PRIVACY NOTICE

Effective Date: January 2023

Last Updated: September 2023

Introduction

This notice (this “Privacy Notice”) is provided by the Shenkman Group of Companies, and their affiliates (collectively the “Shenkman Group”), as well as mutual funds, private funds (single investor or commingled), Collateralized Loan Obligations (“CLOs”), and UCITS funds managed by the Shenkman Group (each, a “Sponsored Fund” and, collectively “Sponsored Funds”). This Privacy Notice sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former clients and investors in Sponsored Funds, as applicable.

References to “you,” “your,” “investor,” or “client” in this Privacy Notice mean any investor in a Sponsored Fund or any client of the Shenkman Group, as applicable. References to, “we,” “us,” or “our” in this Privacy Notice mean a Sponsored Fund or the Shenkman Group, as applicable

The Shenkman Group includes Shenkman Capital Management, Inc., Shenkman Capital Management Ltd, Romark Credit Advisors LP, Romark CLO Advisors LLC, and their affiliates. Capitalized terms used but not defined herein have the meanings assigned to them in the Form ADV Part 2A of Shenkman Capital Management, Inc., or of Romark Credit Advisors LP, as applicable, each of which may be supplemented, updated or modified from time-to-time.

Certain Shenkman Group entities and Sponsored Funds are considered to be data controllers in respect of any personal data we hold about you for the purposes of certain privacy and data protection laws that apply in jurisdictions where we operate (collectively, the “Data Protection Laws”), please visit https://www.shenkmancapital.com/datacontrollers for a comprehensive list. This means that each of the Sponsored Funds and the Shenkman Group (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal data.

Please note that certain service providers (collectively, the “Service Providers”) of the Shenkman Group and/or Sponsored Fund including, without limitation, administrators, transfer agents, legal advisers, depositaries, distributors, prime brokers, and custodians work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, such Service Providers, from time-to-time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and, therefore, would be acting as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by such service providers, you may also contact the relevant Service Provider directly, and we can provide relevant contact information upon request. With respect to Sponsored Funds, Service Provider contact information may be found in the prospectus or confidential private placement memorandum of the applicable Sponsored Fund.

The Types of Personal Data We May Hold

The categories of personal data we may collect include, but are not limited to: names; residential or business addresses, or other contact details; signature; nationality; tax identification, passport, or social security number or similar identification number; date of birth; place of birth; country of incorporation or domicile; jurisdiction of tax residence(s) photographs; copies of identification documents; bank account details; information about assets or net worth; credit history; information on investment activities; financial information, for example, interest, dividends, income from certain insurance contracts or products and other income generated with respect to assets held in the account or payments made with respect to the account; account balances; proceeds from the sale or redemption of property paid or credited to the account; or other personal data, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches, together with any other information required by applicable law or regulation.

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and monitoring of telephone conversations with you, to the extent relevant or permissible under applicable law.

We also may receive your personal data from third parties or other sources, such as, but not limited to, our affiliates, the Service Providers, publicly accessible databases or registers, tax authorities, governmental and non-governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the internet.

How We May Use Personal Data

We may process your personal data in the course of our business tasks, including, without limitation, in connection with:

1. entering into an advisory agreement or accepting subscription documentation;
2. administering the relationship between you and us;
3. processing subscriptions and redemptions;
4. executing discretionary transactions;
5. providing communications and reporting;
6. maintaining the registers of investors of Sponsored Funds;
7. marketing of our products and services;
8. monitoring and analyzing our activities;
9. processing investments and withdrawals of and payments of dividends to investors;
10. maintaining global client and investor records and providing centralized administrative, marketing and client services;
11. investigating and resolving complaints and recording calls and managing litigation monitoring electronic communications for fraud or crime detection or for regulatory reasons; and
12. complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities or law enforcement agencies).

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal data. Such grounds include, for example, circumstances where:

1. processing is necessary to perform our obligations under applicable advisory agreements or Sponsored Fund governing documents;
2. we are required to comply with a legal or regulatory obligation applicable to us; or
3. we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal data, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal data for such purpose.

We Combine Information

For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

What Are the Consequences Of Failing To Provide Personal Data

Where personal data is required to satisfy a statutory or regulatory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in our advisory agreement with you, or, as applicable, yoursubscription in the applicable Sponsored Fund being rejected or terminated, and/or your interests in a Sponsored Fund becoming subject to compulsory redemption or withdrawal, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose certain personal data about you to our affiliates, Service Providers or other third parties to onboard you as an advisory client, or in the case of Sponsored Fund investors, to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal data: (i) with courts, ombudsmen, regulatory, tax, law enforcement, or other non-governmental regulators and/or authorities to comply with applicable legal or regulatory requirements; (ii) to respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations; or (iii) when we believe in good faith that disclosure is legally required or we or a Sponsored Fund have a legitimate interestinmaking a disclosure, such as where necessary to protect our or a Sponsored Fund’s rights and property. We will also release information about you if you direct us to do so.

It may also be necessary, under anti-money laundering and similar laws, to disclose personal data about you to facilitate the establishment of trading relationships for your accounts, or in the case of Sponsored Fund investors, accounts of the Sponsored Funds, with prime brokers, custodians, executing brokers or other trading counterparties.

Wemay also disclose personal data about you, or yourtransactions and experiences with us, to our affiliates or Service Providers for our everyday business purposes, such as administration of our business, record- keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.¹

We may also disclose personal data about you to any third party that acquires, or is interested in acquiring, all or part of our assets or ownership interests, or that succeeds us in carrying on all or a part of our or its business, whether by merger, acquisition, reorganization or otherwise.

Retention Periods and Security Measures

We take standard security measures in accordance with applicable Data Protection Laws.

We will retain personal data for a minimum period of six years from the date on which you redeem all of your shares or unitsin the relevant Sponsored Fund(s) or you close your account with the Shenkman Group, or for as long as required for us to perform the services or comply with applicable legal or regulatory obligations. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time-to-time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longerserves any purpose to us.

Monitoring of Communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former clients and investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law

We may disclose information about our clients, investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non- affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about our clients or Sponsored Fund investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at DataProtection@shenkmancapital.com. If you are a new client or investor in a Sponsored Fund, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our client or an investor in a Sponsored Fund, we may continue to share your information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal data at DataProtection@shenkmancapital.com. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing

We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by a Sponsored Fund, or a client solicitor.

AdditionalInformation under the Cayman Islands Data Protection Act 2017 (“DPA”)

With respect to investors in Sponsored Funds organized under the laws of the Cayman Islands, the applicable Sponsored Fund may share your personal data with its Services Providers, including the Shenkman Group, as well as the Sponsored Fund’s administrators, transfer agents, depositories, distributors, custodians, prime brokers, or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the Cayman Islands. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPA. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You may have certain rights under the DPA, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. If you wish to exercise these rights, please contact DataProtection@shenkmancapital.com. A complaint in respect of a Sponsored Fund organized under the laws of the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have.

Additional Information under the General Data Protection Regulation and the Swiss Federal Act on Data Protection

You may have certain rights under the EU General Data Protection Regulation (“GDPR”) and equivalent legislation adopted in the United Kingdom including the UK General Data Protection Regulation (“UK GDPR”) as well as in Switzerland, to the extent the Swiss Federal Act on Data Protection (“FADP”) is applicable, in relation to our processing of your personal data and any processing carried out on your behalf. These include rights to:

1. Access: confirm with us whether your personal data is processed, and if it is, to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to receive confirmation regarding how and why we process your personal data.
2. Rectification: request correction/rectification of the personal data that we hold about you. This enables you to have incomplete or inaccurate information we hold about you corrected.
3. Erasure: request erasure of your personal data in certain circumstances.
4. Objection: object to processing of your personal data, on grounds relating to your particularsituation, where we are relying on a legitimate interest (or those of a third party). However, we may be permitted to continue to process your personal data where we have a compelling legitimate grounds for the processing. You also have the right to object where we are processing your personal data for direct marketing purposes.
5. Restriction: request the restriction of processing of your personal data in certain circumstances. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Portability: in certain circumstances, request to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format.

If we have relied upon your consent to process your personal data for a particular purpose, you have the right to withdraw your consent.

Please contact DataProtection@shenkmancapital.com if you wish to exercise these rights.

You also have the right to lodge a complaint about the processing of your personal data with the competent data protection supervisory authority. A complaint in respect of the Shenkman Capital Management Ltd may be lodged with the Information Commissioner’s Office in the United Kingdom. To the extent that FADP is
applicable, a complaint with respect to the Shenkman Group may be lodged with the Federal Data Protection and Information Commissioner in Switzerland. Nonetheless, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as in the European Economic Area, the United Kingdom or Switzerland (“Third Countries”). If you live outside of the United States and choose to use Shenkman’s website, you understand that it is at your own risk. You also understand that your information will be sent to the United States. Where we transfer personal data outside of the United Kingdom, the European Economic Area and Switzerland, we will use adequate safeguards, such as standard contractual clauses. In addition to the information provided in this paragraph, FADP requires us to inform you about the countries to where Swiss personal data may be transferred to, or where Swiss personal data may be accessed from. We may transfer Swiss personal data to countries, or may access Swiss personal data from countries, such as the UK, the United States, Ireland and the Cayman Islands. As explained above, we take specific security measures in accordance with applicable Data Protection Laws and have standard contractual clauses or any other relevant tool or mechanism in place as appropriate under FADP to provide an adequate level of protection.

The Shenkman Group has entered into standard contractual clauses (“Model Contracts”) for intra-group transfers of personal data. Investors have a right to request copies of the Model Contracts by contacting DataProtection@shenkmancapital.com. We may also be required to transfer your personal data to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

State-Specific Disclosures

If you are a California resident, California law may provide you with additional rights regarding our collection and use of your personal information. To learn more about your privacy rights, please see the California Consumer Privacy Notice as an addendum to this Privacy Notice below.

Revisions to Our Privacy Policies

The Shenkman Group evaluates its privacy policies and procedures to implement improvements and refinements from time-to-time. The Shenkman Group reserves the right to amend the terms contained herein in whole or in part for any reason. We therefore suggest that you review this Privacy Notice periodically, which is available at https://www.shenkmancapital.com/privacy_notice.

Who to Contact About This Privacy Notice

Please contact our Chief Compliance Officer at DataProtection@shenkmancapital.com, at (212) 867-9090, or by writing to the following address, Shenkman Capital Management, Inc., 151 W. 42nd Street, New York, NY 10036 with any questions about this Privacy Notice or requests with regards to the personal data we hold.

¹ Please refer to the Privacy Statement of Refinitiv, a due diligence Service Provider of the Shenkman Group, located here: https://www.refinitiv.com/en/policies/privacy-statement

California Consumer Privacy Notice

Introduction

This notice (the “CaliforniaConsumer Privacy Notice”)is provided by the Shenkman Group of Companies, and their affiliates (collectively the “Shenkman Group”), as well as mutual funds, private funds (single investor or commingled), Collateralized Loan Obligations (“CLOs”), and UCITS funds managed by the Shenkman Group (each, a “Sponsored Fund” and, collectively “Sponsored Funds”).

This California Consumer Privacy Notice contains disclosures required by the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) and only applies to California residents. This California Consumer Privacy Notice applies to the collection or other use of “personal information” that is subject to the CCPA.

References to “you,” “your,” “investor,” or “client” in this California Consumer Privacy Notice mean any resident of California. References to, “we”, “us”, or “our” in this California Consumer Privacy Notice mean a Sponsored Fund or the Shenkman Group, as applicable. The Shenkman Group includes Shenkman Capital Management, Inc., Shenkman Capital Management Ltd, Romark Credit Advisors LP, Romark CLO Advisors LLC, and their affiliates. Capitalized terms used but not defined herein have the meanings assigned to them in the Form ADV Part 2A of Shenkman Capital Management, Inc., or of Romark Credit Advisors LP, as applicable, each of which may be supplemented, updated or modified from time-to-time.

Personal Information We Collect

In the past 12 months, we may have collected, without limitation, the following categories of personal information about you:

• Identifiers, such as your real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers;
• Other personal information categories (as listed in the California Customer Records statute), such as your signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number or any other financial information, medical information, or health insurance information;
• Protected classification characteristics under California or federal law, such as your age, race, citizenship, marital status, gender, or veteran or military status;
• Commercial information, such as your account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Biometric information,such as your fingerprints, faceprints, voiceprints, and iris or retina scans;
• Internet or other similar network activity, such as information regarding your interaction with our website, online portal, or other applications;
• Sensory data, such as recordings of your audio (e.g., voicemails);
• Professional or employment-related information, such as your current or past job history or performance evaluations;
• Non-public education information, such as your education records maintained by an educational institution or party acting on its behalf;
• Inferences drawn from other personal information, such as a profile reflecting your preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive Personal Information, such as your Social Security number, driver’s license number, state identification card number, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; and racial or ethnic origin.

We do not knowingly sell personal information from anyone under the age of 16.

Sources of Personal Information We Collect

We primarily collect personal information from the following categories ofsources:

• Your communications with us;
• Service providers, including, but not limited to, administrators, lenders, banks, trading counterparties, auditors, law firms, consultants, placement agents, employment agencies and recruiters, and background check providers;
• Affiliates not under the Shenkman Group brand;
• Nonprofit organizations; and
• Government entities.

Use of Personal Information

We may use the personal information we collect for one or more of the following purposes:

• Providing you with information about our products and services;
• Providing performance and other updates;
• One or more of the following business purposes:
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
  • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
  • Legal compliance;
  • Internal operations;
  • Activities to maintain and improve ourservices; and
  • Other commercial purposes, including, but not limited to, activities that are directed to advancing commercial or economic interests, such as inducing a person to buy, rent, lease, join, subscribe to, provide or exchange products or services, or enabling or effecting a commercial transaction.

Sharing PersonalInformation

We may share your personal information as follows:

Please note, our Service Providers, include but are not limited to, administrators, lenders, banks, trading counterparties, auditors, law firms, consultants, placement agents, employment agencies and recruiters, and background check providers.

We may share your personal information to comply with our legal obligations (in response to a subpoena or other legal process by a governmental entity or third party if otherwise required by law) and internal policies. We may also share your personal information, on an as needed basis, to facilitate a business transfer or merger.

In the past 12 months, we have not sold, as we understand that term, any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers

Subject to certain exceptions and limitations, you have the following rights under your California law:

• The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
• For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
• The right to request that we delete the personal information we have collected from you or maintain about you;
• The right to correct inaccurate personal information we may maintain about you;
• The right to limit our use and disclosure of sensitive personal information about you;
• The right to opt out of our sale(s) (if any) of your personal information; and
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests to exercise your rights under the CCPA to our Chief Compliance Officer at DataProtection@shenkmancapital.com or at (212) 867-9090.

We may need to request additional information from you to verify your identity or understand the scope of your request. In verifying requests, we will require you to provide, at a minimum your mailing address and telephone number to verify your identity. If we are unable to verify your identity, we will need to deny your request.

You may designate an authorized agent to make a CCPA request on your behalf. In such case, we will ask the agent to provide proof that you have given the agent signed permission to act on your behalf. In addition, we will ask you to either (1) verify your identity directly with us in the manner described above or (2) directly confirm with us that you have provided the agent permission to make the request on your behalf

Retention of Personal Information

We retain personal information for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We decide how long we need personal information on a case-by-case basis. We may consider the following factors when making retention decisions:

• Whether we need to keep some of your personal information to maintain your account;
• Whether we are required by law to keep some types of personal information for certain periods of time to comply with our legal obligations; and
• Whether we need some of your personal information for other business purposes, such as to prevent harm and ensure safety and security of our website and services; investigate possible violations of our terms and conditions of use; or otherwise protect ourselves.

If we determine your personal information is no longer necessary using the factors above, we will generally destroy or anonymize that information.