Regulatory Disclosures.

Last Updated: January 2026

Investment Adviser Registration

Fortuneo, LLC and its investment-adviser affiliates operate in accordance with applicable U.S. federal and state investment adviser registration and exemption regimes. Registration status is disclosed to prospective and current limited partners in the applicable fund's Private Placement Memorandum and, where applicable, in Form ADV Parts 1, 2A, and 2B, which are made available upon request and through public regulatory databases.

Fund Vehicle Structure

All Fortuneo-sponsored investment funds are structured as Delaware Limited Partnerships. Parallel vehicles are available for tax-exempt investors and for non-U.S. investors under conditions specified in the applicable Limited Partnership Agreement.

Fund Auditor

Each Fortuneo-sponsored investment fund is audited annually by PricewaterhouseCoopers LLP (PwC). Audited financial statements are provided to limited partners within statutorily required timeframes.

Fund Administrator

Fund accounting, capital call processing, distribution processing, and limited partner reporting are performed by an independent third-party fund administrator. Administrator identity is disclosed in the applicable Private Placement Memorandum.

Fund Counsel

Fund formation, ongoing regulatory compliance, and limited partner documentation matters are handled by LePore Law Group in coordination with specialty counsel where required.

Governance Framework

• LP Advisory Committee: Every Fortuneo-sponsored investment fund seats a limited partner advisory committee with standing rights on conflicts of interest, valuation, and material fund events.
• Valuation Committee: A standing valuation committee, including an independent external member, reviews fair-value assessments on a quarterly basis.
• Investment Committee: All fund investments are approved by a fund-level investment committee with documented voting procedures and conflict-recusal policies.

Economic Alignment

• GP Commitment: The general partner co-invests two percent (2%) of committed capital in each Fortuneo-sponsored investment fund.
• Preferred Return: Limited partners receive a return of contributed capital and an eight percent (8%) preferred return before any carried interest is distributed to the general partner.
• Waterfall: Each investment fund uses a European whole-fund waterfall. Deal-by-deal carry is not used.
• Carry Escrow: Thirty percent (30%) of realized carried interest is held in escrow against clawback until final liquidation of the fund.

Conflicts of Interest

Fortuneo maintains a documented conflicts-of-interest policy addressing cross-fund investments, related-party transactions, principal transactions, allocation of investment opportunities across funds, and outside business activities of the general partner, its affiliates, and its personnel. Material conflicts are disclosed to the applicable fund's LP advisory committee. The full policy is available to limited partners in the LP Portal.

Best Execution and Broker Selection

Where Fortuneo-sponsored funds use brokerage or transaction services, brokers and counterparties are selected on the basis of best execution, including factors such as price, capability, reliability, and total cost. Fortuneo does not accept undisclosed compensation or benefits from brokers or counterparties.

Cybersecurity

Fortuneo maintains an enterprise cybersecurity framework aligned to the NIST Cybersecurity Framework, including multi-factor authentication, network segmentation, endpoint protection, encryption of data at rest and in transit, annual penetration testing by an independent third party, and a documented incident response plan. LP-facing cybersecurity attestations are provided annually.

Business Continuity

Fortuneo maintains a documented business continuity and disaster recovery plan, tested annually, covering personnel, technology, records, vendor relationships, and LP communications.

Anti-Money Laundering

Fortuneo maintains an anti-money-laundering and know-your-customer program in coordination with its fund administrator, including onboarding due diligence, ongoing screening, and reporting procedures consistent with applicable U.S. federal law.

Contact

Questions regarding these disclosures, requests for Form ADV, or requests for policy documents may be directed to [email protected].