Voloridge Investment Management LLC

5, “Fees & Compensation.”

The management fees and incentive allocations incurred by Investors in the Funds differ by Fund. This
creates a con�lict of interest in allocating investments that are anticipated to earn higher returns to those
funds which charge higher management fees and incentive allocations.

Additionally, the possibility for the Firm or its af�iliates to receive performance-based compensation
creates a potential con�lict of interest in that it may create an incentive to make investments that are riskier
or more speculative than would be the case in the absence of such a performance-based fee. However, this
incentive may be tempered by the fact that losses will reduce the Fund’s performance and thus the fees
earned. Investors are provided with clear disclosure as to how performance-based compensation is
charged with respect to a particular Fund and the risks associated with such performance-based
compensation prior to making an investment.

The Firm recognizes that it is a �iduciary and, as such, must act in the best interests of its clients. Further,
the Firm recognizes that it must treat all clients fairly and must refrain from favoring one client’s interests
over another’s. VIM has adopted policies and procedures designed to address con�licts of interest,
including procedures regarding the allocation and aggregation of investment opportunities among the
Funds and a Code of Ethics (the “Code”), which includes a standard of business conduct and establishes
policies and procedures with regard to personal securities transactions of VIM’s personnel.

            PART 2A OF FORM ADV                                                       Page 6 of 13

DISCLOSURE BROCHURE

ITEM 7: TYPES OF CLIENTS

The Firm’s only clients are the Funds. The Firm will determine if a prospective Investor �its the criteria to
invest in our Funds, and, if an af�irmative determination is made, a private placement memorandum
(“PPM”) will be provided to the prospective Investor. The Firm reserves the right to be selective on who
can invest in our Funds based on criteria including Investor suitability, Investor time horizon, prospective
capital an Investor may commit, and the relationship of the Investor to the Firm. Additionally, minimum
initial capital contributions apply as outlined in the PPM for the respective Fund.

An Investor may invest in any of the domestic private funds if it is (i) an “accredited investor” as de�ined in
Rule 501(a) of Regulation D under the U.S. Securities Act of 1933 and (ii) a “quali�ied purchaser” as de�ined
in Section 2(a)(51) of the Investment Company Act and the regulations promulgated thereunder. In
addition to being an accredited investor and a quali�ied purchaser, an Investor must be a non-US or a US
tax-exempt Investor to purchase shares in any of the foreign private funds.