Glacier Peak Capital Management LLC

Fees and Compensation
We generally receive compensation from our clients based on a percentage of net assets under
management and/or on the performance achieved for the account of each of our clients. Details
concerning such terms are set forth in each of our clients’ investment advisory agreement.

Our management fee is generally 2% per annum of the net asset value of the client’s account.
Management fees are generally charged quarterly in arrears and invoiced directly to the client.
Investment advisory services begin with the effective date of the Investment Advisory Agreement
(“Agreement”), which is the date the client signs the Agreement. For that calendar quarter, fees will
be adjusted pro rata based upon the number of calendar days in the calendar quarter that the
Agreement was effective.

The performance fee ranges up to 25% annually and is generally based on the new appreciation in
the net assets of the client’s account during the period. New appreciation is defined to mean (a) the
net gain or loss realized from closed trades during the period, plus (b) the net change in open trade
equity during the period, less (c) all other expenses directly related to the Account paid or due at the
end of the period, if any. If the sum of (a) and (b) less (c), results in a net loss at the end of the period,
such loss is carried forward and offset against gains in subsequent periods. Until the Account
achieves new appreciation over and above any accumulated losses carried forward, no incentive fee
is due. If funds are withdrawn/added from/to the Account, losses carried forward will be
reduced/increased in the same proportion as such withdrawals/additions bear to the equity of the
Account. Incentive fees already received by the Glacier Peak shall not be rebated by virtue of
subsequent losses.

In addition to management and performance fees clients may be subject to costs and expenses
directly related to portfolio investments or prospective investments, including brokerage
commissions, clearing and settlement charges, custody fees, interest on debit balances or
borrowings. Please see the section entitled “Brokerage Practices” for more information regarding
our brokerage practices.

Performance Based Fees and Side-by-Side Management
We have entered into performance-based fee arrangements with clients. The performance-based fee
arrangement may create an incentive for us to recommend investments which may be riskier or more
speculative than those which would be recommended under a different fee arrangement.

The terms of the performance-based fees may differ among the separately managed accounts we
manage. This may result in a conflict of interest if we allocate investment opportunities among these
clients because we will have an incentive to favor clients that pay us higher performance- based fees
and allocations. To avoid such a conflict of interest, we will allocate opportunities among such
clients, based on their individual risk tolerances and objectives which do not take into account the
performance-based fees and allocations to which such clients are subject.

Types of Clients
Glacier Peak primarily provides portfolio management services directly to institutional investors
through separately managed accounts. Our minimum account size is generally 3,000,000.00, but this
amount is negotiable.

Methods of Analysis, Investment Strategies and Risk of Loss
We use a t-bill/short coupon arbitrage strategy which deals in high quality investment grade
securities, predominantly U.S. Treasury securities and short end futures and options. We capitalize
on arbitrage between t-bills/short coupons and t-bill/short coupon financing occurring due to (i)
increased financing needs of the U.S. Treasury; and (ii) swings in the short-term Treasury financing
needs and other cyclical market factors.

Our investment objective is to pursue a market neutral strategy focused on the short maturity
spectrum of the U.S. Treasury yield curve. We identify market opportunities by seeking technical
fluctuations in the U.S. Treasury bill/short coupon market and purchase t-bills/short coupons at
higher yield than financing cost to maturity. Specifically, we purchase 3 month – 1 year U.S.
Treasury bills and/or 1 year – 3 year short U.S. Treasury short coupons and hedge with U.S. Treasury
financing (repo), SOFR futures, federal funds futures, Eurodollar futures/options and/or GCF repo
futures. Entry point of trade is when t-bill/short coupon yields are attractive, in our opinion, on a
relative basis compared to the financing cost. We unwind the trade as t-bills/short coupons become
expensive, in our opinion, to treasury financing. We incorporate the use of high leverage to enhance
returns.

All investing involves a risk of loss that clients should be prepared to bear. We cannot give any
guarantee that we will achieve our investment objectives or that clients will receive a return on their
investment. The description contained below is a brief overview of different material risks related
to our investment strategy:

Dependence on key personnel – Our investment activities depend upon the experience and
expertise of our Portfolio Managers. The loss of the service of our Portfolio Managers could have a
material adverse effect on our operations.

Use of leverage increases the risk of loss and increases costs. As stated above, we incorporate the
use of high leverage to enhance returns, including the use of borrowed funds and investments in
certain types of options. Leverage strategies increase the risk of loss. When we purchase securities
with borrowed funds, net assets will tend to increase or decrease at a greater rate than if borrowed
funds are not used. The interest costs associated with such borrowing will reduce profits. If the
interest expense on borrowings were to exceed the return on the investments made with borrowed
funds, the use of leverage would result in a lower rate of return than if leverage was not used.

Securities lending entails unique risks. Brokers, dealers and other financial institutions needing to
borrow securities to complete certain transactions may borrow securities from a client’s portfolio as
determined by us. We agree to lend securities from client portfolios as a means of earning additional
income for clients. The portfolio will be entitled to payments in the form of interest, dividends or
other distributions payable on the loaned securities, which affords the portfolio an opportunity to
earn interest on the amount of the loan and current income on the loaned securities themselves.
However, we will not vote proxies on securities that are loaned. In addition, the portfolio might
experience a loss if any institution that the portfolio has loaned securities to breaches its agreement
with the portfolio. If the borrower becomes insolvent or bankrupt, the portfolio could experience
delays and costs in recovering the loaned securities. To the extent that, in the meantime, the value
of the loaned securities declines, the portfolio could experience further losses.

Interest Rate Changes. Debt securities have varying levels of sensitivity to changes in interest
rates. In general, the price of a debt security can fall when interest rates rise and can rise when
interest rates fall. Short-term and long-term interest rates do not necessarily move in the same
amount or the same direction. Short-term securities tend to react to changes in short-term interest
rates, and long-term securities tend to react to changes in long-term interest rates.

Options. The purchase or sale of an option involves the payment or receipt of a premium payment
by the investor and the corresponding right or obligation, as the case may be, to either purchase or
sell the underlying security or other instrument for a specific price at a certain time or during a
certain period. Purchasing options involves the risk that the underlying instrument does not change
price in the manner expected, so that the option expires worthless and the investor loses its premium.
Selling options, on the other hand, involves potentially greater risk because the investor is exposed
to the extent of the actual price movement in the underlying security in excess of the premium
payment received.

Futures. Futures markets are highly volatile. When we engage in transactions in futures contracts
and options on futures contracts, the profitability of such transactions will depend to some degree
on our ability to analyze correctly the futures markets, which are influenced by, among other things,
changing supply and demand relationships, governmental policies, commercial and trade programs,
world political and economic events and changes in interest rates.

Default by the U.S. Treasury. We use a T-bill/short coupon arbitrage strategy which deals in high
quality investment grade securities, predominantly U.S. Treasury securities and short end

futures and options. If the U.S. Treasury should default, we may be unable to recover all or even a
portion of the assets maintained by client accounts.