Barnegat Fund Management Inc

Item 5 – Fees and Compensation

The specific manner in which fees are charged by Barnegat is established in the Funds’
written Investment Management Agreement entered into with Barnegat. Barnegat bills its
fees to BIL on a quarterly basis. BIL is billed in arrears each calendar quarter. Management
and performance-based fees shall be prorated for each capital contribution and withdrawal
made during the applicable calendar quarter. Investments in BIL Class B shares initiated or
terminated during a calendar quarter will be charged a prorated fee. Upon termination of
any investment in BIL Class B shares, any earned, unpaid fees will be due and payable. The
Funds have the right to terminate the Investment Management Agreement without penalty
upon prior written notice of at least twelve months. Investors in BIL Class B shares should
refer to BIL’s Fund Documents for detailed termination provisions.

Barnegat’s fees are not negotiable.

Barnegat’s fees are exclusive of brokerage commissions, transaction fees and other related
costs and expenses which shall be incurred by the Funds. The Funds may incur certain
charges imposed by custodians, brokers, third party service providers and other third
parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. Such charges, fees and commissions are
exclusive of and in addition to Barnegat’s fees, and Barnegat shall not receive any portion
of these commissions, fees and costs.

                              Barnegat Fund Management, Inc.
                                Form ADV Part 2A Brochure
                                 Dated February 18, 2026

Item 12 further describes the factors that Barnegat considers in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions).

The fee schedule applicable as of this Brochure is as follows:

Client Assets                                     Annual Fee (%) for all assets
Management fee on all assets of BIL               1.0% of the net asset value of BIL, calculated
                                                  monthly in arrears and payable quarterly in
                                                  arrears
Performance-based fee on all assets of BIL        15% of total profits of BIL in excess of net
                                                  losses that have been carried forward from
                                                  prior quarters, calculated and payable
                                                  quarterly in arrears by reference to the
                                                  applicable quarterly valuation date

The employees of Barnegat are permitted to invest in a separate series of the Class B shares
(hereinafter “the Employee Series Shares”), which shares shall not be subject to
management fees or performance-based fees but shall be subject to all other fees and
expenses of the Company and will be subject to all other rights and terms as other Class B
shares. The Employee Series Shares shall have a Net Asset Value per Share that is
calculated separately and that shall be distinct from the Net Asset Value per Share of the
other Class B shares.

Item 7 – Types of Clients

Barnegat is an investment adviser to the Funds, which are private placement vehicles. In
the future, Barnegat may provide advisory services to other various private placement
investment vehicles.