12th Street Asset Management LLC

Item 5)

12th Street invests partnership assets pursuant to the similar strategies that it employs when it invests
separate account assets. Potential conflicts of interest can arise when the partnership buys, sells, or
holds positions in securities which 12th Street also buys, sells, or holds for other advisory clients. These
potential conflicts include, among other things, treating the partnership more favorably than other
clients in connection with the allocation of limited investment opportunities or the allocation of
aggregated trade orders. To avoid or mitigate any potential conflicts of interest, 12 th Street has adopted
written policies that impose internal controls over trade management and the fair aggregation and
allocation of trades. For information about these policies and procedures, see the section entitled

Item 7: Types of Clients

12th Street provides portfolio management services to high-net-worth individuals, pooled investments
vehicles or investment companies, pensions, other investment advisory companies and institutional
clients. 12th Street also participates in arrangements where it provides a model portfolio to clients. In
some cases, the firm maintains discretion over the investments in those accounts. When the firm acts as
a sub-advisor or model provider to an overlay manager, it does not have discretion. See Item 4 for
further discussion on Model Portfolios.

There is a stated minimum account size of $1,000,000 for limited partnerships and for separate
accounts. However, 12th Street has discretion to manage accounts below our stated minimum sizes.
Minimum account sizes for sub-advised, model portfolio accounts, “wrap” fee programs and dual
contract agreements are negotiated separately.

When 12th Street participates as an advisor in a Wrap Fee Program, on a platform, or provides a model,
the program sponsor or advisor may determine the minimum account size. Wrap Fee Programs and
Model Portfolios typically have lower minimums than the minimums 12th Street requires of investors in
LPs or separate accounts.

Form ADV Part 2A                                                                                      Page 7