment Manager does not successfully address such omission through its testing and evaluation by modifying the Models accordingly, major losses may result—all of which will be borne by the Funds. The Investment Manager will continue to test, evaluate and add new Models which may also result in the modification of existing Models from time to time. Investors will not be informed of nor will investors approve the addition, modification or removal of Models and investment strategies. There can be no assurance as to the effects (positive or negative) of any changes including additions, modifications and/or removals of Models or investment strategies on a Fund’s performance. Crowding/Convergence There is significant competition among quantitatively-focused managers and the ability of the Investment Manager to deliver returns that have a low correlation with global aggregate equity markets and other hedge funds is dependent on its ability to employ Models that are simultaneously profitable and differentiated from those employed by other managers. To the extent that the Investment Manager is not able to develop sufficiently differentiated Models, the Fund’s investment objective may not be met, irrespective of whether the Models are profitable in an absolute sense. In addition, to the extent that the Models come to resemble those employed by other managers, there is an increased risk that a market disruption may negatively affect predictive Models such as those employed by the Investment Manager, as such a disruption could accelerate reductions in liquidity or rapid re-pricing due to simultaneous trading across a number of funds utilising Models (or similar quantitatively-focused investment strategies) in the marketplace. Trading Systems and Execution of Orders The Investment Manager relies extensively on computer programmes, systems, technology, Data and Models to implement its execution strategies and algorithms. The Investment Manager’s investment strategies, trading strategies and algorithms depend on its ability to establish and maintain an overall market position in a combination of financial instruments selected by the Investment Manager. There is a risk that the Investment Manager’s proprietary algorithmic trading system may not be able to adequately react to a market event without serious disruption. Further, trading strategies and algorithms may malfunction causing severe losses. While the Investment Manager has employed tools to allow for human intervention to respond to significant system malfunctions, it cannot be guaranteed that losses will not occur in such circumstances as unforeseen market events and disruptions and execution system issues. Orders may not be executed in a timely and efficient manner due to various circumstances, including, without limitation, trading volume surges or systems failures attributable to the Investment Manager, the Investment Manager’s counterparties, brokers, dealers, agents or other service providers. In such event, the Investment Manager might only be able to acquire or dispose of some, but not all, of the components of such position, or if the overall position were to need adjustment, the Investment Manager might not be able to make such adjustment. As a result, the Funds would not be able to achieve the market position selected by the Investment Manager, which may result in a loss. Hedging Transactions The Investment Manager may utilise financial instruments both for investment purposes and for risk management purposes in order to: (a) protect against possible changes in the market value of one or more of the positions of the Funds investment portfolio resulting from fluctuations in the markets and changes in interest rates; (b) protect the Funds unrealised gains in the value of its investment portfolio; (c) facilitate the sale of any such investments; (d) enhance or preserve returns, spreads or gains on any investment in the one or more of the Fund’s portfolios; (e) hedge against a directional trade; (f) hedge the interest rate, credit or currency exchange rate on financial instruments; (g) protect against any increase in the price of any financial instruments the Investment Manager anticipates purchasing at a later date; or (h) act for any other reason that the Investment Manager deems appropriate. The Investment Manager will not be required to hedge any particular risk in connection with a particular transaction or its portfolios generally. Furthermore, the Investment Manager may not anticipate a particular risk so as to hedge against it. While the Investment Manager may enter into hedging transactions to seek to reduce risk, such transactions may result in a poorer overall performance for the Funds than if the Investment Manager had not engaged in any such hedging transaction. Moreover, it should be noted that the Funds will always be exposed to certain risks that may not be fully hedged. Limited Ability to Hedge Hedging may not be possible for certain of the insurance-linked instruments because there may not be “negatively correlated” risks. The principal means of controlling overall risk exposure in the risk-linked market is by diversification. Trade Error Risk The complex execution modalities operated by the Investment Manager and the speed and volume of trading invariably result in occasional trades being executed which, with the benefit of hindsight, were not required or intended by the execution strategy or occasional trades not being executed when they should have been. To the extent a trade error is caused by a counterparty, such as a broker, the Investment Manager will generally, to the extent reasonable and practical, attempt to recover any loss associated with such trade error from the respective counterparty. To the extent a trade error is caused by the Investment Manager, a formalised process is in place for the documentation and resolution of such trade errors, provided that during any time that the underlying assets of the Fund are considered for purposes of ERISA or Section 4975 of the Code to be plan assets, the Investment Manager will be liable for trade errors caused by a breach of investment guidelines or of fiduciary duties under ERISA. Given the volume, diversity and complexity of transactions executed by the Investment Manager on behalf of each Fund, investors should assume that trade errors will occur on occasion. If such trade errors result in gains to the Fund(s), such gains will be retained by the Fund(s). However, if a trade error result in losses, they will be borne by the Investment Manager in accordance with its internal policies unless otherwise determined by the Directors. Limited Resources of Issuers The issuers of insurance-linked instruments often are thinly capitalised, special-purpose entities that do not have ready access to additional capital. In the event of unanticipated expenses or liabilities, such entities may not have the resources available to pay such expenses or liabilities or the required interest and/or principal on their issued securities. Trade and Settlement Systems Risks Each Fund depends on the Investment Manager and its other service providers to develop and implement adequate systems for processing of each Fund’s trading and settlement activities. Further, the Investment Manager relies on systems and technology (and may rely on new systems and technology in the future) for various purposes including, without limitation, to trade, clear and settle transactions, to evaluate certain financial instruments, to monitor its portfolio and net capital, and to generate risk management and other reports that are critical to oversight of a Fund’s activities. Certain of the Investment Manager's operations processes will be dependent upon systems operated by third parties, including but not limited to executing brokers, prime brokers, the administrator of the market counterparties and their sub-custodians as well as other service providers. These third-party programmes, systems and/or technology may be subject to certain limitations, including, but not limited to, those caused by computer "worms", viruses, power failures and/or other technology-related impairments. The Investment Manager’s operations are highly dependent on each of these systems and technology and the successful operation of such systems and technology is often out of the Investment Manager's control. The failure of one or more systems and technology or the inability of such systems to satisfy the Investment Manager’s current and evolving requirements could have a material adverse effect on the Fund. For example, systems failures could cause settlement of trades to fail, lead to inaccurate accounting, recording or processing of trades, and cause inaccurate reports, all or any of which may affect the ability of the Investment Manager to monitor and/or manage the investment portfolio and risks. Unpredictability of Risk The type, frequency and severity of catastrophic, pandemic and insurance-related events associated with insurance-linked instruments are difficult or impossible to predict. In some cases, the Investment Manager will rely on industry and other models that utilise, among other things, historical information, actuarial analysis and related models to apply a price associated with the corresponding risk of the instrument. Such models contain a material amount of uncertainty. In particular, any change in longevity and/or mortality risk profiles against those predicted by such models would materially adversely affect the performance of the Company. Cash Management The Fund may enter into arrangements by which cash not required by the Fund for trading purposes will be managed by the Investment Manager. Such arrangements may include the entry by the Fund into repurchase or reverse repurchase transactions and other cash management arrangements, including holding cash in bank accounts or secured or unsecured deposits, or investing such cash in corporate or government bonds, or such other instruments as deemed appropriate by the Investment Manager. A repurchase transaction involves the sale of securities by a seller to a buyer for a purchase price, and an agreement for the seller to repurchase such securities on a mutually agreed future date for the same purchase price, plus interest at a negotiated rate. From the perspective of the buyer, the transaction is referred to as a reverse repurchase transaction, and involves buying securities against payment of a cash price, with the buyer agreeing to resell the securities at a future date, and the original seller agreeing to repurchase such securities at the same price, plus interest at a negotiated rate. Such transactions are economically equivalent to a cash loan collateralized by the securities. The use of repurchase and reverse repurchase agreements by the Fund involves certain risks. For example, if the seller of securities to the Fund under a reverse repurchase transaction defaults on its obligation to repurchase the underlying securities, as a result of its bankruptcy or otherwise, the Fund will seek to dispose of such securities, which action could involve costs or delays. The Fund may suffer a loss to the extent that the proceeds from the disposal of the underlying securities are less than the repurchase price due from the defaulting seller. Borrowing for Operations The Fund may borrow money for cash management purposes and to meet withdrawals that would otherwise result in the premature liquidation of its investments. The use of short-term borrowing creates several additional risks for the Fund. If the Fund is unable to service the debt, a secured lender could liquidate the Fund's position in some or all of the financial instruments that have been pledged as collateral and cause the Fund to incur significant losses. The occurrence of other material defaults and other financing agreements may trigger cross- defaults under the Fund's agreements with other brokers, lenders, clearing firms or other counterparties, multiplying the materially adverse impact to the Fund. The amount of debt which the Fund may have outstanding at any time may be large in relation to its assets. Consequently, the level of interest rates generally, and the rates at which the Fund can borrow particularly, will affect the operating results of the Fund. Involuntary Disclosure Risk The ability of the Investment Manager to achieve its investment goals for the Funds is dependent in large part on its ability to develop and protect its models and proprietary research. The models and proprietary research and the Models and Data are largely protected by the Investment Manager through the use of policies, procedures, agreements, and similar measures designed to create and enforce robust confidentiality, non-disclosure, and similar safeguards. However, aggressive position-level public disclosure obligations (or disclosure obligations to exchanges or regulators with insufficient privacy safeguards) could lead to opportunities for competitors to reverse-engineer the Investment Manager's models, and thereby impair the relative or absolute performance of the Funds. Limited Diversification and Risk Management Failures A Fund's portfolio could become significantly concentrated in a limited number of issues, types of financial instruments, industries, sectors, strategies, countries, or geographic regions, and any such concentration of risk may increase losses suffered by a Fund. This limited diversity could expose a Fund to losses disproportionate to market movements in general. Even when the Investment Manager attempts to control risks and diversify the portfolio, risks associated with different assets may be correlated in unexpected ways, with the result that a Fund faces concentrated exposure to certain risks. In addition, many pooled investment vehicles pursue similar strategies, which creates the risk that many funds would be forced to liquidate positions at the same time, reducing liquidity, increasing volatility and exacerbating losses. Although the Investment Manager attempts to identify, monitor and manage significant risks, these efforts do not take all risks into account and there can be no assurance that these efforts will be effective. Many risk management techniques are based on observed historical market behavior, but future market behaviour may be entirely different. Any inadequacy or failure in the Investment Manager's risk management efforts could result in material losses for a Fund. Competition for Investments Certain markets in which the Investment Manager, on behalf of the Funds, may invest are extremely competitive for attractive investment opportunities and, as a result, there may be reduced expected investment returns, or the liquidity of one or more of the Fund’s positions may be reduced. There can be no assurance that the Investment Manager will be able to identify or successfully pursue attractive investment opportunities in such environments. Among other factors, competition for suitable investments from other pooled investment vehicles, the public equity markets and other investors may reduce the availability of investment opportunities. There has been significant growth in the number of firms organised to make such investments, which may result in increased competition to the Investment Manager, on behalf of the Funds, in obtaining suitable investments. Market Risk The Investment Manager, on behalf of the Funds, may make investments in markets that are volatile and/or which may become illiquid. Accordingly, the ability of the Investment Manager to respond to market movements may be impaired, which may result in significant losses to the Funds. To the extent that the Investment Manager, on behalf of the Funds, invests on a public exchange, it bears the risk that the exchange may exercise a right to suspend or limit trading in all securities that it lists. Such a suspension could render it impossible for the Investment Manager to liquidate Fund positions and thereby exposes the Funds to potential losses. In addition, there is no guarantee that markets will remain liquid enough for the Investment Manager to close out positions on behalf of the Funds. Catastrophes Insurance-linked instruments are subject to incurring material losses as a result of natural, man- made or other catastrophes or pandemics. Any event which might result in an increase in the likelihood and/or severity of such events (for example, a pandemic virus leading to increased mortality) could materially adversely affect the performance of the Funds. Systemic Risk Credit risk may arise through a default by one of several large institutions that are dependent on one another to meet their liquidity or operational needs, so that a default by one institution causes a series of defaults by the other institutions. This is sometimes referred to as a "systemic risk" and may adversely affect financial intermediaries, such as clearing agencies, clearinghouses, banks, securities firms and exchanges, with which the Investment Manager interacts on a daily basis. Such risks may be exacerbated by the obligations for certain financial instruments to be centrally cleared by a third-party clearing house. Further, world events and/or the activities of one or more large participants in the financial markets and/or other events or activities of others could result in a temporary systemic breakdown in the normal operation of financial markets. Such events could result in liquidity and counterparty issues which could result in substantial losses. Counterparty Risk The Investment Manager, and in turn the Funds, will have significant credit and operational risk exposure to its counterparties, which will require the Funds to post collateral to support its obligations in connection with transactions involving forwards, swaps, futures, options and other derivative instruments. Generally, counterparties will have the right to sell, pledge, re- hypothecate, assign, use or otherwise dispose of the collateral posted by the Funds in connection with such transactions. Additionally, for example, the Funds may lend securities, on a collateralised and an uncollateralised basis, from its portfolio. Investments are normally entered into between the Funds and brokers as principal (and not as agent). Accordingly, the Fund is exposed to the risk that brokers may, in an insolvency or similar event, be unable to meet their contractual obligations to the Funds. Should any counterparty transacting with the Investment Manager (or other underlying vehicles through which the Funds directly or indirectly invests) become insolvent, any claim that the Funds (or underlying vehicles) may have against such counterparties would ordinarily be unsecured. Such "counterparty risk" is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Funds has concentrated its transactions with a single or small group of counterparties. If there is a default by the counterparty to a transaction, the Fund will under most normal circumstances have contractual remedies and in some cases collateral pursuant to the agreements related to the transaction. However, exercising such contractual rights may involve delays or costs which could result in the Net Asset Value of the Funds being less than if the Funds had not entered into the transaction. If one or more of the Investment Manager’s counterparties that act as custodian, prime broker or broker-dealer for the Funds were to become insolvent or the subject of liquidation proceedings, there exists the risk that the recovery of the Funds securities and other assets from such custodian, prime broker or broker-dealer will be delayed or be of a value less than the value of the securities or assets originally entrusted to such custodian, prime broker or broker- dealer. In addition, the Funds cash held with the counterparties as collateral may not be segregated from the counterparty's own cash and may be used by the counterparty in the course of its investment business. The Funds will therefore rank as an unsecured creditor in relation thereto and in the event of insolvency of any such counterparties, the Funds may not be able to recover such equivalent assets in full. Investors should assume that the insolvency of any counterparty would result in a loss to the Funds, which could be material. Interest and Exchange Rate Risks Fluctuations in exchange rates could cause the value of investments made by Members to increase or decrease. The Funds and the underlying vehicles through which the Funds directly or indirectly invests may have exposure to foreign exchange and/or interest rate risks. The Funds may seek to mitigate its risks through hedging transactions. To the extent these hedging transactions are imperfect or are only placed over a portion of the target investment exposure, the relevant Members will realize the resulting benefit or loss. The Funds may invest in financial instruments denominated in non-US currencies, the prices of which are determined with reference to currencies other than the US Dollar. However, the Funds value its financial instruments in US Dollars. The Funds may or may not seek to hedge its non-US currency exposure by entering into currency hedging transactions, such as treasury locks, forward contracts, futures contracts and cross-currency swaps. There can be no guarantee that financial instruments suitable for hedging currency or market shifts will be available at the time when the Funds wishes to use them, or that hedging techniques employed by the Funds will be effective. Furthermore, certain currency market risks may not be fully hedged or hedged at all. To the extent unhedged, the value of a Fund's direct or indirect positions in non-US investments will fluctuate with US Dollar exchange rates as well as with the price changes of the investments in the various local markets and currencies. In such cases, an increase in the value of the US Dollar compared to the other currencies in which a Fund makes investments will reduce the effect of any increases and magnify the effect of any decreases in the prices of a Fund's financial instruments in their local markets and may result in a loss to a Fund. Conversely, a decrease in the value of the US Dollar will have the opposite effect on a Fund's non-US Dollar investments. Terrorism and Catastrophe Risks A Fund's portfolio is subject to the risk of loss arising from exposure that it may incur, directly or indirectly, due to the occurrence of various events, including, without limitation, hurricanes, earthquakes and other natural disasters, terrorism and other catastrophic events. These risks of loss can be substantial and could adversely affect the return of a Fund. Leverage and Financing Arrangements The Funds may borrow and/or utilize various forms of leverage including leveraged or short positions under derivative instruments. While leverage presents opportunities for increasing total return, it has the effect of potentially increasing losses as well. Accordingly, any event which adversely affects the value of an investment by a Fund would be magnified to the extent leverage is employed, and substantial losses may result from unwinding short positions. The Funds may, in particular, generate leverage through the use of options, futures, options on futures, swaps and other synthetic or derivative financial instruments. Such financial instruments inherently contain much greater leverage than a non-margined purchase of the underlying security, commodity or instrument. This is due to the fact that generally only a small portion (and in some cases none) of the value of the underlying security, commodity or instrument is required to be paid in order to make such investments. As a result of leverage employed in relation to these instruments, small changes in the value of the instruments may cause a relatively large change in the value of a Fund. Many such financial instruments are subject to variation or other interim margin requirements, which may force premature liquidation of investment positions. As a general matter, the banks and dealers that provide financing to the Funds can apply essentially discretionary margin, haircut financing as well as security and collateral valuation policies. For example, should the financial instruments pledged to brokers to secure a Fund's margin accounts decline in value, a Fund could be subject to a "margin call", pursuant to which a Fund must either deposit additional funds or financial instruments with the broker or suffer mandatory liquidation of the pledged financial instruments to compensate for the decline in value. In the event of a sudden drop in the value of a Fund's portfolio, the Fund might not be able to liquidate financial instruments quickly enough to satisfy its margin requirements. Increases in the amount of margin or similar payments could result in the need for trading activity at times and prices which could be disadvantageous to the Fund or the underlying vehicles through which the Fund directly or indirectly invests and could result in substantial losses. As a consequence of leverage, interest expense may be material as a percentage of the assets of the Fund. Interest expense could force a reduction in the exposure of the Interests to the investment strategies. The use of such leverage means that even comparatively small losses, or insufficient profits to offset expenses, could rapidly deplete the capital available to the Fund and reduce or eliminate its profit potential. Further fees relating to any Financing Arrangements such as arrangement, commitment, minimum utilization and renewal fees may also be payable. Changes by banks and dealers in such policies, or the imposition of other credit limitations or restrictions, whether due to market circumstances or government, regulatory or judicial action, may result in large margin calls, loss of financing, forced liquidations of positions at disadvantageous prices, termination of swap and repurchase agreements and cross-defaults to agreements with other dealers. Any such adverse effects may be exacerbated in the event that such limitations or restrictions are imposed suddenly and/or by multiple market participants. The imposition of any such limitations or restrictions could compel the Fund to liquidate all or part of its portfolio at disadvantageous prices, which may lead to a complete loss of the Fund's equity. There can be no assurance that the Fund will be able to maintain adequate Financing Arrangements or avoid having to close out positions at losses which if held would have been profitable. There is also no assurance that any Financing Arrangement will be renewed and, if any Financing Arrangement in respect of the Interests is renewed, it may be renewed on less favourable terms. In particular, third parties may not be available to act as Financing Providers. Additionally, any Financing Arrangement may be subject to early termination in accordance with its terms and may be terminated by a counterparty. A loss of, a termination of, or a reduction in, a Financing Arrangement may have the effect of causing the Fund to reduce its overall investment exposure in respect of the Interests with a corresponding reduction in investment return expectations. The renewal of a Financing Arrangement might be subject to a change in terms of that Financing Arrangement including but not limited to a change in applicable interest margins. Equities The Funds may invest in equity securities and equity derivatives. The value of these financial instruments generally will vary with the performance of the issuer and movements in the equity markets. As a result, the Funds may suffer losses if it invests in equity instruments of issuers whose performance diverges from the Investment Manager's expectations or if equity markets generally move in a single direction and the Investment Manager has not hedged against such a general move. The Investment Manager also may be exposed to risks that issuers will not fulfil contractual obligations such as, in the case of convertible securities, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. Fixed income securities Fixed income securities are subject to the risk of the issuer being unable to meet its principal and interest payment obligations (credit risk) and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). Fixed -income securities are sensitive to changes in interest rates. An increase in interest rates will generally reduce the value of fixed-income securities, while a decline in interest rates will generally increase the value of fixed -income securities. The Company’s performance will therefore depend in part on the Investment Manager’s ability to anticipate and respond to such fluctuations in market interest rates, and to utilise appropriate strategies to maximise returns, while attempting to minimise the associated risks to investment capital. Investments in Emerging Markets The Funds may invest its assets in securities or currencies of emerging market countries. Investing in emerging markets involves additional risks and special considerations not typically associated with investing in other more established please register to get more info

DISCIPLINARY INFORMATION
A. CME Settlement
Pursuant to an offer of settlement, Man Investments Limited (“MIL”), an advisory affiliate of AHL Partners LLP, presented at a hearing on March 22, 2012 to a panel of the CME Business Conduct Committee (“BCC”) whereby MIL voluntarily submitted itself to the jurisdiction of the BCC for purposes of settling the following matter. On November 4, 2011, a date subject to the 300 contract position limit for the expiring November 2011 feeder cattle contract (“Nov 11 Feeder”), MIL maintained a long Nov 11 Feeder position of 436 contracts, 136 contracts (45.33%) in excess of the applicable speculative spot month position limit. MIL liquidated the overage position and realized profits in the amount of $35,050. The BCC found that as a result, MIL violated CME Rule 562. Without admitting or denying the rule violation, MIL entered into a settlement offer to pay a fine to the CME in the amount of $25,000 and to disgorge profits in the amount of $35,050.
B. NYMEX Settlement
Pursuant to a separate offer of settlement, MIL presented at a hearing on March 21, 2012 to a panel of the NYMEX Business Conduct Committee (“BCC”) whereby MIL voluntarily submitted itself to the jurisdiction of the BCC for purposes of settling the following matter. On November 20, 2009, a date subject to the 1000 contract expiration month position limit for the expiring December 2009 Natural Gas Futures contracts (“Dec 09 Nat Gas”), MIL maintained a short Dec 09 Nat Gas position of 4,455 contracts, 3,455 contracts (345.5%) in excess of the applicable speculative spot month position limit. The BCC found that as a result MIL violated NYMEX Rule 443. Without admitting or denying the rule violation, MIL entered into a settlement offer to pay a fine to the NYMEX in the amount of $70,000. please register to get more info

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. Broker-Dealer Registration Status
AHL Partners LLP is not registered as a broker-dealer and does not have any application pending to register with the SEC as a broker-dealer. AHL Partners LLP utilizes the sales team of its affiliate, Man Investments Inc. ("MII") to assist in the marketing of its investment services in the U.S. MII is a limited purpose broker-dealer registered with the SEC and a member of Financial Industry Regulatory Authority, Inc. ("FINRA"). MII acts as solicitor, selling agent and/or investor servicing agent for certain AHL clients and Funds for which it may be compensated as agreed between AHL Partners LLP and MII.
B. Futures Commission Merchant, Commodity Pool Operator or Commodity
Trading Adviser Registration Status
AHL Partners LLP is a commodity pool operator (“CPO”) and commodity trading advisor (“CTA”) registered with the Commodity Futures Trading Commission (“CFTC”) and a member of the National Futures Association (“NFA”).
C. Material Relationships or Arrangements with Industry Participants
AHL Partners LLP through its managing member Man Investments Limited is affiliated with the following London based entities that are authorized and regulated by the Financial Conduct Authority: Financial Risk Management Limited (“FRM”), Man Solutions Limited, an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA; GLG Partners LP, an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA and Man Global Private Markets UK Ltd. an investment adviser registered with the SEC. AHL Partners LLP is also affiliated with Man Investments AG (“MIAG”) and Man Investments (CH) AG, both registered with Swiss Financial Market Supervisory Authority (FINMA). Certain of AHL Partners LLP’s Funds have a distribution agreement with MIAG. AHL Partners LLP is also affiliated with FRM Investment Management Limited, and Man Fund Management (Guernsey) Limited both based in Guernsey and regulated by the Guernsey Financial Services Commission. FRM Investment Management Limited may, on behalf of its clients and/or funds, invest in the Funds advised by AHL Partners LLP or its affiliates. Nevertheless, FRM Investment Management Limited undergoes the same due diligence process for investments it considers in Funds advised by AHL Partners LLP as it would for unaffiliated funds. Furthermore, AHL Partners LLP is affiliated with the following New York based entities: Man Investments Inc., a limited purpose broker dealer registered with the SEC and member of FINRA which provides placement agent services to certain of AHL Partners LLP Funds as well as marketing and sales services to AHL Partners LLP; Man Solutions (USA) LLC, an investment adviser registered with the SEC; FRM Investment Management (USA) LLC, an investment adviser registered with the SEC, a commodity pool operator and commodity trading advisor registered with the CFTC and a member of the NFA; and GLG LLC, an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA. In addition, AHL Partners LLP is affiliated with Numeric Investors LLC, based in Boston, MA which is an investment adviser registered with the SEC, a commodity pool operator registered with the CFTC and a member of the NFA; Silvermine Capital Management LLC, based in Stamford, CT which is an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA and Man Global Private Markets (USA) Inc., based in Charlotte, NC which is an investment adviser registered with the SEC. Man Investments (USA) Corp., a corporation incorporated in the State of Delaware, United States, is the managing member of the AHL Delaware Funds and has responsibility for providing management services to the Delaware Funds. AHL Partners LLP is also affiliated with Man Investments (Hong Kong) Ltd, an entity licensed by the Hong Kong Securities and Futures Commission. AHL Partners LLP utilizes Man Investments (Hong Kong) Ltd. for certain trading services. AHL Partners LLP is also affiliated with Man Asset Management (Ireland) Limited, a firm that is registered with the Central Bank of Ireland, Man Asset Management (Cayman) Limited a manager regulated by the Cayman Islands Monetary Authority, and Man Investment Management (Shanghai) Co. Ltd registered with the Asset Management Association of China (AMAC). In addition AHL Partners LLP may utilize certain investment management, research, trading, operations and administrative services of its affiliates in providing certain services to its clients. In addition, from time to time AHL Partners LLP provides sub-advisory or other investment management services to clients of Man Solutions Limited. Man Solutions Limited is an affiliated investment adviser which provides customized portfolios to its clients across strategies managed by its affiliates, including AHL Partners LLP. AHL Partners LLP, its affiliates and its personnel serve as investment advisers and investment managers to multiple pooled investment vehicles and managed accounts. AHL Partners LLP may manage accounts on behalf of its affiliates alongside its clients. AHL Partners LLP, its affiliates and its personnel may take action or give advice with respect to certain clients and accounts that differs from the advice given to other clients and accounts. AHL Partners LLP, its affiliates and its personnel will devote as much time to the activities of each client and account as deemed necessary and appropriate and the amount of time devoted to different clients and accounts may vary. AHL Partners LLP manages each client in accordance with its respective investment objectives and guidelines.
D. Material Conflicts of Interest Relating to Other Investment Advisers
AHL Partners LLP does not recommend or select other third party investment advisers for its clients. AHL Partners LLP’s Funds may invest in other AHL Partners LLP Funds. An affiliate may from time to time seed funds to which AHL Partners LLP may provide investment management services. Potential and actual conflicts of interest may arise from the activities described herein. AHL Partners LLP has established policies and procedures to monitor and to the extent possible resolve conflicts of interest and will endeavour to resolve conflicts with respect to investment opportunities in a manner it deems appropriate and equitable to the extent possible under the prevailing facts and circumstances. AHL Partners LLP may be subject to conflicts of interest from time to time in performing its respective duties to Funds and managed accounts. Any such conflict of interest could have a material adverse effect on clients. When a conflict of interest arises AHL Partners LLP will endeavour to ensure that the conflict is resolved or managed appropriately and fairly. Furthermore, AHL Partners LLP has substantial incentives to see the assets of clients appreciate in value and merely because an actual or potential conflict of interest exists does not mean that it will be acted upon to the detriment of clients. AHL Partners LLP is permitted to manage and/or advise other managed accounts and funds, some of which may have objectives similar to those of its existing clients, including without limitation other funds or accounts in which AHL Partners LLP or its affiliates may have an interest. please register to get more info

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
A. Code of Ethics
AHL Partners LLP strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. Accordingly, AHL Partners LLP has adopted a Global Code of Ethics (the “Code”) that is supplemented by additional policies and procedures that are designed to reinforce its institutional integrity, and to set forth procedures and limitations which govern, amongst other matters, the personal securities transactions of its employees. The Code was developed to promote the highest standards of behaviour and to ensure compliance with all applicable regulations. The Code applies to all AHL Partners LLP employees. The Code contains policies and procedures that, among other things:  Require employees to observe fiduciary duties owed to clients;  Prohibit employees from taking personal advantage of opportunities belonging to clients;  Prohibit trading on the basis of material non-public information;  Require employees to comply with anti-money laundering requirements;

 Place limitations on personal trading by employees and impose pre- clearance and reporting obligations with respect to such with the exception of certain security types;  Impose limitations on the giving or receiving of gifts and entertainment;  Restrict employee outside business activities;  Require employees to disclose family members’ business activities that may present a conflict;  Require pre-clearance on political contributions; and  Prohibit disclosure by employees of confidential information of AHL Partners LLP and its clients. AHL Partners LLP’s employees are subject to the prohibition on trading on the basis of material non-public information and to the limitations and pre-clearance requirements on personal trading. Employee personal trades in securities covered by the Code are monitored by the Chief Compliance Officer or designee and governed by the procedures set forth in the Code. Employees may from time to time have proprietary investments in which clients advised or sub-advised by AHL Partners LLP also take a position, may trade and invest simultaneously with such clients, and may take investment positions that are different from or opposite to the positions taken by such clients. In general, all personal securities transactions (except for unaffiliated US open-ended mutual funds, US Treasury securities, or other permitted investments listed in the Code) are subject to pre-clearance by the Chief Compliance Officer, or designee. A copy of AHL Partners LLP’s Code is available to clients and prospective clients upon request by contacting AHLCompliance@man.com. Furthermore, AHL Partners LLP has adopted procedures to prevent and detect misuse of material non-public information. Specifically, AHL Partners LLP’s procedures prohibit any employee from trading, either personally or on behalf of others (such as client accounts advised or sub-advised by AHL Partners LLP), while in possession of material, non-public information, and prohibit employees from communicating material, non-public information to others in violation of the law. From time to time, as part of its business activities, AHL Partners LLP or its affiliates may come into possession of material non-public information concerning specific issuers. Under applicable laws and AHL Partners LLP’s procedures, this may limit AHL Partners LLP’s flexibility to buy or sell securities of such issuers. AHL Partners LLP clients are subject to Man’s Cluster Munitions and Anti-Personnel Mines Policy, which is designed to ensure compliance with The Convention on Cluster Munitions and relevant laws. This may limit AHL Partners LLP’s flexibility to buy or sell securities of issuers that, among a range of other activities, are involved in cluster munitions or anti-personnel mines or other controversial weapons for its clients.

In addition, certain AHL Partners LLP clients may be subject to the Man Responsible Investment framework which considers responsible investment criteria when making investment decisions. AHL Partners LLP and its affiliates are subject to certain position limits, including commodities. Under applicable laws and internal procedures, this may limit AHL Partners LLP’s flexibility to buy certain futures contracts or derivatives thereon. Related persons and personnel of AHL Partners LLP and its affiliates (the "Advisory Affiliates") may invest in or have a financial interest in the Funds and may not invest in all such Funds. It is expected that the size of these investments or the financial interest will change over time. Potential conflicts may arise due to the fact that the Advisory Affiliates may have investments or financial interests in some Funds but not in others or may have different levels of investments or financial interests in various Funds, and because the Funds may pay different levels of fees. In addition, certain Advisory Affiliates may from time to time make personal investments in securities or financial instruments which may be appropriate for, may be held by, or may fall within client investment guidelines. Such Advisory Affiliates may buy, sell, or hold securities or other financial instruments for their own accounts while entering into different investment decisions for one or more clients. These activities may adversely affect the prices and availability of securities or financial instruments held by or potentially considered for one or more clients. From time to time, AHL Partners LLP or the Advisory Affiliates may form and manage additional pooled investment vehicles and advise other client accounts with similar or different investment strategies as the Funds or managed accounts currently advised or sub-advised by AHL Partners LLP. It may be appropriate for more than one Fund or managed account advised by AHL Partners LLP to trade in the same securities at the same time. AHL Partners LLP has policies and procedures to manage the conflicts of interest in connection with such trades.
B. Securities that the Investment Adviser or a Related Person Has a Material
Financial Interest.
1. Cross Transactions and Principal Transactions AHL Partners LLP generally does not engage in cross trades for its U.S. clients. However, should AHL Partners LLP engage in a cross transaction on behalf of the Funds, each cross transaction will be performed in conjunction with AHL Partners LLP’s policies and procedures. To the extent that AHL Partners LLP engages in cross trades and a cross trade is considered a principal transaction covered by Section 206(3) of the Advisers Act AHL Partners LLP will comply with the requirements of Section 206(3) of the Advisers Act with respect to any U.S. client or fund, including that AHL Partners LLP will notify the applicable client (or an independent representative of the client) in writing of the transaction and obtain the client's consent (or the consent of an independent representative of the client). Section 206(3) of the Advisers Act (i) only applies with respect to principal transactions involving the purchase or sale of securities (and not, for the avoidance of doubt, commodities, currencies or many of the other financial instruments in which a Fund may trade) and (ii) does not apply to principal transactions effected between a non-US registered investment adviser such as AHL Partners LLP and a non-US client or fund. For the avoidance of doubt an inadvertently matched trade between two or more AHL Partners LLP Funds or between an AHL Partners LLP Fund(s) and one of its affiliates is not considered a Cross Transaction or Principal Transaction as defined herein. 2. Allocation of Investment Opportunities AHL Partners LLP provides discretionary advisory or sub-advisory investment advice and/or management services to multiple client accounts that may seek to invest in the same or similar investment opportunities. This may create potential conflicts particularly where there is limited availability or liquidity for certain investments. AHL Partners LLP has developed policies and procedures that provide that both investment opportunities and trades will be allocated among these client accounts in a manner that is considered to be reasonable and equitable and in a manner that is consistent with each client's investment objectives and guidelines. AHL Partners LLP utilizes proprietary computer based algorithms to determine allocations of orders and subsequent fills to its client accounts with the goal of allocating trades fairly and equitably across its managed funds. Due to various market conditions, including but not limited to price volatility, variations in liquidity, and differences in order execution, it is impossible for AHL Partners LLP to obtain identical trade execution for all of its Funds. In general, orders for any proprietary or testing accounts will be subject to the same allocation procedures as those applicable to client accounts. AHL Partners LLP may determine that an investment opportunity or particular transaction is appropriate for one or more client accounts, but not for other clients, or are appropriate for or available to certain clients but in different sizes, terms, or timing than is appropriate for others. AHL Partners LLP will make allocations for client accounts of such investments with reference to numerous factors including, without limitation, AHL Partners LLP’s perception of the appropriate risks and rewards for each client account, investment objectives and guidelines of each client account, leverage of each client account, the liquidity of the account at the time of the investment and on a going-forward basis, risk parameters for each client account, regulatory restrictions affecting the client, and such other factors as are relevant in the judgment of AHL Partners LLP. Although allocating orders among client accounts may create potential conflicts of interest because of the interests of AHL Partners LLP or its employees or because AHL Partners LLP may receive greater fees or compensation from one client account over another, AHL Partners LLP will not make allocation decisions based on such interests or greater fees or compensation. Allocation among accounts in any particular circumstance may be more or less advantageous to any one account. In addition, transactions in investments by multiple client accounts may have the effect of diluting or otherwise impairing the values, prices or investment strategies of an individual client, particularly, but not limited to, in small capitalization, or less liquid strategies. Therefore, the amount, timing, structuring, or terms of an investment by some clients may differ from, and performance may be lower than, investments and performance of other clients. AHL Partners LLP, its affiliates, their principals and their employees may trade securities and commodity interests for their own accounts. Such proprietary and employee trading may be in competition with a Fund and may be conducted at brokerage commission rates substantially lower than rates charged a Fund. Investors in a Fund will not be permitted to inspect the proprietary and employee trading records of AHL Partners LLP, its affiliates, their principals or their employees. 1. Valuation The Funds have established valuation policies and procedures that seek to establish a consistent framework and methodology for the determination, validation, approval, regular monitoring and review of pricing all positions of each Fund. The Fund’s directors have appointed an Independent Pricing Committee (the “IPC”) to undertake certain services concerning the valuation policies and procedures relating to each Fund. The IPC is an independent body set up to: (1) establish a pricing matrix (a table which lays out a pricing source for certain assets and liabilities) which the directors will decide whether to adopt for the Fund and if so will thereafter be used by the administrator to calculate the value of the assets and liabilities held by the Fund; and (2) establish the prices of any positions held in the Fund that do not have an independently ascertainable value as per the pricing matrix. In addition, the IPC provides general governance and oversight of the valuation process.
C. Investing in Securities that the Investment Adviser or a Related Person
Recommends to Clients
The Code places restrictions on personal trades by employees, including that they disclose their personal securities holdings and transactions to AHL Partners LLP on a periodic basis, and requires that employees pre-clear certain types of personal securities transactions. Generally, and subject to certain exceptions, AHL Partners LLP’s employees may not engage in personal securities trading without pre-clearance. Accordingly, under certain circumstances, AHL Partners LLP, its affiliates and its employees may invest on behalf of themselves in securities and other instruments that would be appropriate for, held by, or may fall within the investment guidelines of clients. AHL Partners LLP, its affiliates and its employees may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for clients. These activities may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more clients. Potential conflicts also may arise due to the fact that AHL Partners LLP and its personnel may have investments in some Funds but not in others or may have different levels of investments in the various Funds. AHL Partners LLP has established policies and procedures to monitor and resolve conflicts with respect to investment opportunities in a manner it deems fair and equitable, including the restrictions placed on personal trading in the Code of Ethics, as described above, and regular monitoring of employee transactions and trading patterns for actual or perceived conflicts of interest, including those conflicts that may arise as a result of personal trades in the same or similar securities made at or about the same time as client trades.
D. Conflicts of Interest Created by Order Aggregation and Contemporaneous
Trading
AHL Partners LLP manages investments on behalf of a number of client accounts. Certain client accounts have investment strategies that are similar to or, in part, overlap and may, therefore, participate in one or more orders with each other. It is the policy of AHL Partners LLP to allocate trades among all clients fairly, to the extent practical and in accordance with each client's applicable investment strategies, over a period of time. AHL Partners LLP may aggregate orders with similar orders that are generated on or around the same time for other client accounts if, in their reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to the participating client accounts. When there is trading on behalf of one client managed Fund on or around the same time as trading on behalf of another client managed Fund such trades may be made at slightly different prices. AHL Partners LLP employs a two-part allocation algorithm which (i) determines the percentage of each aggregated order will be allocated to each participating client managed Fund at the time of order creation (“Pre-Allocation Percentage”) and (ii) handles fill allocation in accordance with the Pre-Allocation Percentage. The allocation algorithm is subject to change over time. AHL Partners LLP will have no obligation to purchase or sell a financial instrument for, enter into a transaction on behalf of, or provide an investment opportunity to any client managed Fund solely because AHL Partners LLP purchases or sells the same instrument for, enters into a transaction on behalf of, or provides an opportunity to any client managed Fund if, in its reasonable opinion, such financial instrument, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client managed Fund. Further, there can be no assurance that on a trade-by-trade or overall basis that any particular client managed Fund will not be treated more or less favourably than another client managed Fund. AHL Partners LLP or its affiliates may take inconsistent positions in the same security or trade in opposite directions as a result of rebalancing or different investment strategies. This will result in potential conflicts of interest. AHL Partners LLP strives to ensure that all clients are treated fairly and equitably.

From time to time, AHL Partners LLP may maintain one or more test trading accounts which may be willing to accept more risk than it believes is acceptable for the Funds and positions in the test trading accounts may be inconsistent or opposite to those of the Funds. In general, the test trading accounts are used to test new trading methodologies, Models, strategies, technology and markets and seek to identify any (i) divergence in expectation of implementation when operating in production, (ii) cost or (iii) illiquidity issues prior to considering the implementation of such strategy or processes to the Funds. In certain regions and jurisdictions AHL Partners LLP may choose to leverage certain trading modalities and/or trading desk expertise of one or more of its affiliates and, by doing so, direct certain of its client orders to an affiliates trading desk for order handling and execution. In such circumstances the client orders of AHL Partners LLP will be subject to the same order aggregation and trade allocation processes as described herein but AHL Partners LLP client orders may not be aggregated in the same manner with client orders of the respective affiliate. please register to get more info

BROKERAGE PRACTICES
A. Factors Considered in Selecting or Recommending Broker-Dealers for Client
Transactions
The Investment Manager will place client orders for the execution of transactions via a centralized trading desk with various brokers, dealers and/or trading venues (as defined by the Markets Financial Instruments Directive) on the basis of best execution (in accordance with the rules of the FCA, SEC and MiFID II) in accordance with its Best Execution Policy based on a number of factors, including, among other things, execution costs inclusive of commission rates, speed and likelihood of execution, impact on market price, availability of price improvement, liquidity of the instrument, the broker's financial strength, ability to commit capital, stability and responsibility, reputation, reliability, overall past performance of services, responsiveness to the Investment Manager as well as means of communication, ability to execute trades based on the characteristics of a particular trade, technology and trading systems, trading activity in a particular security, block trading and block positioning capabilities, net price, depth of available services, bond capability and options operations, the availability of stocks to borrow for short trades, willingness to execute related or unrelated difficult transactions, back office, settlement processing and special execution capabilities and error resolution. The centralized trading desk will take all sufficient steps to execute orders in a manner designed to obtain the best possible results on a consistent basis. However Investment Manager does not need to, nor will it, seek the best result on each and every client order but rather ensures that methodologies employed achieve overall best execution on behalf its Clients. The Investment Manager has established a best execution committee to review execution performance and other execution related decisions taken by Investment Manager on behalf of its Clients. The Investment Manager does not adhere to any rigid formulas in selecting brokers, but weighs a combination of the factors, some of which are referenced above. There is, however, no direct correlation between these factors and the allocations of brokerage for client accounts advised or sub-advised by the Investment Manager. Because of the range of factors considered by the Investment Manager, it is possible that the Investment Manager’s clients may pay brokerage commissions in excess of that which another broker might have charged for effecting the same transaction. The Investment Manager will make a good faith determination that the amount of commission is reasonable in relation to the value of the products and services received, the broker's execution ability, and other factors. The Investment Manager has delegated certain of its order handling and execution responsibilities to an affiliate. In doing so the Investment Manager believes that such delegation is consistent with its obligations and will review execution quality received by the respective affiliate as part of its overall execution measurements to confirm such engagement continues to meet the Investment Manager’s obligations. 1. Research and Other Soft Dollar Benefits The Markets in Financial Instruments Directive II (“MiFID II”), which went into effect on January 3rd, 2018, requires Investment Managers authorized and regulated by FCA to separate execution commission from any investment research payments. In light of these regulatory changes the Investment Manager has ceased using and/or accruing soft dollars in its provision of investment management services on behalf of the Funds. Effective as of January 3rd, 2018 the Investment Manager pays for all investment research as defined by MiFID II and the safe harbour of Section 28(e) on behalf of the Funds. 2. Brokerage for Client Referrals The Investment Manager does not consider introduction and marketing assistance with respect to investors in the Funds in selecting or recommending broker-dealers for the Funds. However, the Investment Manager or its affiliates may be invited to capital introduction events as a result of the relationship the Investment Manager and its affiliates have with certain broker dealers. 3. Directed Brokerage AHL Partners LLP does not generally allow for directed brokerage arrangements. In addition, the Investment Manager does not typically recommend brokers to be used by client accounts. If the Investment Manager does deem it appropriate to make such a recommendation, Investment Manager will generally take into account the factors and considerations discussed above.
B. Trade Error Policy
In the event that AHL Partners LLP experiences a trade error with respect to order handling and execution on behalf of clients, a formalized process is in place for the resolution of such trade errors. The Investment Manager will correct such trade error in accordance with its policies and procedures. If the Investment Manager, in its sole discretion determines that a client should be reimbursed as a result of a trade error caused by the Investment Manager interest will generally not be paid on such losses.
C. System Event Policy
The systematic approach to the development and deployment of investment strategies utilised by the Investment Manager harnesses complex econometric and statistical theories, research and modelling which may result in a “System Event” (e.g., errors or omissions regarding trading systems, coding/programing/modelling, etc.). The Investment Manager, to the extent feasible and reasonable, will correct a System Event in accordance with its policies and procedures. The Fund will benefit from any gains and bear any losses unless it otherwise determined by the Investment Manager. please register to get more info

REVIEW OF ACCOUNTS
A. Frequency and Nature of Review of Client Accounts or Financial Plans
The Investment Manager’s portfolio managers are primarily responsible for reviewing accounts of the clients and do so individually or in a group, depending upon account needs and market conditions. The portfolio managers, individually or in a group, perform daily, weekly, or monthly reviews of all accounts as they deem appropriate or as otherwise required. Reviews may be undertaken because of changes in market conditions; change of security positions; changes in investment objectives or policies; capital inflows/outflows; and other reasons. Various matters may be discussed during such reviews, (e.g., performance of accounts in connection with investment objectives, portfolio construction, risk/reward, security positions, and investment opportunities).
B. Factors Prompting Review of Client Accounts Other than a Periodic Review
A review of a client account may be triggered by changes in market conditions; change of security positions; changes in investment objectives or policies; capital inflows/outflows; and other reasons.
C. Content and Frequency of Account Reports to Clients
The requirements for frequency and content of reports will be set forth in the documents for each client account. Investors in the Funds generally receive estimated and final monthly statements, as applicable, generally showing account values, changes in account values, account activity, asset allocation, currency exposure and performance. Depending on specific requirements, investors in private funds also generally receive audited financial statements prepared within either 90 or 120 days of the applicable fund's fiscal year end. While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received) which is in addition to information provided in a Fund’s regular reports to investors, such information may provide such investor with greater insight into the Fund’s activities. This may enhance such investor's ability to make investment decisions with respect to a Fund and possibly affect such investor’s decision to request a redemption from such Fund. Affiliated investment advisers that invest in AHL Partners LLP Funds will receive information with greater transparency on such Fund that may not otherwise be made available to other investors. please register to get more info

CLIENT REFERRALS AND OTHER COMPENSATION
A. Economic Benefits for Providing Services to Clients
AHL Partners LLP does not receive economic benefits from non-clients for providing investment advice and other advisory services.
B. Compensation to Non-Supervised Persons for Client Referrals
From time to time, AHL Partners LLP and/or its affiliates may from time to time utilize third party placement agents or solicitors that receive compensation, which may be borne either by AHL Partners LLP or its affiliates or by the investor or client, for referring the client to AHL Partners LLP or investors to the Funds. Compensation may be in the form of a percentage of management fees or performance fees, a flat fee or as otherwise agreed. AHL Partners LLP or its affiliates may benefit from the arrangements where clients are referred directly to it and/or investors are referred directly to a Fund, since the management fees are generally based upon a percentage of such client's assets under management. Thus the more assets the Investment Manager or its affiliates has under management, the higher the management fee income. If applicable, any such arrangement with a third-party solicitor will comply with Rule 206(4)-3 under the Advisers Act. MII, a US based affiliate of the Investment Manager, acts as the selling agent and/or investor servicing agent for certain Funds in the US. AHL Partners LLP may pay a portion of its fees to MII for its services. MII may also receive compensation directly from a Fund. In addition, MII has entered into agreements with other broker-dealers and certain financial advisers to solicit interests in Funds and/or to provide ongoing investor services and account maintenance services to investors. Each such broker-dealer and financial adviser generally receives compensation based on the aggregate value of outstanding interests held by investors that receive services from such persons, fixed amounts or other agreed upon compensation. Such compensation generally will be paid by MII from the fees that it receives from a Fund or the Investment Manager. In addition, AHL Partners LLP has entered into a distribution agreement with MIAG and certain other affiliated entities. These affiliated entities act as solicitors for managed accounts and the selling agent and/or investor servicing agent for certain Funds outside of the U.S. please register to get more info

CUSTODY
With regards to its US clients and private funds, the Investment Manager is subject to Rule 206(4)-2 under the Advisers Act (the "Custody Rule"). In accordance with the Custody Rule each Fund complies with the provisions of the "Pooled Vehicle Annual Audit Exception" and is subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and distributes its audited financial statements to all investors within 120 days of the end of its fiscal year. With respect to certain managed accounts and, as agreed, AHL Partners LLP may directly debit fees from such clients’ accounts and may be deemed to have custody as a result of such authority. In these cases in order to comply with the Custody Rule, managed accounts will receive statements directly from the managed account’s qualified custodian(s) (as defined in the Custody Rule) on at least a quarterly basis. please register to get more info

INVESTMENT DISCRETION
In general, AHL Partners LLP provides discretionary advisory, sub-advisory investment advice and/or management services to its clients. As such, AHL Partners LLP has discretion regarding all investment decisions and is authorized to determine and direct execution of transactions within each client's specified investment objectives, restrictions and policies. However, AHL Partners LLP’s discretion is subject to limits imposed on the investment manager as described in the applicable offering document in the case of the Funds, as applicable, and investment management agreements or other relevant documents with each client advised or sub-advised by AHL Partners LLP. AHL Partners LLP may utilize certain trading capabilities of its affiliates in providing services to certain of its clients. please register to get more info

VOTING CLIENT SECURITIES
A. Proxy Voting
AHL Partners LLP has adopted policies and procedures to ensure that any proxy voted on behalf of its clients is voted in a manner which is in the best interests of such clients. Proxies may be voted for clients at AHL Partners LLP’s or the Portfolio Manager’s discretion, where AHL Partners LLP has been specifically instructed by a client to vote proxies or where AHL Partners LLP is required to vote a proxy for a client (each a “Proxy Client”). In such cases, proxies will be evaluated and voted in the best interest of the relevant Proxy Client(s) with the goal of increasing the overall economic value of the investment. It should be noted that there may be times whereby Portfolio Managers invest in the same securities/assets while managing different investment strategies and/or client accounts; accordingly, it may be appropriate in certain cases that such securities/assets are voted differently across different investment strategies and/or client accounts, based on their respective investment thesis and other portfolio considerations. AHL Partners LLP will only vote proxies on securities currently held by clients. Proxies received for securities that are loaned will generally not be voted. AHL Partners LLP will endeavour to identify material conflicts of interest, if any, which may arise between AHL Partners LLP and one or more issuers of clients’ portfolio securities, with respect to votes proposed by and/or affecting such issuer(s), in order to ensure that all votes are voted in the overall best interest of clients. AHL Partners LLP will appoint one or more proxy voting service companies, to provide it with proxy voting services for certain Proxy Clients. Where applicable, AHL Partners LLP will generally vote proxies for the relevant Proxy Clients in accordance with the relevant proxy voting service company’s proxy voting guidelines, unless otherwise specifically instructed to vote otherwise by the Portfolio Manager or such Proxy Client. A Stewardship and Active Ownership Committee has been established to be responsible for resolving proxy voting issues when deemed necessary; making proxy voting decisions where a material conflict of interest may exist; monitoring compliance with the Global Proxy Voting Policy; and setting new and/or modifying existing policy, among other functions. The proxy voting service company’s guidelines generally provide that (i) when the view of the company’s management is favourable, AHL Partners LLP will generally support current management initiatives with exceptions as noted below and (ii) when the view is that changes to the management structure would probably increase shareholder value, AHL Partners LLP will not necessarily support current management initiatives. Exceptions in supporting current management initiatives may include: - Where there is a clear conflict between management and shareholder interests, the Proxy Voting Guidelines may call to elect to vote against management. - In general, the Proxy Voting Guidelines will call to oppose proposals that act to entrench management. - In some instances, even though AHL Partners LLP may support management, there may be corporate governance issues that, in spite of management objections, AHL Partners LLP believes should be subject to shareholder approval. Furthermore, with respect to certain proxy issues including, but not limited to, option re-pricing and the terms and conditions of members of the Board of Directors and/or Managing Members, AHL Partners LLP may choose to vote on a case-by-case basis, which may be different from the recommendations set forth in relevant proxy voting guidelines. Nevertheless, in voting proxies, AHL Partners LLP will take into account what is the overall best economic interest of its Proxy Clients. AHL Partners LLP will maintain documentation memorializing the decision to vote a proxy in a manner different from what is stated in the relevant proxy voting guidelines. AHL Partners LLP may abstain from voting a proxy when it is determined that the cost of voting the proxy exceeds the expected benefit to the client. Documentation will be maintained of all proxies that are not voted for Proxy Clients and the reasons therefor where AHL Partners LLP has been instructed by the Proxy Client to vote. Upon request, clients may receive a copy of the Global Proxy Voting Policy and/or information regarding the manner in which securities held in their account were voted by contacting AHL Partners LLP at ++ 44 20 7144 1000.
B. Class Actions
AHL Partners LLP will generally participate in class actions on behalf of the Funds. Unless specifically stated in the client’s investment management agreement, AHL Partners LLP will not participate in class actions on behalf of managed accounts. AHL Partners LLP utilizes the services of a third party class actions service provider to file claims and participate in class action settlements. Only current Fund investors will receive any proceeds received from class action recoveries. Investors that have fully redeemed will not receive any class action proceeds. AHL Partners LLP may from time to time receive notification of and/or determine to engage or participate in litigation regarding investments held in Accounts. It is AHL Partners LLP’s policy to review each lawsuit and to participate in those lawsuits where AHL Partners LLP has made the determination that the potential benefit to its client(s) outweighs the costs of participation in the litigation. Any monies recovered as a result of any such litigation will be allocated on a pro rata or other appropriate basis to the Account(s) which hold/held the investment at issue. AHL Partners LLP will not be responsible for reimbursing any client(s) or investor(s) who may have been invested during the period that is the subject of any litigation but had redeemed or withdrawn such investment prior to such a recovery. AHL Partners LLP may consider a de minimis amount with regards to distributing any proceeds received. please register to get more info

FINANCIAL INFORMATION
AHL Partners LLP is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy petition at any time during the past ten years. please register to get more info