CLEAN ENERGY TRANSITION LLP

The Firm has policies and procedures to address conflicts of interest when managing multiple accounts, including those with different fee arrangements. Investment opportunities are generally allocated pro rata based on the relative net worth of each client account, considering factors like investment suitability, regulatory limitations, and transaction costs. The Firm prepares schedules comparing allocations between advisory accounts within the same strategy, reviewed by the Chief Compliance Officer. The Firm may participate in meetings with corporate executives or capital introduction programs arranged by broker-dealers, potentially placing client portfolio transactions with these firms if it aligns with best execution, but not as remuneration for recommendations or opportunities. The Firm reviews the most significant holdings of client accounts daily, considering trading activity, corporate developments, and other factors that may necessitate portfolio changes. Portfolios are analyzed for risk management, including diversification, and reviewed periodically based on investment objectives and specific situations. Segregated managed accounts receive reports according to their client agreements, while investors in Firm-managed funds receive reports as outlined in the fund's offering documents.

The Firm's investment approach and method of analysis vary between its two main fund strategies. One of these strategies is the Energy Dynamics Funds. The Energy Dynamics Funds aims to take advantage and contribute to the world’s transition from an unsustainable to sustainable energy system by investing in best-in-class companies enabling and adopting these changes, and shorting poor companies positioned against this trend. The funds invest primarily in the equity and equity-related securities of global energy companies (including, but not limited to, energy companies involved in the coal, gas, and oil sectors, utilities, energy capital goods and renewables), which are identified as mispriced, either in absolute terms or relative to other equity securities.

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