Activant Capital Group LLC

Item 5, Fees and Compensation. Performance-Based Compensation creates an incentive for
Activant to make more speculative or riskier investments than would otherwise be made, or make
decisions regarding the timing and manner of realization of investments differently than if such
compensation were not received. Activant is permitted, in its sole discretion, to waive or reduce
the performance-based compensation for certain Limited Partners. In addition, the terms of the
Performance-Based Compensation among Clients vary, which creates an incentive to favor Clients
that pay higher Performance-Based Compensation when allocating or evaluating investment
opportunities.

The payment by Clients of Performance-Based Compensation also creates an incentive for
Activant to disproportionately allocate time, services or functions to these Clients, or to allocate
investment opportunities to such Clients. Finally, Activant’s management fee compensation at
times is based in part on unrealized gains and losses, so Activant could have an incentive to inflate
the value of Client assets through fair valuation determinations.

Despite the presence of these conflicts of interest, we seek to act fairly when we allocate
investment opportunities and value Client assets. We have also adopted written policies and
procedures that are designed to ensure fair allocations and valuations over time. Current and
prospective Clients and Fund Investors are invited to discuss our allocation and valuation policies
and procedures with us. Additional conflicts with respect to Performance-Based Compensation
and side-by-side management are discussed throughout this brochure and the Governing
Documents.

Additional information about the Performance-Based Compensation, side-by-side management
and associated risks and conflicts of interest, can be found in greater detail below in Item 8,
Methods of Analysis, Investment Strategies and Risk of Loss and in Item 11, Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading, under the heading
“Certain Conflicts of Interest and Other Considerations.”

Item 7: Types of Clients
Activant provides investment advisory services to the Private Funds and Special Purpose Entities.
Details concerning applicable investor suitability criteria are set forth in the respective Governing
Documents and subscription materials. There is generally no minimum commitment for a Fund
Investor, however, Activant is permitted to establish minimum investments in the future, though
Activant will maintain discretion to accept less than any minimum investment threshold
established and can increase or decrease such thresholds from time to time. Each Fund Investor is
required to meet certain suitability qualifications, such as being an “accredited investor” within
the meaning set forth in Rule 501(a) of Regulation D under the Securities Act of 1933, as amended
(the “Securities Act”), and with limited exceptions a “qualified purchaser” or “knowledgeable
employee” as defined in the Investment Company Act of 1940, as amended (the “Investment
Company Act”). This brochure is not an offer to invest in our Private Funds or in any private fund
Activant establishes in the future. Any offer to invest in our Private Funds or in any private fund
we establish in the future will only be made through the provision of such entity’s confidential

Form ADV Part 2A Firm Brochure | Activant Capital Group LLC

offering documents. Our Private Funds are not, and it is not anticipated that any private fund
established in the future will be, registered under the Securities Act or the Investment Company
Act.