Jordan Park Group LLC

ITEM 1. COVER PAGE 1. COVER PAGE DISCLOSURE BROCHURE March 30, 2026 JORDAN PARK GROUP LLC 100 Pine Street, Suite 2600 San Francisco, California 94111 415-417-3000 www.jordanpark.com This brochure provides information about the qualifications and business practices of Jordan Park Group LLC (“Jordan Park” or the “Firm”). If you have any questions about the contents of this brochure, please contact our Chief Compliance Officer at (415) 417-3000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”), or any state securities authority. Jordan Park is an SEC registered investment adviser. Registration does not imply a certain level of skill or training. information about Jordan Park is available on the SEC’s website at Additional www.adviserinfo.sec.gov (click on the link, select “Investment Adviser Search” and type in our firm name or Jordan Park’s CRD firm number, 287755). The results will provide clients with both Parts 1 and 2A of our Form ADV.  ITEM 2. MATERIAL CHANGES Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s brochure, the adviser is required to notify clients and provide a description of the material changes. Generally, Jordan Park will notify clients of material changes on an annual basis. However, when Jordan Park determines that an interim notification is required, Jordan Park will notify our clients promptly. The last filing of Jordan Park’s Form ADV Part 2 (“Brochure”) dated March 27, 2025, has been updated as of March 30, 2026. Material changes since the last annual amendment include: • We amended Item 5 to clarify certain types of fee arrangements, including a detailed description of the consolidated reporting fee, and clarification of the fees for certain long/short strategies managed by the Firm. • We updated Item 8 and Item 10 to further explain the circumstances in which the Firm may refer investment opportunities and clients to the Firm’s affiliated broker-dealer • Certain risks were added and/or revised in Item 8, including updates to the risks associated with emerging technology, long/short strategies and investments in new technologies. In addition, we made additional minor changes related to these updates, as well as other non- material changes to provide updated descriptions and clarification of existing policies and practices, throughout the Brochure. is available on the SEC’s public disclosure website (IAPD) at The Brochure www.adviserinfo.sec.gov or clients may contact our office at the number listed on the cover page of this Brochure to obtain a copy. If an update is made to this Brochure, Jordan Park will send a copy to clients with the summary of material changes, or a summary of material changes that includes an offer to send clients a copy either by electronic means (email) or in hard copy form. 2  ITEM 3. TABLE OF CONTENTS ITEM 1. COVER PAGE ............................................................................................................................... 1 ITEM 2. MATERIAL CHANGES ................................................................................................................. 2 ITEM 3. TABLE OF CONTENTS ............................................................................................................... 3 ITEM 4. ADVISORY BUSINESS ................................................................................................................. 4 ITEM 5. FEES AND COMPENSATION .................................................................................................... 7 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................. 11 ITEM 7. TYPES OF CLIENTS .................................................................................................................. 12 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ............... 13 ITEM 9. DISCIPLINARY INFORMATION .............................................................................................. 37 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS.................................. 37 ITEM 11. CODE OF ETHICS .................................................................................................................. 40 ITEM 12. BROKERAGE PRACTICES ..................................................................................................... 42 ITEM 13. REVIEW OF ACCOUNTS ...................................................................................................... 44 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ...................................................... 45 ITEM 15. CUSTODY ................................................................................................................................ 45 ITEM 16. INVESTMENT DISCRETION.................................................................................................. 46 ITEM 17. VOTING CLIENT SECURITIES .............................................................................................. 47 ITEM 18. FINANCIAL INFORMATION ................................................................................................. 48 3  ITEM 4. ADVISORY BUSINESS Jordan Park provides investment and financial advisory services to a distinct community of primarily high net worth individuals, families, and their related entities, including trusts and estates, as well as charitable organizations, foundations, donor-advised funds, and other clients. The Firm, which is privately held, was founded in 2017 and is principally owned by our Chief Executive Officer, Frank Ghali, through Jordan Park Holding Company LLC and his related estate planning entities. The Firm is under common ownership with an affiliated trust company, Jordan Park Trust Company LLC (“JPTC”), based in New Hampshire, and an affiliated broker- dealer, JP Portsmouth Capital LLC (“JPPC”), based in New York. At the end of 2025, there were 153 employees at Jordan Park across three offices in San Francisco, California, New York, New York, and Portsmouth, New Hampshire. Jordan Park provides the following advisory services, among other services, to clients, in each case pursuant to written agreements (collectively, a “Client Agreement”) executed by both Jordan Park and the client. Investment and Financial Advisory Services. Jordan Park manages and oversees the investment of client assets primarily on a discretionary basis (“Managed Assets”). As part of the advisory relationship and investment process, Jordan Park works with each client to assess its unique financial situation and to develop and maintain a customized set of investment guidelines that reflect the client’s overall investment objectives and constraints. The investment guidelines are updated periodically and facilitate investment planning and the implementation of a client’s portfolio based on the client’s specific guidelines and restrictions, risk objectives, liquidity considerations, and/or any unique investment goals, such as environmental, social, and governance (“ESG”) factors or restrictions and impact considerations. Consistent with each client’s investment guidelines, Jordan Park develops a strategic and comprehensive asset allocation and invests the client’s Managed Assets across a spectrum of investment strategies in one or more of the following ways: (i) through a portfolio of separate accounts sub-advised by third-party investment advisers (“Separate Accounts”), (ii) directly in exchange-traded funds (“ETFs”), mutual funds and other investments including pooled investment vehicles managed by third parties (“Direct Investment Accounts”), and/or (iii) directly in pooled investment vehicles sponsored and managed by Jordan Park (“JP Funds”, and together with Separate Accounts and Direct Investment Accounts, the client’s “Portfolio”). Using these strategies, Jordan Park can customize each Portfolio to meet a client’s particular needs. The Firm also provides advice concerning diversification strategies and other advisory services to certain clients regarding assets that are not Managed Assets, such as concentrated equity or substantial real estate assets holdings, as supplemental advisory services. As part of the investment advisory services, the Firm also selects sub-advisors on behalf of clients to manage portions of their Managed Assets through Separate Accounts, in each case pursuant to the terms and conditions of an agreement with the relevant sub-advisor which will generally include the delegation of investment discretion to the sub-advisor. For JP Funds, the Firm selects the underlying investments, either in a fund managed by another advisor, in another JP Fund, or in direct investments or co-investments with managers or portfolio companies. Where 4  appropriate, Jordan Park, or a third-party engaged by Jordan Park, conducts initial due diligence on, and monitors on a periodic basis, such sub-advisors, managers, and other investments. Jordan Park typically negotiates the fees to be paid by clients or by the JP Funds. Jordan Park also provides consolidated performance reporting for the Managed Assets of our clients, and in some cases, develops customized reporting to include other assets not managed by Jordan Park. If a client has requested that Jordan Park collect data to provide reporting on non-Managed Assets, Jordan Park will charge a consolidated reporting fee, as further detailed in Item 5. Capital Markets Services. Jordan Park provides advice to certain clients with respect to strategies relating to equity and debt capital markets. Jordan Park will also refer clients to either JPTC or JPPC for specific client engagements depending on a client’s needs, which can include single stock advisory services or consulting services relating to private or public equity or debt security transactions, among other services. Clients will enter into a separate agreement with either JPTC or JPPC for such services. Family Office Services. Jordan Park will provide a range of family office services customized to serve the needs of its clients upon mutual agreement with the client, including broad-based balance sheet and cash flow analysis; cash flow and capital budgeting and forecasting; periodic asset and performance reporting; income tax planning analysis and coordination with clients’ tax advisors; wealth transfer and related gift and estate tax planning analysis and coordination with clients’ estate advisors; philanthropy and charitable gift strategy and planning; insurance policy review and analysis; payment processing (including bill pay); support in acquiring and disposing of major assets; advice regarding management and retention of employees and other service providers; and other services typically undertaken by family offices on behalf of their clients. Jordan Park will deliver these services after consultation with the client and in partnership and coordination with the client’s existing outside advisors, including legal counsel, accounting professionals, estate planning professionals, insurance providers, philanthropic advisors, and family office staff (or, in their absence, advisors recommended by Jordan Park and selected by the client). In some cases, some of these services are provided by third-party service providers engaged by Jordan Park. If requested by a client and agreed to by Jordan Park, family office services can be provided with respect to client assets and liabilities beyond Jordan Park’s Managed Assets, regardless of custodian or asset manager, or in some cases are offered to clients who do not have Managed Assets with Jordan Park. Any additional fees associated with the family office services provided will be included in the Client Agreement as described in Item 5. Clients may also choose to appoint JPTC to serve as an authorized person of their entities, such as a trustee of a trust or manager of a limited liability corporation, in accordance with a separate agreement with JPTC. IRA Rollover Recommendations. For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, Jordan Park is providing the following acknowledgment to clients. When the Firm provides investment advice to clients 5  regarding their retirement plan account or individual retirement account, Jordan Park is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way the Firm makes money creates some conflicts with client interests. Jordan Park operates under an exemption that requires the Firm to act in the clients’ best interest and not put the Firm’s or its employees’ interests ahead of the clients. Under this exemption, Jordan Park must: • meet a professional standard of care when making investment recommendations (give prudent advice); • not put the Firm’s or its employees’ financial interests ahead of the clients when making recommendations (give loyal advice); • avoid making misleading statements about conflicts of interest, fees, and investments; • follow policies and procedures designed to ensure that the Firm and its employees give advice that is in the clients’ best interest; • charge no more than is reasonable for services; and • give the clients basic information about conflicts of interest. Jordan Park benefits financially when a client selects the Firm to manage its retirement assets because the assets increase the Firm’s assets under management and, in turn, its Advisory Fees (as defined below). As a fiduciary, Jordan Park only recommends investments for a retirement account when the Firm and its employees believe it is in the client’s best interest. To the extent the Firm is a fiduciary of a client’s retirement account and recommends a rollover to another type of retirement account, such recommendation will also be made if the Firm believes it is in the client’s best interest, and clients are given the opportunity to review the Firm’s recommendations with respect to a rollover. ESG and Impact Investing and Advising. Jordan Park provides a range of services related to ESG and impact investing, as well as guidance and advice regarding philanthropy strategy and non-profit management. ESG and impact considerations are integrated into the overall investment due diligence and selection process across Jordan Park’s investment activities by considering ESG and impact factors alongside non-ESG or impact factors. Clients have the ability to indicate their preference for ESG and impact Investing in their investment guidelines. For clients who indicate a preference for ESG and impact Investing, the Firm will allocate a client’s Portfolio into available investment opportunities that have either an ESG or impact investment objective and are consistent with the client’s financial goals. ESG and impact reporting is also available to clients upon request, which provides an analysis and assessment of the ESG and impact characteristics in the client’s Portfolio. Other impact advisory services include education and guidance, strategy and activation, and the facilitation of partnerships and community. In addition, these services may include support specific to philanthropy such as budgeting and planning, entity and grantmaking facilitation, and philanthropic reporting. Any additional fee for these services will be included in a Client Agreement as described in Item 5. Assets Not Advised by Jordan Park. At times, clients request Jordan Park to transact in and/or oversee certain securities or other assets that Jordan Park does not advise on. If deemed appropriate based on the client’s individual needs and circumstances, Jordan Park will agree to 6  provide such services and will also consider the impact of such securities or other assets in its overall asset allocation recommendations. However, Jordan Park is not obligated to provide investment advice on such securities or other assets for which it does not regularly provide investment advisory services or on non-advised assets. Wrap Fee Programs. The Firm does not participate in nor sponsor wrap fee programs. Assets Under Management. As of December 31, 2025, the Firm had approximately $23.3 billion in assets under management, the majority of which are managed on a discretionary basis. ITEM 5. FEES AND COMPENSATION Generally, clients will pay Jordan Park an annual percentage fee based on the value of the Managed Assets in the client’s Portfolio. Clients will also bear underlying investment costs and, depending on the investments and services selected, fees and expenses charged by other financial institutions and third parties, such as sub-advisors, other expenses charged by Jordan Park and/or its affiliates, and fees and expenses of JP Funds including, as applicable, fund management fees, performance-based incentive compensation (“Incentive Fees”), and fund accounting and operations fees. Detailed information about Jordan Park’s compensation structure and other costs, fees and expenses a client may incur is provided below. Clients may request additional information at any time as to their client-specific costs, fees and expenses. Investment Advisory Fees. In exchange for its investment and financial advisory services, the Firm typically charges a tiered annual percentage fee based on the total value of a client’s Managed Assets, and the blended annual percentage fee typically ranges from 0.30% to 0.75% (“Advisory Fee”). The Advisory Fee rate is generally lower for clients with higher amounts of assets under management and certain charitable organizations but can be higher if additional family office services are, or are expected to be, provided by Jordan Park. In addition, Jordan Park negotiates Advisory Fees with certain clients based on factors unique to them, including a client’s needs, nature and complexity of the services to be performed, and the size and types of assets. This may result in these clients paying higher or lower Advisory Fees than clients with similar Managed Assets. Advisory Fees charged by Jordan Park are detailed in each Client Agreement. Jordan Park waives all Advisory Fees for its employees and their respective family members who enter into a Client Agreement with Jordan Park for investment advisory services. JP Funds Fees and Expenses. Typically, each JP Fund is charged a management fee, paid to Jordan Park, as outlined in the governing documents of the JP Fund. In addition, as described in more detail in Item 6, certain JP Funds incur an Incentive Fee payable to Jordan Park. All investors in JP Funds (“JP Fund Investors”) are responsible for their share of the costs, expenses, and liabilities relating to their investment in the JP Funds, as authorized under the governing documents of the JP Funds. This includes a pro-rata portion of any fees and expenses charged or borne by the JP Funds, such as management fees and Incentive Fees, fees and expenses of the underlying investments of the JP Funds, as well as expenses incurred in connection with the organization, offering, operation, administration, regulation, taxation, dissolution, liquidation, and termination of such JP Funds; and expenses related to the research, evaluation, due diligence, negotiation, consummation, management, valuation and disposition 7  of investments and investment-related travel expenses (including, as applicable, those expenses that relate to investments that are not consummated) of such JP Funds. Certain JP Funds charge a fund accounting and operations fee, details about which are described in the fund documents. With respect to certain JP Funds, Jordan Park has agreed to waive 50% to 70% of the fund management fees for investors who are clients that pay Jordan Park Advisory Fees, depending on the JP Fund. In other words, clients pay less than the standard fund management fee to these JP Funds, and a client’s Advisory Fee applied to the Managed Assets includes the value of the investments in these and other JP Funds as determined according to the governing documents of the JP Funds. Under arrangements already in place with clients invested in legacy closed-end JP Funds established prior to 2024, or if otherwise agreed with a client or investor, Jordan Park is waiving 100% of the JP Fund management fees. If the advisory relationship between a client and Jordan Park ends and a client is no longer paying an Advisory Fee, unless Jordan Park agrees to a different arrangement, the client will begin paying 100% of the fund management fees otherwise chargeable by the applicable JP Fund(s) if they remain an investor in a JP Fund. The Incentive Fee is generally not waived for clients and is in addition to the Advisory Fee, fund management fees, and all other fees, costs and expenses, as applicable; although certain JP Funds may have a higher Incentive Fee for clients not paying an Advisory Fee, which will be described in the fund governing documents. In some cases, the Incentive Fee is earned only after a performance hurdle or preferred return is achieved, while some JP Funds have no performance hurdle or preferred return. The Firm does not earn Incentive Fees on Managed Assets that are not invested in the JP Funds. Jordan Park waives all fund management fees, Incentive Fees, and fund accounting and operations fees for its employees and their respective family members who invest in JP Funds. interest expenses, custodial investments, co-investments, and “secondary” Underlying Investment Fees and Expenses of Financial Institutions and Other Third Parties. Managed Assets also bear the economic effect of any fees (including management and, if applicable, Incentive Fees of third-party sub-advisors and managers) and expenses (including brokerage fees and/or commissions, trading fees and expenses, shareholder fees, private fund expenses, currency hedging costs, fees, bank charges, commitment fees and other fees and amounts payable in connection with borrowing) of the Portfolio’s underlying investments, including investments made by the JP Funds, if any. Such fees and expenses are associated with a variety of investments, including publicly traded securities, such as stocks and ETFs, mutual funds (including money market funds), and other financial instruments, such as derivatives; fixed income securities; real assets; asset-backed securities or other structured debt or equity investment products; assets in “qualified opportunity zones” (“QOZ”); private funds managed by a third-party manager (a “Third-Party Manager”) or by Jordan Park or an affiliate of Jordan Park, such as venture capital funds, private equity funds, absolute return funds, real asset funds, hedge funds, and other types of pooled investment vehicles; direct investments (collectively, the “Portfolio Investments”). Please refer to Item 12 for additional information about our brokerage practices. 8  Fees for Additional Services. Jordan Park can charge fees for other services requested by the client (e.g., reporting on non-Managed Assets, Family Office services, and consultative services on non-advised assets), as described in Item 4. Jordan Park also charges some clients fees for certain family office or impact and philanthropy related services, the amount of which varies depending on the services provided and the experience of the team member(s) providing the services. Any such additional services and associated fees will be agreed upon with the client through the Client Agreement and may include a fixed, periodic fee. Consolidated Reporting Fee: If a client has requested that Jordan Park collect data to provide reporting on non-Managed Assets, Jordan Park will charge a consolidated reporting fee according to the fee outlined in the Client Agreement for the use of a third-party software and data aggregation platform, which will generally be $300 per position on an annual basis. Clients who do not need reporting on non-Managed Assets are not required to use the third-party resources available through Jordan Park to administer or report on non-Managed Assets. There are certain tangible non-Managed Assets that typically do not have cash flow activities, such as cars, art or jewelry, that are reflected in the third-party software and data aggregation platform and included in client reports without incurring the consolidated reporting fee. In addition, Jordan Park will reduce or waive the consolidated reporting fees for certain clients based on factors unique to each such client, including the nature and complexity of the non-Managed Assets included in the reporting. Calculation and Payment of Fees. The Advisory Fees and fees for additional services are typically paid by (i) direct deduction from clients’ accounts by Jordan Park; (ii) direct deduction from clients’ accounts by a third-party (such as a sub-advisor); (iii) direct transfer from clients’ accounts by the client or Jordan Park for remittance to a third-party or Jordan Park; or (iv) charged to the clients’ interest in the JP Fund. In certain circumstances, clients are invoiced for all or a portion of the client’s fees and expenses. The consent for deduction of fees is contained in the Client Agreements or the agreements with the third parties involved. Clients’ custodians deliver periodic (at least quarterly) account statements directly to clients. The statements include all transactions that took place in the account during the period covered by the statement and reflect any fees deducted directly from the account. Clients are advised to review the fees charged to their account(s) to fully understand the total amount of all fees charged. Fund management fees charged directly to an investor’s interest in a JP Fund would be reflected in the quarterly capital statement provided to all investors in the JP Fund. Advisory Fees are paid quarterly in arrears, based on the value of the average daily balance of the Managed Assets in a client’s Portfolio (“Average Daily Balance”) over the prior quarter. The Average Daily Balance for the Firm’s Advisory Fee calculation is equal to the sum of (i) the average daily market value balance of liquid investments (which includes the market value of any derivatives and the net market value of any accounts invested in a long/short strategy); (ii) the average daily target notional balance of derivative overlay strategies (other Managed Assets held as collateral for such strategies separately are included in the calculation of the Average Daily Balance pursuant to clause (i)); and (iii) the average daily net asset value (“NAV”) (or such other value (“Other Value”) as described in the governing documents of applicable JP Funds) of all other investments. The governing documents of a JP Fund will describe the calculation 9  methodology of the value to be used for purposes of calculating the Average Daily Balance assigned to the JP Fund, which may be different than NAV. Certain long/short strategies may incur an additional fee if leverage exceeds predetermined thresholds. Any such fee will be based on the degree of excess leverage utilized and will apply only to the Separate Account employing the strategy. Additionally, for certain long/short strategies that utilize collateral held in another Separate Account or Direct Investment Account, the Advisory Fee will be adjusted and calculated based on the gross value of the long and short positions within the long/short strategy Separate Account. In both cases, these arrangements will be detailed in the applicable Client Agreement. Fees for additional services are paid based on the calculation methodology described in the relevant Client Agreement. Valuation of Managed Assets: For liquid investments, including derivatives, held in Separate Accounts or Direct Investment Accounts, market values are provided by the relevant custodian of a client’s Managed Assets and shared through a data feed to Jordan Park’s third-party reporting system which is used for fee billing and valuation purposes. For client investments in JP Funds, Jordan Park or the administrator to the JP Funds calculates the NAV or Other Value of the JP Funds, generally based on valuations provided to us or the administrator by third parties, including investment advisers unaffiliated with Jordan Park, administrators to private investment vehicles, and third-party valuation agents. In certain circumstances, primarily involving direct investments in private companies or other closely held securities that are not actively traded on a public market, Jordan Park will assess the fair value of such securities in accordance with the Firm’s valuation policies and procedures. Investments in private companies and certain real estate development assets will generally be valued at the cost of the investment for some period of time, including during the construction phase for real estate development assets, but in any event will be assessed at least annually based on the Firm’s valuation policies and procedures. In the absence of a new NAV or Other Value, the NAV or Other Value of such investments will remain the same from day to day, and over longer periods of time in the case of illiquid investments. The values assigned to a JP Fund’s assets and the determination of the NAV or Other Value of the JP Fund affect fundamentally whether a JP Fund is deemed to have experienced a profit or a loss for a particular period and other economic attributes of the JP Fund. Advisory Fees, fund management fees, Incentive Fees, the amounts to which investors are entitled to receive upon withdrawal, and the impact of new capital contributions and withdrawals on profit and loss participation depend on valuations of a JP Fund’s assets and liabilities. Because valuations of non-marketable assets generally involve significant professional judgment in the application of both observable and unobservable attributes, the values of a JP Fund’s non-marketable assets as of any measurement date could differ significantly from their future fair market values or their actual values at realization. A JP Fund’s assets will consist predominantly of its interests in Portfolio Investments, the underlying assets of which are valued by their respective manager or portfolio managers or their affiliates or designees. A Portfolio Investment will not necessarily engage an independent 10  valuation agent to value its investments or underlying assets and could therefore be entirely reliant upon the manager or the portfolio manager or its affiliates or designees for the valuation of the Portfolio Investment. In such a case, the manager or portfolio manager and their affiliates or designees have an inherent conflict of interest in valuing the Portfolio Investment, as the fund management fees and, if applicable, Incentive Fees to be received by a manager or portfolio manager and/or its affiliates generally will be calculated based upon the value of the Portfolio Investment. To the extent that Jordan Park is involved in the valuation of a JP Fund’s assets and liabilities, Jordan Park also has an inherent conflict of interest in performing this function. It is in Jordan Park’s interest to have the assets of a JP Fund valued at as high a level as possible, as the fund management fee or Advisory Fee as well as any Incentive Fee to be received by Jordan Park from certain JP Funds will be calculated based on such valuation. In addition, Jordan Park’s performance record used in marketing Jordan Park’s services to current and prospective clients and investors will be in part dependent on the performance of the JP Funds. To mitigate this conflict, the valuation process is overseen by a Valuation Committee and all determinations of the fair market value of an asset made internally by Jordan Park are reviewed and approved by the Valuation Committee. If and to the extent that Jordan Park determines that the values for any period differ materially from the values on which Jordan Park based a client’s Advisory Fee for investments over that period, Jordan Park will adjust the Advisory Fee as it deems appropriate to take such differences into account. Such adjustments could result in a client paying more or less in fees than were originally charged, depending on the circumstances. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Performance-based fees are fees based on a share of capital gains on, or capital appreciation of, the assets of a client. Side-by-side management generally refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management, hourly charges, fixed fees (not including subscription fees) and at the same time manages other accounts for which fees are assessed on a performance fee basis. We engage in both practices, as described below. We manage JP Funds that charge an Incentive Fee and manage other JP Funds, Separate Accounts or Direct Investment Accounts for which Jordan Park only charges an Advisory Fee and/or a fund management fee. For certain JP Funds, the Incentive Fee is earned only after a performance hurdle or preferred return is achieved, while some JP Funds have no performance hurdle or preferred return. In addition, the Incentive Fee or management fee can be different among the various JP Funds. As a result, we have an incentive to favor JP Funds that could generate higher compensation for the Firm, such as JP Funds for which we receive a higher Incentive Fee or JP Funds with an Incentive Fee without a performance hurdle or preferred return, over JP Funds with a performance hurdle or preferred return or JP Funds for which we do not receive any Incentive Fee. Clients should be aware that this creates a conflict of interest and may indirectly influence the way we manage the investment due diligence and allocation process. To address this conflict of interest, we have developed and implemented policies and 11  procedures with respect to investments that may be appropriate for more than one client or JP Fund, which include a review of the fees charged to clients, the investment merits and suitability considerations for different clients or JP Funds, and a review of the allocation decision by the Conflicts Committee if an investment opportunity has limited capacity and is deemed to be suitable and appropriate for more than one client or JP Fund. The ability to receive Incentive Fees creates conflicts of interest for Jordan Park between its responsibility to manage the JP Funds and its interest in maximizing the profits it will receive. For example, these types of fees create an incentive to make more risky or speculative investments to generate higher positive returns or to allocate client capital to the JP Funds over other investments that do not pay an Incentive Fee. In addition, the compensation of Jordan Park could be affected by the timing of dispositions and other factors within the control of Jordan Park. We disclose this conflict of interest in fund documents which include detailed information about the Incentive Fees applicable to the JP Fund, and each client or investor must complete and execute a subscription document before investing in a JP Fund. The Firm structures any performance-based fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3 which allows, among other things, an investment adviser to assess performance-based fees on assets of “qualified clients” as defined by Rule 205-3. Jordan Park recommends the JP Funds to invest clients’ Managed Assets only when it deems it to be consistent with its clients’ investment guidelines. To help mitigate conflicts associated with the multiple potential avenues for investment, which can have different fees or levels of profitability for the Firm, Jordan Park charges a single Advisory Fee on a client’s Managed Assets in accordance with the Client Agreement, and a client must complete and execute a subscription document before investing in JP Funds that have different fee arrangements from Separate Accounts or Direct Investment Accounts such as the fund management fees, Incentive Fees, and other fees and expenses as described above. Jordan Park has also implemented an investment process culminating in a committee approval for Portfolio Investments, with related policies, procedures, and controls to consider the best interest of all clients for whom an investment may be appropriate. See Item 8 for more details. ITEM 7. TYPES OF CLIENTS Jordan Park’s clients include high net worth individuals and their families and related entities, such as trusts and business entities (e.g., limited liability companies and family limited partnerships), as well as charitable organizations, foundations, donor-advised funds, and other institutional clients. Jordan Park also manages the JP Funds in which clients and other investors invest. The Firm generally provides investment advisory services to clients with assets under management exceeding $25 million, with many of our clients exceeding $100 million or more. Upon a client’s request, and as accepted by Jordan Park at its sole discretion, assets under management of related parties (e.g., family members) may be associated or linked together for 12  purposes of meeting the asset amount. We also have a select number of client relationships that are limited to family office services and do not include investment advisory services. To invest in the JP Funds or certain pooled investment vehicles managed by third parties, clients must be sophisticated in financial matters, “accredited investors” within the meaning of Regulation D under the Securities Act of 1933, as amended, and “qualified purchasers” under the Investment Company Act of 1940, as amended (“Investment Company Act “), and the regulations thereunder. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Investment Strategies and Methods of Analysis. Our professionals, based on experience and judgment, utilize various analytical frameworks to determine which investment strategies best serve our clients’ needs. We stay abreast of microeconomic and macroeconomic fundamentals and build Portfolios based on our expectations of returns, risks (e.g., using variance), and correlation amongst assets. We regularly monitor risk levels in our clients’ Portfolios, taking advantage of the natural volatility of the markets to actively rebalance Portfolios and align the investments to clients’ targeted risk objective as expressed in their investment guidelines while also considering the tax consequences of any rebalancing activity for taxable clients. During market dislocations, we typically review and adjust as appropriate risk levels within agreed-upon constraints as described in the investment guidelines to take advantage of investment improve the risk and/or return opportunities that such dislocations may provide to characteristics of client Portfolios. Where possible, and if appropriate or feasible for a client’s circumstances, we also employ tax-loss harvesting strategies to improve the tax characteristics of client Portfolios. However, Jordan Park does not provide tax services and tax-managed investing strategies are not designed to provide comprehensive tax advice, are limited in scope and not designed to eliminate taxes in an account, and (like any investment strategy) subject to risks. Given the ever-evolving landscape of investment vehicles and types of assets available to sophisticated investors, Jordan Park has a pragmatic approach to alternative assets. We utilize alternative assets only when, in our judgment, those assets could reasonably improve risk- adjusted returns for our clients. The investment process is led by the Chief Investment Office and implemented by a dedicated Investment Team. Members of the team focus on, among other areas, public equities and fixed income, private credit, private equity, real estate, real assets, emerging markets, natural resources, derivative overlay strategies, transaction structuring, risk management, special situations, and ESG and impact investing. The process involves identifying, reviewing, and analyzing prospective investment opportunities while conducting due diligence on and monitoring third-party sub-advisors and managers, and other investments. Generally, if an investment opportunity is attractive and suitable as a Portfolio Investment, the Investment Team prepares an investment memorandum for review and approval by the sub-committee of the Investment Committee (“IC”). In the event the Chairperson of the sub-committee of the IC determines that an investment decision should be reviewed by the IC, the Chairperson will bring such investment decision to the IC for its approval. The IC’s approval is also required for new 13  investment strategies and certain investment decisions such as tactical positioning or strategic asset allocation changes that materially impact aggregate Managed Assets in excess of a defined threshold, among other decisions as required by the IC charter and the Firm’s investment due diligence policies and procedures. Jordan Park’s Investment, Legal and Compliance Teams collectively conduct and oversee operational and legal due diligence for Portfolio Investments. Allocation of Investment Opportunities Among Clients. Jordan Park, in certain cases, allocates limited investment opportunities among its clients, including the JP Funds, which could disadvantage one or more other clients or JP Funds. Managing different portfolios raises conflicts of interest with respect to the allocation of expenses, resources, and investment opportunities which the Firm, to the extent practicable, seeks to equitably resolve over the long term. Due to the customization of certain Portfolios, the Firm on occasion gives advice or acts with respect to one client in a way that differs from the advice given to a different client. However, the Firm seeks to allocate investment opportunities fairly and equitably over time while acknowledging that not all opportunities are equally suitable for all clients. In its allocation of investment opportunities, the Firm uses the JP Funds to offer clients exposure to private investments or investments in a particular asset class. As a result, Jordan Park allocates more of such investments to the JP Funds to provide a greater number of clients the opportunity to access these investments. Although the Firm manages investments on behalf of a number of other client accounts, investment decisions and allocations will not necessarily be made in parallel among any JP Fund and these other client accounts. Investments made by any JP Fund will not necessarily replicate the investments, investment methods or strategies of other accounts managed by the Firm. If the Firm determines that an investment is appropriate and suitable for more than one client and/or JP Fund, the Firm will allocate the investment opportunity in a manner as determined by the Firm in its discretion, taking into account specific considerations, including, without limitation, the discretion granted to the Firm by clients to invest in such an opportunity, cash available for investment and liquidity, current and prospective asset mix, investment objectives and restrictions, investment style, overall portfolio composition and performance, the appropriate risk and reward ratio, allocation and exposure to other similar investment opportunities, prospective investment opportunities and other investment or client relationship considerations. In the case of allocations to one or more JP Funds, the Firm can decide to allocate to a later-established JP Fund with a narrower focused investment objective before allocating to an earlier-established JP Fund with a broader investment objective. In the event that an investment opportunity is not suitable or otherwise pursued by one or more clients or JP Funds, or there is excess capacity, the Firm can refer the investment to its affiliated broker-dealer, JPPC, to be able to offer the investment to its clients or prospective clients in exchange for a separate fee paid to JPPC. The factors to make this determination will depend on the circumstances and nature of the investment, including but not limited to the suitability of the investment within the Managed Assets of client Portfolios. This can create a conflict of interest for the Firm because of the affiliation to JPPC and the indirect financial benefit that 14  Jordan Park receives from the fees and commissions earned by JPPC. Please see Item 10 for more information about the Firm’s business affiliations and related conflicts. Differing Investment Interests Among Clients. While Jordan Park generally endeavors to select and manage investments for each client based on what Jordan Park believes is in the best interest of that client, the interests among Jordan Park’s various clients may not always be aligned, and a conflict of interest can arise as a result. For example, Jordan Park may cause clients and/or its JP Funds to invest in different parts of the capital structure of the same issuer if it believes that doing so is in the best interest of each individual client or JP Fund (that is, one client or JP Fund may invest in the senior debt securities of an issuer in which another client or JP Fund holds junior debt securities or equity). Jordan Park must also allocate limited opportunities among its clients or JP Funds when it structures, negotiates, or agrees to be subject to the terms of an investment on behalf of its clients or JP Funds in common issuers. The decisions made in such scenarios could lead to different investment outcomes even if clients or JP Funds are invested in the same issuer. Furthermore, in the event of an actual or threatened event involving default or reorganization, or another major event affecting an issuer in which Jordan Park clients have differing economic exposure, Jordan Park may exercise creditor rights or remedies (like foreclosure), or decline to exercise those rights or remedies, or take (or omit to take) other actions (like re-financings or follow-on investments) that could benefit certain groups of clients over others. Although Jordan Park seeks to resolve these types of conflicts in a manner that, over time and under the circumstances, is generally fair and equitable to all of its clients, the resolution of any particular conflict could result in adverse consequences to a particular client or JP Fund in any particular instance despite the Firm’s best efforts and intentions. Investment Opportunities for Employees. Employees and principals of Jordan Park may have the opportunity to invest in private investments or private funds that are not affiliated with Jordan Park (i.e., not a JP Fund). These opportunities could include, but are not limited to, interests in limited partnerships or limited liability companies; certain cooperative investments in real estate; commingled investment vehicles such as hedge, real estate, private equity, or venture capital funds; and investments in privately held or family-owned businesses. Given the potential conflicts that can arise with these types of investments, Jordan Park reviews and approves such requests in accordance with its policies and procedures, and will consider a number of factors, including the way in which the investment opportunity was introduced to the employee, any existing relationship between Jordan Park and the principals of the fund or company, and the likelihood of any JP Fund investing in such investments. In general, Jordan Park will not approve an employee’s investment in funds or direct investments if any JP Fund is also investing or pursuing such investment and the employee investment could prevent or otherwise constrain the JP Fund’s opportunity or ability to invest. However, there may be instances in which employees invest in opportunities that are not appropriate for client Portfolios or a JP Fund due to several factors, including the size of the investment opportunity, the suitability of the opportunity for any client Portfolio or JP Fund, the timing of the opportunity, or the source of the opportunity. This presents a conflict of interest in that employees may invest in opportunities that are not offered to, or considered for, client Portfolios or JP Funds. Jordan 15  Park mitigates this conflict through its employee personal investment policies and procedures as well as the allocation policies and procedures described above. Material Risks of Investment Strategies and Methods of Analysis. We remain mindful that asset markets by their very nature are unpredictable, and that any investment in, or investment strategy that pertains to, securities or other financial instruments involves risks of loss that clients must be willing to bear. The performance of any investment is subject to numerous factors which are neither within the control of, nor predictable by Jordan Park. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war, or a regional or global pandemic) that affect investments in general or in specific industries or companies. The investment decisions made, and the actions taken in managing client Portfolios, will be subject to various market, liquidity, currency, economic, political and other risks. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments may lose value, and past performance is never a guarantee of future results. The information contained in this Brochure cannot disclose every potential risk associated with an investment strategy, nor all of the risks applicable to a particular investment opportunity. A client Portfolio’s level of risk will vary by client according to their investment objectives, guidelines, liquidity needs or risk tolerances and not every client Portfolio will be exposed to each of the risks described in this Brochure. This list is not intended to be exhaustive of all of the risks associated with investing in strategies or securities that are utilized or recommended by Jordan Park, but rather a general list of the types of risks of the investment advisory services provided by us and the related investments. This summary is qualified in its entirety by reference to the prospectuses and offering documents that apply to the investments and/or JP Funds that we recommend or in which a client invests. Clients should carefully read any applicable offering documents of the JP Funds and should consider consulting with their legal and/or tax professionals before investing in the JP Funds. GENERAL RISKS Social, Political, Economic, and Other Conditions. Social, political, economic, and other conditions and events (such as natural disasters, epidemics and pandemics, terrorism, war, government-imposed economic sanctions, political conflicts, and social unrest) will occur that have significant impacts on issuers, industries, governments, and other systems, including the financial markets, to which clients and the issuers in which they invest are exposed. As global systems, economies, and financial markets are increasingly interconnected, events that historically had limited geographic or market impact are now more likely to have regional or even global effects. An event that occurs in one country, region, or financial market will, more frequently, adversely impact issuers in other countries, regions, or markets, including in established markets such as the United States. This impact can be exacerbated by the failure of governments and societies to adequately respond to an emerging event or threat. 16  Uncertainty can result in or coincide with increased volatility in the global financial markets, including those related to equity and debt securities, loans, credit, derivatives and currency; a decrease in the reliability of market prices and difficulty in valuing assets; greater fluctuations in currency exchange rates; increased risk of default (by both government and private issuers); further social, economic, and political instability; nationalization of private enterprise; greater governmental involvement in the economy or in social factors that impact the economy; greater, less or different governmental regulation and supervision of the securities markets and market participants and increased, decreased or different processes for and approaches to monitoring markets and enforcing rules and regulations by governments or self-regulatory organizations; limited, or limitations on, the activities of investors in such markets; controls or restrictions on foreign investment, capital controls and limitations on repatriation of invested capital; inability to purchase and sell assets or otherwise settle transactions (i.e., a market freeze); unavailability of currency hedging techniques; substantial, and in some periods extremely high, rates of inflation, which can last many years and have substantial negative effects on markets as well as the economy as a whole; recessions; and difficulties in obtaining and/or enforcing legal judgments. Although it is impossible to predict the precise nature and consequences of these events, the issuer of securities in which clients invest could be significantly impacted by emerging events and uncertainty of this type, and clients will be negatively impacted if the value of their portfolio holdings decreases because of such events and the uncertainty they cause. There can be no assurance that emerging events will not cause a client to suffer a loss of any or all of its investments or interest thereon. Clients will also be negatively affected if the operations and effectiveness of the adviser, its affiliates, the issuer of securities in which clients invest, or their key service providers, are compromised, or if beneficial or critical systems and processes are disrupted. Risk of Loss. All securities investments present a risk of loss of capital. Such investments are subject to investment-specific price fluctuations as well as to macro-economic, market and industry-specific conditions, including, but not limited to, national and international economic conditions, domestic and international financial policies and performance, natural disasters, outbreaks of infectious or other diseases, conditions affecting particular investments such as the financial viability, sales, and product lines of corporate issuers, national and international politics and governmental events, and changes in income tax laws. Moreover, Jordan Park’s ability to vary the client Portfolios in response to changing economic, financial, and investment conditions could be limited. The third-party sub-advisors and managers’ respective investment programs utilize a wide variety of investment techniques, which can, in certain circumstances, increase investment losses. An investor is subject to loss, including possible loss of the entire amount invested. No guarantee or representation is made that investments will be successful, and investment results could vary substantially over time. Market Disruptions, Governmental Intervention and Future Pandemics. The global financial markets have in the past gone through pervasive and fundamental disruptions that have led to extensive and unprecedented governmental intervention. Such intervention has in certain cases been implemented on an “emergency” basis, suddenly and substantially eliminating market 17  participants’ ability to continue to implement certain strategies or manage the risk of their outstanding positions. In addition — as one would expect given the complexities of the financial markets and the limited time frame within which governments have felt compelled to act — these interventions have typically been unclear in scope and application, resulting in confusion and uncertainty, which has been materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. Furthermore, the global outbreak of the novel Coronavirus (or Covid-19) created enormous and unprecedented economic and social uncertainty throughout the world, causing dramatic declines in asset prices over a very short period and significant reductions in market liquidity. The ultimate impact of such outbreaks is impossible to predict, but they could well have an enduring and materially adverse impact on global, national, and local economies. Disruptions to commercial activity due to the imposition of quarantines, remote working policies, “social distancing” practices, travel restrictions and similar measures, and/or local, national, or international failures to contain the outbreak despite these measures, could imperil people and businesses across the world and create long-lasting instability in the financial markets. In addition, the imposition of restrictive measures (including “shelter-in-place” or “lock-down” directives), as well as the physical impact of any illness on key persons could materially disrupt their business operations, and similar disruptions can occur among their service providers and counterparties. Such events can impact the financial markets, investor confidence, and overall economic conditions and could result in major economic or financial losses. Dependence on Principals (Key Person Risk). Investment performance will depend to a significant extent upon the experience of the principals of Jordan Park. The loss of services of one or more of these individuals could have a material adverse effect on such performance because of a reduced capacity to develop and implement investment strategies, obtain investment opportunities, capitalize upon the relationships of such individuals, or structure and execute potential investments for Jordan Park’s clients. Reliance on Jordan Park. Jordan Park will make decisions with respect to the management, disposition, or other realization of any Managed Assets. Clients generally will not have the opportunity to evaluate personally the relevant economic, financial, and other information which will be utilized by Jordan Park in its selection, structuring, monitoring, and disposition of investments of the Managed Assets. In addition, clients will not receive some financial information that will be available to Jordan Park. Consequently, the success of the investment strategies will depend substantially upon the skill and expertise of Jordan Park in selecting investments on behalf of a client or JP Fund. Cybersecurity Risk and Information Security. Jordan Park and its service providers, counterparties, and other market participants on whom Jordan Park relies increasingly depend on the internet as well as complex information technology and communications systems to conduct business functions. These systems are subject to a number of different threats or risks that could adversely affect clients and their Managed Assets. Cyber incidents can result from deliberate attacks or unintentional events, including but not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or 18  sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party service providers may cause disruptions at third-party service providers and impact Jordan Park’s business operations, potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation costs; and/or additional compliance costs. Jordan Park has an established business continuity and disaster recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics. Additionally, Jordan Park employs reasonable security standards and safeguards to protect clients’ personal information and prevent fraud. If you suspect fraudulent activity in accounts managed by Jordan Park, you should immediately contact the Firm at 415-417-3000 or contact your account custodian using the information on the custodial statement. Emerging Technology. From time to time, Jordan Park will use emerging technologies, such as artificial intelligence (“AI”), as a complement to operational and investment research processes. Jordan Park, on behalf of its clients, can also invest in companies developing or leveraging emerging technology. Emerging technology and AI are wide-ranging terms and include a broad spectrum of technologies and applications, such as machine learning, deep learning, neural networks, and natural language processing, that are quickly evolving. Such emerging technology and AI present unique risks. For example, the automation of tasks previously performed by humans can potentially lead to job displacement and economic disruption. Data privacy concerns arise when AI systems collect and analyze vast amounts of personal data, which can be misused or inadequately protected. Additionally, the rapid development of these technologies often outpaces the creation of appropriate regulations, resulting in ethical challenges such as bias in AI algorithms and the potential for misuse in surveillance, investment decisions or other biases. New security vulnerabilities can also emerge as AI tools are developed, making systems potentially more susceptible to cyberattacks when using emerging AI technologies. While Jordan Park continues to evaluate and adjust its own internal policies governing the use of AI by its employees, we expect the use of AI by third party service providers, including Third- Party Managers, to increase. Notwithstanding any such policies, employees of Jordan Park or third-party service providers could utilize AI in a manner that is inconsistent with such policies. Jordan Park and its clients could be further exposed to the risks of AI if third party service providers or any counterparties, whether or not known to Jordan Park, also use AI in their business activities. Jordan Park will not be in a position to control the manner in which third party products are developed or maintained, or the manner in which third party services are provided. Use of AI by any of the parties described in the previous paragraph could include the input of confidential information (including material non-public information) into AI technology applications by third parties in contravention of non-disclosure agreements, resulting in such confidential information becoming part of a dataset that is accessible by other third-party AI applications and users. 19  Cash Deposits and Cash Equivalents (Money Market Funds). Cash deposits held in a client’s custodian account are not guaranteed to have full insurance coverage by the Federal Deposit Insurance Corporation (“FDIC”), the independent government agency responsible for insuring deposits at federally regulated banking entities. FDIC coverage will be dependent on several factors, including but not limited to the available cash deposit options at the client’s custodian and whether or not the cash held in any deposit account at the custodian exceeds the insurance limits set by the FDIC (generally, $250,000 per depositor, per insured bank, per account ownership category). In certain circumstances, cash deposits are included as part of a brokerage firm’s Securities Investor Protection Corporation (“SIPC”) protection that generally applies to accounts up to $500,000, including up to $250,000 of cash. Such brokerage firms may also provide supplemental protection on its accounts beyond SIPC coverage. Cash equivalents are short-term, highly liquid investments, such as money market funds (a type of mutual fund) and are subject to interest rate and issuer-specific changes. Interest rate increases can cause the price of a money market security to decrease. Likewise, a decline in the credit quality of an issuer can cause the price of a money market security to decrease. An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other government agency. Although money market funds seek to preserve the value of your investment at one dollar per share, it is possible to lose money by investing in a money market fund. Equities (Stocks). Equity instruments are subject to equity market risk, which is the risk that common stock prices will fluctuate over short or even extended periods. Equity securities generally have greater price volatility than fixed income securities. Equity securities may decline in value due to factors affecting markets generally, particular industries, sectors or geographic regions represented in those markets, or individual security concerns. Investments in ownership stakes of public or private companies or in mutual funds or ETFs which seek to provide investors with exposure to the equity markets are subject to a risk of significant capital loss due to the unpredictable nature of corporate earnings and their low hierarchical position in the capital structure. Fixed Income (Debt or Bonds). Investments in bonds, credit, and other types of fixed income- like securities are subject to a variety of risks, including credit risk or the risk of default of the issuer, interest rate risk, or the risk of a decline in value due to changes in interest rates, and reinvestment risk or the risk that proceeds from a fixed income security will be reinvested later at lower interest rates. Debt securities are affected by changes in interest rates. When interest rates rise, the value of debt securities are likely to decrease. Conversely, when interest rates fall, the values of debt securities are likely to increase. The values of debt securities may also be affected by changes in the credit rating or financial condition of the issuing entities Inflation Risk. Certain investments are subject to the risk that the purchasing power of an investor’s assets will be reduced over time due to inflation. Foreign and Emerging Markets. To the extent that a Portfolio invests in foreign or emerging market products, such Portfolio will be subject to certain additional risks that are not usually associated with similar investments in industrialized democracies, including fluctuation in currency exchange rates, the imposition of exchange control regulations, the possibility of 20  expropriation decrees, more limited information about issuers and their operations, different accounting standards, and smaller, less liquid markets. Structured Notes. Jordan Park has the discretion to invest client assets in structured notes. Such instruments are generally privately negotiated financial instruments where the interest or value of the structured security is linked to equity securities or equity indices or other instruments or indices (reference instruments). They provide investors with economic exposure closely correlated with a direct holding in an individual stock, basket of stocks, or equity indices in a single security. Issuers of structured notes include corporations and banks. Structured notes differ from debt securities in several aspects. The interest rate or the principal amount payable upon maturity or redemption will increase or decrease, depending upon changes in the value of the reference instrument. If the terms of a structured note provide that, in certain circumstances, no principal is due at maturity, it could result in a loss of invested capital. Receipt of the reference instrument is also, in certain circumstances, exchanged upon maturity of the security. Options and Other Derivative Instruments. Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. Although an option buyer’s risk is limited to the amount of the original investment for the purchase of the option, an investment in an option could be subject to greater fluctuation than an investment in the underlying security. In theory, the writer (seller) of an uncovered call is subject to unlimited losses, but as a practical matter, the amount of potential loss is likely to be limited by reason of the option having only a limited term. The risk for a writer of a put option is that the price of the underlying securities could fall below the exercise price. The ability to trade in or exercise options could be restricted if trading in the underlying securities interest becomes restricted. The market price of options written by a Separate Account, Direct Investment Account or Portfolio Investment will be affected by many factors, including changes in the market price or dividend rates of underlying securities (or in the case of indices, the securities comprising such indices); changes in interest rates or exchange rates; changes in the actual or perceived volatility of the relevant stock market and underlying securities; and the time remaining before an option’s expiration. The market price of an option also could be adversely affected if the market for the option becomes less liquid. The pricing of derivatives (including options) is variable and based on theoretical models, the outputs of which could vary substantially from the prices observed in the market. The market for many types of derivative instruments is comparatively illiquid and inefficient, creating the potential for substantial mispricing, as well as sustained deviations between theoretical and market value. In addition, the derivatives market is, in comparison to other markets, a relatively new market, and the events of 2008 and 2009 demonstrated that even some of the most sophisticated market participants misunderstand how the market in derivatives will perform during periods of unusual price volatility or instability, market illiquidity or credit distress. The primary risks associated with the use of derivatives are (i) model risk, (ii) market risk, and (iii) counterparty risk. Investments in over-the-counter (“OTC”) derivatives are subject to greater risk of counterparty default and less liquidity than exchange-traded derivatives, although exchange-traded derivatives are subject to risk of failure of the clearinghouses through which 21  they are guaranteed. Counterparty risk includes the risk of default, failure to pay mark-to-market amounts, return risk premium, and the risk that the market value of OTC derivatives will fall if the creditworthiness of the counterparties to those derivatives weakens. Substantial financial market disruption and uncertainty in the derivatives markets can cause substantial losses if transactions are prematurely terminated, especially due to default when payment could be delayed or completely lost. Uncertainties in the derivatives markets continue due to proposed regulatory initiatives, moves toward centralized derivatives clearing, and allegations of inappropriate behavior by market participants to cause or avoid payments under contractual obligation. ‑ Long/Short Strategies. Jordan Park may invest client Portfolios in long/short strategies upon a client’s request. Such strategies involve establishing active long and short equity positions in order to take long positions in securities believed to be undervalued, sell short positions in securities believed to be overvalued, manage certain types of risk including but not limited to factor, sector and concentration risks, or pursue any combination of these objectives in a tax aware manner. Unlike traditional long only investing, long/short strategies introduce risks associated with both purchased securities and securities that are sold short, as well as risks related to the use of leverage. The use of long/short strategies can increase the volatility of a client’s portfolio and result in losses that are greater than those that would be incurred through long only investing. ‑ Short selling involves the sale of a security that the portfolio does not own and must borrow. If the price of a security sold short increases, the portfolio will incur a loss, and such loss may be theoretically unlimited because the price of a security sold short may rise without limit. Securities that are borrowed for short selling may be recalled by the lender at any time, requiring the portfolio to purchase the security at prevailing market prices, which may be unfavorable. In addition, certain securities may become “hard to borrow,” meaning they are costly or difficult to source for short selling, and the associated borrowing costs may increase significantly or vary unexpectedly over time. Long/short strategies often entail the use of leverage obtained through margin borrowing or other forms of financing. Leverage magnifies both gains and losses, such that a relatively small movement in the value of an underlying security can produce a disproportionately large impact on portfolio performance. The use of leverage also subjects the portfolio to the risk of margin calls or other demands for additional collateral, which may require liquidating positions at disadvantageous times. Financing availability, interest rates, and stock borrow fees can change abruptly, and increases in such costs may reduce or offset the anticipated economic benefits of a long/short strategy. A higher amount of leverage can increase these risks. In addition to these risks, long/short strategies depend on the continuing availability of liquidity in both long and short markets. Rapid price movements, unexpected shifts in market correlations, and periods of reduced liquidity can adversely affect the adviser’s ability to maintain or adjust exposures. Market dislocations may impair the intended hedging relationships between long and short positions, thereby increasing the strategy’s overall risk. Counterparty arrangements, including those with prime brokers, custodians, and financing 22  providers, introduce additional operational and credit risks that may impact the portfolio’s ability to execute, maintain, or close positions. ESG Investing Risk. Investments that consider ESG factors could underperform the market as a whole or underperform similar strategies that do not consider ESG factors. Specifically, the use of ESG factors could result in selling or avoiding investments that subsequently perform well or making investments that subsequently underperform. There are no uniformly accepted ESG standards, and the analysis and determination of ESG focused investments involve judgment, which is inherently qualitative and subjective. As such, an investment selected by Jordan Park as having ESG focus may not be treated as such by another manager. In addition, there is no guarantee that the information on which Jordan Park bases its ESG evaluation is accurate or complete, and no guarantee that companies, sub-advisors or managers that Jordan Park believes to incorporate ESG factors into their corporate strategies or investment decisions necessarily display favorable ESG characteristics. Impact Risk. Impact-oriented investments may be riskier and/or less profitable than other types of investments due to less proven investment strategies, less developed businesses or technologies, immature or unproven markets, reliance on government subsidies or social goodwill that may change, underlying business managers not seeking to maximize return for shareholders, partial donations of profits to non-owner entities such as charities, changing regulations, obsolescence due to rapidly evolving technology, political and regulatory risk, failure to reach critical mass, acceptance of greater risk or reduced due diligence standards by underlying managers, and many other factors. ETFs. Investing in an ETF exposes an investor to all the risks of that ETF’s investments and subjects it to a pro-rata portion of the ETF’s fees and expenses. As a result, the cost of investing in ETF shares will, under certain circumstances, exceed the costs of investing directly in its underlying investments. ETF shares trade on an exchange at a market price that will sometimes vary from the ETF’s NAV. ETFs will sometimes be purchased at prices that exceed the NAV of their underlying investments and will sometimes be sold at prices below such NAV. Because the market price of ETF shares depends on the demand in the market for them, the market price of an ETF will sometimes be more volatile than the underlying portfolio of securities the ETF is designed to track. Under such circumstances, an investor will not be able to liquidate ETF holdings at the time and price desired, which could negatively impact the investment’s performance. Real Estate Investments. Real estate historically has experienced significant fluctuations and cycles in performance that can result in reductions in the value of real estate investments made by a Portfolio Investment. The performance and value of real estate investments once acquired depends upon many factors beyond a portfolio manager’s control. Revenues and cash flows from real estate investments could be adversely affected by: changes in national or local economic conditions, including unemployment rates and consumer spending/confidence; changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; the supply of available properties to acquire at attractive pricing in a particular market; competition from other investors pursuing the same or similar strategies; competition from other properties offering the same or similar 23  services and amenities, including technology capabilities; rising labor, materials and financing costs; access to transportation, highways and roadways; changes in interest rates and in the state of the debt and equity capital markets; the ongoing need for capital improvements, particularly in older building structures; changes in real estate tax rates and other operating expenses; civil unrest, acts of God, including earthquakes, hurricanes and other natural disasters, acts of war or terrorism, which can decrease the availability of or increase the cost of insurance or result in uninsured losses; changes in governmental rules/regulations and fiscal policies which can result in adverse tax consequences, unforeseen increases in operating expenses generally or increases in the cost of borrowing; the bankruptcy or liquidation of major tenants or a decline in the business operated by tenants; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws; the impact of lawsuits which could cause Portfolio Investment to incur significant legal expenses and divert the portfolio manager’s time and attention away from the day-to-day operations of the Portfolio Investments; and other factors that are beyond a portfolio manager’s control and the control of the property owners. Opportunity Zone Investments. Jordan Park may invest client assets in “qualified opportunity zone funds” (or “QOZFs”) and/or “qualified opportunity zone businesses” (“QOZBs”) that make real estate investments and/or pursue real estate development projects in QOZs. The purpose of the qualified opportunity fund program is to encourage economic growth in QOZs (which are generally located in low-income urban, suburban, or rural areas) by providing U.S. federal income tax benefits to taxpayers who make long-term investments within them. The tax regulations applicable to QOZFs and QOZBs are complex, however, and they impose numerous constraints and restrictions on their structure and operation (including a minimum 10-year holding period). Failure to comply with these regulations could result in the loss of these tax benefits and tax penalties. Investments in low-income urban, suburban, or rural QOZs are also subject to the risk that the anticipated economic growth of these areas may not materialize, which could result in investment losses. Crypto and Digital Assets. Crypto assets, broadly defined and including various types of cryptocurrencies and other of digital tools (collectively, “Digital Assets”), are based on evolving technological innovations. The networks underlying certain Digital Assets, such as bitcoin, typically operate based on an open-source protocol maintained by uncompensated volunteer developers. Consequently, there may be a lack of financial incentives for developers to maintain or develop the network, and the developers may lack the resources to adequately address emerging issues with the relevant Digital Asset protocol. Some Digital Asset networks involve substantial commitments of physical resources, such as space and purpose-built hardware, and involve substantial ongoing commitments in power to run the network that is performing the mining or other similar tasks. There can be no assurance that the core developers of a Digital Asset network will continue to be involved in the network, or that new volunteer developers will emerge to replace them. The rules and regulations governing Digital Assets are evolving. Digital Assets have been subject to uncertain and evolving regulatory status, including a very recent interpretation issued by the SEC and acknowledged by the Commodity Futures Trading Commission (“CFTC”) that 24  provides a new framework for defining Digital Assets and regulatory oversight that has yet to be tested. New laws, regulations or directives by U.S. and non-U.S. jurisdictions may also impact investments in Digital Assets. In addition, such uncertainty may lead to material litigation, including individual and class action lawsuits, as well as investigations and enforcement actions by regulators and governmental authorities that could affect Digital Assets in ways that cannot be predicted. Most Digital Assets are not legal tender, and the value of Digital Assets is based on market demand, perceived utility, adoption and investor sentiment. Digital Assets have experienced and are expected to continue to experience rapid fluctuation in their market prices. Prices are affected by numerous factors, including limited supply, low liquidity of exchanges, concerns about perceived manipulation of the price and the safety of the Digital Assets, market perceptions of the value of Digital Assets as an investment, a shifting regulatory landscape, political and economic uncertainties around the world, and the changes exhibited by an early- stage technological innovation. The digital nature of Digital Assets and certain Digital Asset exchange markets make them attractive targets for theft, hacking, cyber-attacks, and data breaches, and newly developed Digital Asset markets and exchange platforms can and have limited volume, trading, and operational history. Digital Assets may be riskier, less liquid, more volatile and more vulnerable to economic, market, industry, regulatory and other changes than more established financial instruments. There is also no assurance that Digital Assets will gain broad acceptance as a form of payment. As a result, there can be no assurance that investments in Digital Assets, or the companies providing infrastructure for the Digital Asset industry, will be profitable. Turnover. Jordan Park, or by its third-party sub-advisors or managers of the Portfolio Investments, will under certain circumstances invest or trade based on short-term or rapidly evolving market considerations. Such portfolio turnover could involve substantial bid-ask spreads, brokerage commissions, mark-ups, adverse tax impacts, fees, and opportunity costs from misallocated capital. These costs and fees will, of course, reduce profits. Cross and Principal Trades. Jordan Park could determine that a cross or principal transaction is in the best interest of one or more client Portfolios or JP Funds. Jordan Park will generally use an unaffiliated broker-dealer or custodian to execute a cross trade of exchange traded investments between client accounts if it determines that such a transaction is advantageous for each participant. If the investment is not a marketable security with an observable price, Jordan Park will generally determine the value for the proposed trade based on a third-party valuation in accordance with its valuation policies and procedures. Any trade in client or JP Fund accounts that constitutes a principal trade as defined under Section 206(3) of the Advisers Act, would be disclosed to, and require consent from, each participating client or JP Fund before completion of the transaction. Evolving State and Federal Privacy Laws and Regulations. Jordan Park and the JP Funds are directly or indirectly subject to numerous evolving privacy laws and regulations, including the Gramm-Leach-Bliley Act (the “GLBA”), the SEC’s Regulation S-P, and state privacy laws that can 25  apply to Jordan Park and the JP Funds based on their business activities. While many of the state privacy laws include broad exemptions for GLBA-covered entities or data, these state privacy laws present an increasingly complex regulatory framework for financial institutions. There is a risk that compliance practices have some impact on Jordan Park’s or the JP Funds’ marketing or other data activities, that measures taken to comply with new and evolving privacy laws and regulations will not be implemented correctly, or that individuals within the business will not be fully compliant with the new procedures. If there are breaches of these measures, Jordan Park and its affiliates and the JP Funds could face significant administrative and monetary sanctions as well as reputational damage, which could have a material adverse effect on the operations, financial condition, and prospects of Jordan Park and/or the JP Funds. The above considerations also apply to Portfolio Investments, third- party sub-advisors or Third-Party Managers, and counterparties with which they conduct their investment activities. Mutual Funds. The risks with mutual funds include the costs and expenses within the fund that can impact performance, change of managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated with underlying transactions, as well as operating costs such as marketing and distribution expenses and underlying advisory fees. Mutual fund costs and expense vary from fund to fund and will impact a mutual fund’s performance. Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different NAV as determined at the daily market close and have different fees and expenses. Mutual funds that offer different share classes are priced differently and have varying levels of internal costs. For example, institutional share classes often have higher trading costs; however, the internal costs of the fund are lower. Over a period of time, certain share classes will become more expensive if held in an account for a long period of time. Additionally, even though multiple share classes may be available, a custodian may only make available a limited number of share classes, or a custodian may not choose to offer the least expensive share class that is available. Other custodians and investment advisers may offer the same mutual fund or a different mutual fund share class at a lower overall cost to the investor. Regulation of Investment Advisers. Jordan Park operates in a heavily regulated environment. Specifically, as an SEC-registered investment adviser, Jordan Park is subject to the requirements of the Advisers Act and the rules thereunder. Amendments to existing Advisers Act rules and new rules applicable to SEC-registered investment advisers, if adopted and made effective, could have a significant impact on advisers such as Jordan Park. Such impacts include but are not limited to increased compliance burdens and associated regulatory costs and enhanced risk of regulatory actions, which may result in a change to business practices and create additional regulatory uncertainty. No assurance can be given that such regulatory risks will not adversely affect Jordan Park, its clients and/or investors. RISKS ASSOCIATED WITH THE JP FUNDS An investment in the JP Funds involves a significant degree of risk, and no guarantee or representation is or can be made that any such vehicle will achieve its investment objective or 26  that investors will receive a return on their invested capital. The JP Funds are intended to provide investors with the opportunity to invest indirectly in a variety of Portfolio Investments, including underlying securities or other financial instruments, including derivatives; real assets; asset back securities or other structured debt or equity investment products; assets in “qualified opportunity zones”; private investment funds such as venture capital funds, private equity funds, absolute return funds, real asset funds, emerging markets, private credit, and hedge funds; other types of investment vehicles; direct investments; co-investments; and “secondary” investments. Jordan Park clients and other investors are provided offering documents with the relevant disclosures and information concerning a potential investment in a JP Fund and must complete and execute a subscription document before investing in a JP Fund. Clients should refer to each applicable JP Fund’s current offering documents for a more comprehensive description of the risks relevant to the applicable JP Fund. Limited Investment History. Certain JP Funds, and certain Third-Party Managers or Portfolio Investments in which JP Funds invest, are newly formed and have a limited operating history. While Jordan Park has substantial experience advising on the types of opportunities the JP Funds will pursue, there can be no assurance that the JP Funds will generate positive performance results (or avoid losses). Multiple Levels of Fees and Expenses. An investor who meets the conditions imposed by and has access to Portfolio Investments independent of Jordan Park could invest directly in such investments. By investing in Portfolio Investments indirectly through the JP Funds, a client will be charged fees by Portfolio Investments and on the Managed Assets invested in the JP Funds. If the JP Fund charges a management fee, an accounting and operations fee, or Incentive Fee, the client will also bear such fees subject to the terms of the offering documents, which are payable by the JP Fund to Jordan Park. In addition to bearing such fees, a JP Investor bears its share of the transaction-related expenses and other operating costs of both the JP Funds and the Portfolio Investments, all of which can result in higher fees than if invested directly in the Portfolio Investments. Reliance on Underlying Fund Management. The JP Funds typically invest in underlying funds and in some cases through separate accounts managed by underlying managers that will generally be unaffiliated with Jordan Park. Returns could be substantially and adversely affected by the unfavorable performance of one or more underlying funds or separate accounts. Subjective decisions made by the underlying managers may cause the underlying funds or separate accounts to incur losses or to miss profit opportunities on which they would otherwise have capitalized. Furthermore, underlying managers may have a substantial amount of discretion to change their investment approach, potentially without notice to or approval by investors. Neither Jordan Park nor investors will have any right or power to participate in the management or control of such underlying funds or separate accounts, and neither will have an opportunity to evaluate the specific investments made by the underlying managers before they are made. In connection with investments in underlying funds, the JP Funds will be dependent upon underlying managers, which will have custody and control of JP Fund assets invested in such underlying managers’ underlying funds. The failure of an underlying manager or financial 27  intermediary to fulfill its obligations may have a material adverse effect on the related investment and overall performance. If any underlying manager, any other financial intermediary, or any of such underlying manager’s or financial intermediary’s counterparties becomes insolvent or files for bankruptcy, a client or investor could suffer complete or partial losses and increased illiquidity. Selection Process for Third-Party Managers. Certain Portfolio Investments have limited or no performance track record, and certain Third-Party Managers have limited or no assets under management other than their own and the assets of the relevant JP Fund. In such cases, Jordan Park will not be able to provide the same level of due diligence or other analysis as it would in other cases and will therefore not employ the same selection methodology with respect to all Portfolio Investments. Commitment-Based Fees to Jordan Park and Portfolio Managers. With respect to certain JP Funds and Portfolio Investments that accept capital commitments from their investors, it is possible that such JP Funds or Portfolio Investments will never be fully invested if there are not enough sufficiently attractive investments identified and consummated. Investors in certain JP Funds and Portfolio Investments are required to pay Jordan Park or the portfolio managers fund management fees based on the investor’s entire capital commitments during the investment period, regardless of the extent to which such capital commitments are invested. Performance Compensation to Third-Party Managers. Each Portfolio Investment in which the JP Funds invest is expected to calculate its performance compensation based on its individual performance. Moreover, performance compensation payable at a Portfolio Investment level is typically calculated based on the JP Fund’s investment experience in that Portfolio Investment, not the individual investment experience of any JP Fund Investor as an indirect investor, through the JP Fund, in such Portfolio Investment. Consequently, a JP Fund could be subject to paying substantial performance fees to certain Portfolio Investments during periods when the JP Fund is incurring overall losses. Portfolio Manager Risks. The historical performance of Portfolio Investments and their portfolio managers is not indicative of their future performance and can vary considerably from historical experience. A JP Fund will not have an active role in the day-to-day management of the Portfolio Investments’ assets and will not have the opportunity to evaluate the specific investments made by any Portfolio Investment. Accordingly, the returns of the JP Funds will depend primarily on the performance of the Portfolio Investments’ managers and will be substantially adversely affected by the unfavorable performance of those managers. After an investment by a JP Fund, a Portfolio Investment could follow investment policies that differ from those originally anticipated or even conflict with those of the JP Fund. Jordan Park will have only limited power to prevent such occurrences and will be restricted in its ability to dispose of such investments. In addition, although Jordan Park will conduct initial due diligence and periodic monitoring of the Portfolio Investments, it will be difficult for Jordan Park to protect the JP Funds from the risk of fraud or misrepresentation, or material strategy alteration on the part of the Portfolio Investments’ managers. 28  Some of the managers of Portfolio Investments in which the JP Funds invest have only a limited number of principals. If the services of any of such principals became unavailable, the Portfolio Investment’s management, operations, and financial performance could potentially be negatively impacted, which could potentially also negatively impact the performance of the JP Funds. investments made by those Portfolio Managers of Portfolio Investments in which the JP Funds invest might become involved in Investments. Under such litigation because of circumstances, the JP Funds could be named as a defendant in a lawsuit or regulatory action. In trading securities, there are consequences for trading on insider information, and Jordan Park expects that managers of the Portfolio Investments in which the JP Funds invest will use only public information when making an investment or trading decisions. Managers, however, could potentially be investigated or charged with misuse of confidential information, which could, among other things, distract them from pursuing their investment strategies. Furthermore, if a manager of a Portfolio Investment in which a JP Fund invests has engaged in the past or engages in the future in such misuse, the JP Funds could be exposed to losses. The managers of Portfolio Investments in which JP Funds invest have responsibility for investing the funds allocated to them. These managers also manage other accounts (including other accounts in which the managers can have an interest) and can have financial and other incentives to favor such accounts over the JP Funds. In investing on behalf of other clients, as well as the JP Funds, the managers must allocate their resources, as well as limited market opportunities. Seed Investments. Jordan Park can cause one or more of the JP Funds to make “Seed Investments” in certain Portfolio Investments and/or their portfolio managers. Seed Investments in portfolio managers or Portfolio Investments take a variety of forms, including direct early- stage investments in the equity interests of a portfolio manager or a Portfolio Investment in exchange for a certain portion of such portfolio manager’s or Portfolio Investment’s profits, as well as lending to a portfolio manager. Seed Investments could involve portfolio managers or companies with which Jordan Park has a relationship (“Relationship Parties”), which can create conflicts of interest for the Firm. Please refer to Item 6 and Item 10 to understand how the Firm mitigates this conflict. Each Seed Investment is subject to the risks of a "start-up" operation, including inexperienced management, lack of resources, lack of infrastructure, and operational difficulties. Seed Investments could be unsuccessful, causing the investing JP Fund to incur losses on the capital invested in such Seed Investment. Seed Investments typically require the commitment of a large amount of capital for a significant period of time. Consequently, any JP Fund making a Seed Investment will operate on a "buy and hold" rather than an active asset allocation basis. Jordan Park will often have limited oversight in the day-to-day operations of Seed Investments, creating risk that a portfolio manager or a Portfolio Investment could misappropriate or waste assets, fail to follow agreed-upon investment strategies, provide incomplete or incorrect reports on operations, or engage in other forms of misconduct. There are no reliable means for determining the "fair value" of Seed Investments. As a result, Seed Investments will generally be valued based on the lower of the cost or market value of such investment, provided that Jordan Park can also increase the value of a Seed Investment if it has 29  a reasonable basis to do so (such as a bona fide firm arm's-length third party offer to purchase a Seed Investment or valuation provided by an independent external valuation agent). The failure of Jordan Park to properly value a JP Fund’s interests in Seed Investments can lead to an overstated fund management fee or Advisory Fee and subsequent economic dilution of JP Fund Investors. Lack of Portfolio Liquidity. Many Portfolio Investments of the JP Funds have either no trading market or are very thinly traded and, in addition, are often restricted as to their transferability under U.S. federal or state, or non-U.S. securities laws. In addition, many Portfolio Investments have no withdrawal or redemption rights or limited withdrawal or redemption rights that are subject to various restrictions. Transfers of interests or shares in many Portfolio Investments require the approval of their managers as well, which approval can be withheld. In some cases, Portfolio Investments will be prohibited by contract from selling securities of portfolio companies or other assets for a period of time or otherwise be restricted from disposing of such securities or other assets. In other cases, the investments of a Portfolio Investment will require a substantial length of time to liquidate. Consequently, there is a significant risk that a Portfolio Investment or the JP Funds will be unable to realize their investment objective by sale or other disposition of securities or other assets at attractive prices or will otherwise be unable to complete any exit strategy with respect to its portfolio companies. These risks can be further increased by changes in the financial condition or business prospects of the underlying portfolio companies, changes in national or international economic conditions, and changes in laws, regulations, fiscal policies, or political conditions of countries in which underlying portfolio companies are located or in which they conduct their businesses. A relatively slow market for “initial public offerings” will, in some instances, complicate the efforts of Portfolio Investments to dispose of investments pursuant to “IPO exit” strategies and can diminish the value of those investments. The state of the “IPO market” during the period in which a JP Fund and the Portfolio Investments in which it invests dispose of their investments cannot be predicted. Further, it cannot be predicted whether the future state of the “IPO market” will have a material effect on the value of those investments. In addition, a Portfolio Investment can distribute its investments “in-kind” to its investors, including the JP Funds. The JP Funds will generally hold these “in-kind” securities itself until the end of the applicable restriction period and thereafter attempt to liquidate, under certain circumstances, such securities and distribute cash to the JP Fund Investors. However, the JP Funds can choose to make in-kind distributions of these investments, which in certain cases can be composed of illiquid securities. The JP Funds also can make in-kind distributions of the securities or other assets representing direct investments, which in certain cases will be illiquid. There can be no assurance that investors would be able to dispose of these investments or that the value of these investments, as determined by the JP Funds for purposes of the determination of the distributions and the calculation of any performance fee, will ultimately be realized. In the case of an investment in, for example, a “closed end” or “committed capital” pooled vehicle or a direct investment in illiquid underlying assets such as real estate, an investor is 30  generally required to hold its investment in the Portfolio Investment for the entire term of the Portfolio Investment or otherwise until a sale or liquidation, which could be ten years or more. JP Funds that invest in such Portfolio Investments would therefore need to hold their investments in those Portfolio Investments for a significant period with limited ability to transfer or redeem their interest in these Portfolio Investments. Limitations on Opportunities. Access to Portfolio Investments can be limited by the high level of investor demand some Portfolio Investments receive. The business of identifying attractive investment opportunities and the right fund sponsors is difficult and involves a high degree of judgment on the part of Jordan Park. Moreover, the historical performance of a sponsor is not a guarantee or prediction of the future performance of its Portfolio Investment, and there is no certainty that any given Portfolio Investment will permit the JP Funds to invest. The business of investing in buyouts, venture capital opportunities, and other private asset situations, whether by JP Funds in direct investments or by other Portfolio Investments in which the JP Funds invest, is highly competitive. In the case of Portfolio Investments, the JP Funds will rely on the managers of Portfolio Investments to identify attractive investment opportunities. The investment process of any Portfolio Investment also involves a high degree of uncertainty. Even if an attractive investment opportunity is identified, there is no certainty that a Portfolio Investment will be able to invest in such opportunity (or invest in such opportunity in the intended full allocation). Accordingly, there can be no assurance that the JP Funds will be able, directly or indirectly, to identify and complete attractive investments in the future or that it will be able to invest fully its committed capital. Portfolio Investment Operative Documents. A JP Fund will be materially affected by the terms of the operative documents of the Portfolio Investments in which the JP Fund invests. However, Jordan Park will not always be able to negotiate the terms of the JP Fund’s investments in Portfolio Investments depending on the specific circumstances of a JP Fund’s investment in a particular Portfolio Investment. The JP Funds have no liability whatsoever for the terms of the Portfolio Investments, and such terms can be more adverse to a JP Fund as an investor in a Portfolio Investment than the terms on which other investors invest in the Portfolio Investment. Concentration of Investments. While some diversification of investment risk is expected to result from the investment approach of the JP Funds, no assurance can be given that such diversification will occur, or if it does, that it will decrease rather than increase potential risks. Investment portfolios will be concentrated in Portfolio Investments and will not be restricted in any manner from investing in companies in which other Portfolio Investments invest. Consequently, the JP Funds’ investments will potentially be more concentrated in a limited number of portfolio companies than originally expected. Furthermore, each investment opportunity will present specific risks relevant to the industry, structure, management, and environment in which the underlying company competes. These risks cannot be fully assessed at this time and could be significant. The concentration of investments could cause a proportionately greater loss than if a larger number of investments were made. Expedited Transactions. Investment analyses and decisions by Jordan Park or the portfolio manager of a Portfolio Investment, as applicable, will be required to be undertaken on an 31  expedited basis, under certain circumstances, to take advantage of investment opportunities. In such cases, the information available to Jordan Park or such portfolio manager at the time of an investment decision will potentially be limited, and as such, Jordan Park or such portfolio manager will not have access to all relevant information regarding the investment opportunity. Therefore, no assurance can be given that Jordan Park or such portfolio manager will have knowledge of all relevant circumstances that can adversely affect an investment. Liability upon Disposition. In connection with the disposition of an investment in a portfolio company, the JP Funds or its Portfolio Investments will oftentimes be required to make representations and warranties about the business and financial affairs of the portfolio company typical of those made in connection with the sale of any business. The JP Funds or Portfolio Investments will potentially also be required to indemnify the purchasers of such investments to the extent that any such representations and warranties turn out to be inaccurate or misleading. These arrangements will result in liabilities for the JP Funds or Portfolio Investments. Liabilities incurred by the JP Funds in connection with the disposition of investments in Portfolio Investments can cause the JP Funds to recall distributions made to JP Fund Investors. Leverage. Certain JP Funds employ leverage in connection with uncalled capital commitments through credit facilities secured by assets of the JP Funds. The operative documents of the JP Funds generally do not prohibit the JP Funds from employing other forms of leverage, and such leverage can be employed by the JP Funds at Jordan Park’s discretion. The use of leverage has attendant risks and can, in certain circumstances, substantially increase the adverse impact to which a JP Fund’s investments are subject. As leverage increases in a JP Fund, fluctuations in the market value of the JP Fund’s portfolio will have an increasing effect in relation to their capital. Any such credit facility can be secured by the investors’ capital commitments as well as by pledges of the JP Fund’s assets and will potentially require that distributions to the investors be subordinated to payments required in connection with any indebtedness under that credit facility. If a JP Fund defaults on secured indebtedness, the lender can cause the JP Fund to issue a call notice for the purpose of repaying the secured indebtedness and/or the lender can foreclose, and the JP Fund could lose its entire investment in any assets used as collateral for such loan. A credit facility at the JP Fund level can place restrictions on payments to equity holders, including prohibitions on distributions or other payments to equity holders in the event of any default (or continuance thereof) under the credit facility. Furthermore, the costs and expenses of any credit facility will increase the expenses indirectly borne by investors and would diminish net investment returns. Other than specific rights or provisions negotiated for a specific Portfolio Investment, the JP Funds will generally not have control over the investments and activities of the Portfolio Investments, and certain Portfolio Investments do employ leverage, with some employing more extensive leverage than others. Leverage by Portfolio Investments can be expected to increase both potential profits and potential losses. In addition, the JP Funds, directly through direct investments or indirectly through other Portfolio Investments, will potentially acquire securities issued by portfolio companies with leveraged capital structures. These portfolio company investments are subject to increased exposure to adverse economic factors such as a significant rise in interest rates, a severe 32  downturn in the economy, or deterioration in the condition of such portfolio company or its industry. Investments in New Technologies. The JP Funds and certain Portfolio Investments are expected to allocate capital directly or indirectly to companies developing or commercializing new or rapidly evolving technologies. Such businesses often operate in nascent markets with uncertain customer adoption, unproven revenue models, and limited operating histories. Technological innovation cycles can be short, and a portfolio company’s products or platforms may become obsolete or non-competitive faster than anticipated due to breakthroughs by competitors, shifts in industry standards, or changes in customer preferences. Emerging technology businesses frequently require significant, ongoing capital to achieve scalability; if additional financing is unavailable on acceptable terms, a portfolio company’s growth prospects and valuation may be impaired. Intellectual property protection, cybersecurity, and compliance with evolving regulatory frameworks (including but not limited to data privacy, AI, and product- safety rules) present additional execution risks and potential liabilities. Valuations in early-stage technology sectors can be volatile and may not reflect ultimate realizable value, particularly in the absence of mature public markets or predictable exit pathways. Any of these factors could adversely affect a portfolio company’s performance and, consequently, a JP Fund’s returns and the value of an investment in the JP Fund. Non-U.S. Investments. The JP Funds, directly through direct investments or indirectly through other Portfolio Investments, generally invest in a number of different countries. Depending on the country in which a JP Fund or a Portfolio Investment invests, or a portfolio company is located, the JP Fund and Portfolio Investment will potentially be subject to the risk of adverse political developments, including nationalization, confiscation without fair compensation, or war. In addition, in the case of investments in securities that are not denominated in U.S. dollars, any fluctuation in currency exchange rates will affect the value of such investments and the returns ultimately achieved by the JP Fund and the Portfolio Investment. Laws and regulations of other countries will potentially impose restrictions that would not exist in the United States. A non-U.S. investment can require significant government approvals under corporate, securities, exchange control, foreign investment, and other similar laws and can potentially require financing and structuring alternatives that differ significantly from those customarily used in the United States. In addition, some governments, from time to time, impose restrictions intended to prevent capital flight, which can, for example, involve punitive taxation (including high withholding taxes) on certain securities transfers or the imposition of exchange controls, making it difficult or impossible to exchange or repatriate the local currency. In addition, the repatriation of currency and other restrictions will potentially make it impracticable for the JP Funds to distribute the full amount of the JP Fund Investors’ capital accounts in U.S. dollars, and therefore a portion of the distribution can potentially be made in non-U.S. securities or currency. No assurance can be given that political, economic, legal, or regulatory risks will not adversely affect an investment by the JP Funds. 33  Control Positions. Where discretionary authority exists in the offering documents, the Portfolio Investments, as well as the JP Funds through their direct investments, can potentially take control positions in companies. The exercise of control over a company imposes additional risks of liability for environmental damage, product defects, failure to supervise, and other types of related liability. If such liabilities were to occur, JP Funds would likely suffer losses in their investments. Limited or No Liquidity; Restrictions on Transfer. The JP Funds are designed for long-term investors who can commit their funds for an extended period of time. With respect to illiquid JP Funds, withdrawals or redemptions from such JP Funds are not permitted at the discretion of a JP Fund Investor. With respect to JP Funds that offer limited liquidity, while a JP Fund Investor generally is allowed to withdraw or redeem its interest in such JP Funds periodically, such withdrawals or redemptions are subject to various restrictions, including those imposed by the Portfolio Investments held by such JP Funds, such as lockups, “side pockets,” withdrawal “gates” and fees, holdbacks, and suspensions. In addition, JP Fund Investors are not permitted to transfer their interests without both the consent of Jordan Park, which can be withheld in its sole discretion, and satisfaction of certain other conditions, including compliance with applicable securities laws. There is currently no market for investor interests in the JP Funds, and it is not contemplated that one will develop. Thus, JP Fund Investors will potentially not be able to liquidate their investment in part or in full in the event of an emergency or for any other reason, and interests in JP Funds will potentially not be readily accepted as collateral by lenders. Long-Term Investment. An investment in the JP Funds requires a long-term commitment, without any certainty of a return of capital and irrespective of materially adverse changes to Jordan Park, the JP Funds, general economic conditions, and/or such investor’s own financial situation. Even if the investment strategy of a JP Fund proves successful, it is unlikely to produce a realized return to the investor for several years. The JP Funds will make capital calls from investors at any time prior to the completion of the winding up of the JP Funds, subject to certain limitations. Reserves. In managing the JP Funds, Jordan Park will establish reserves for investments, expenses, liabilities, and obligations of the JP Funds and other matters. Estimating the amount necessary for such reserves is difficult. Inadequate or excessive reserves could have a material adverse effect upon the investment returns to the investors. For example, if reserves are inadequate, the JP Funds can potentially decline attractive investment opportunities. On the other hand, if reserves are excessive, JP Funds can potentially hold unnecessary amounts of capital in lower-yielding assets. One JP Fund established for a single portfolio company investment includes reserve amounts when calculating the fees charged to investors. Any such fee arrangement is disclosed to investors in the offering documents. Valuation. For certain Portfolio Investments, such as direct investments in early-stage companies and certain real estate investments, their managers or portfolio managers do not provide Jordan Park with any third-party valuation and, in some cases, for an extended period. In these circumstances, Jordan Park generally will retain an external valuation agent to 34  determine a fair value of such Portfolio Investments’ assets, based on the fundamentals of its investments and/or other factors deemed relevant by such external valuation agent or will retain an auditor charged with periodically reviewing the fairness of the internally underwritten fair value of its investments. In addition, Jordan Park is permitted to establish the fair value of the JP Funds’ investments pursuant to its valuation policy. There can be no assurance that the fair value of such investments will be fully realizable upon their ultimate disposition. Because of the inherent uncertainty of the estimated values of unrealized gains and losses, the fair value can differ significantly from the realized value upon liquidation of such investments, and the differences could be material. The fair value calculations of the JP Funds can potentially be adjusted following the year-end audit as well. Failure to Make Capital Contributions. The organizational documents of those JP Funds that employ a capital commitment mechanism provide for significant adverse consequences in the event an investor defaults on its capital commitment or any other payment obligation. In addition to losing its right to potential distributions from the relevant JP Fund, a defaulting investor can be forced to transfer its interest in the JP Fund for an amount that is less than the fair market value of such interest. These JP Funds will be required to meet capital calls of Portfolio Investments or to fund direct investments over an extended period. Failure by investors to meet the JP Funds’ capital call could result in the failure of the JP Funds to meet capital calls from Portfolio Investments, or the inability of the JP Funds to make direct investments, either of which could have adverse consequences for the JP Funds and the non-defaulting investors. Recourse to the JP Funds’ Assets. The assets of a JP Fund, including any investments held by the JP Fund and, if applicable, the capital commitments of the JP Fund Investors, are available to satisfy all liabilities and other obligations of the JP Fund. If a JP Fund becomes subject to any liability, parties seeking to have the liability satisfied will potentially have recourse to the JP Fund’s assets generally and will potentially not be limited to any particular asset, such as the asset representing the investment giving rise to the liability. Indemnification. Jordan Park and its affiliates are entitled to indemnification, except under certain circumstances, from the JP Funds. This means that Jordan Park and its affiliates can in circumstances where indemnification is available recover losses, including defense fees, damages, and settlement amounts, from the JP Funds in connection with claims brought against Jordan Park and/or its affiliates by others, such as investors of the JP Funds, portfolio companies, and third-party service providers. The payment of such indemnity will not be affected by the termination or the dissolution of a JP Fund. Potential Mandatory Withdrawal. Jordan Park has the discretion to cause a partial or complete withdrawal or redemption or a transfer of an investor’s interest in a JP Fund. Such mandatory withdrawal or redemption or transfer could result in adverse and/or economic consequences for that investor. For example, because of the inherent uncertainty of the estimated values of unrealized gains and losses, the fair value at which such withdrawal or redemption or transfer is 35  effectuated will potentially differ significantly from the realized value upon liquidation of such investments. Risk of Litigation. In the ordinary course of business, a JP Fund and/or the Portfolio Investments in which it invests can be subject to litigation from time to time. The outcome of such proceedings, which can materially adversely affect the value of the JP Fund or such Portfolio Investments, will be impossible to anticipate, and such proceedings can potentially continue without resolution for long periods of time. Any litigation will consume substantial amounts of time and attention, and that time and the devotion of resources to litigation will, at times, be disproportionate to the amounts at stake in the litigation. Limited Investment Company Regulation. Each JP Fund intends to rely on Section 3(c)(7) of the Investment Company Act to avoid the requirement that the JP Fund register as an “investment company” under and comply with the substantive provisions of that act. If a JP Fund were registered as an investment company, the Investment Company Act would require, among other things, that the JP Fund have a board of directors, a majority of whom are “disinterested,” compel certain custodial arrangements and regulate the relationship and transactions between the JP Fund and Jordan Park or its affiliates. JP Fund Investors do not have the benefit of the protections afforded by, nor is a JP Fund subject to the restrictions that arise from, such registration and regulation. Interpretations of Section 3(c)(7) are complex and uncertain in several respects. As a result, there can be no assurance that the JP Funds will remain entitled to rely on this section. If a JP Fund were found not to have been entitled to exclusion from investment company regulation under this section, the JP Fund and Jordan Park could be subject to legal actions by the SEC and others, and the JP Fund could be forced to terminate its business under adverse circumstances. Limited Commodity Futures Trading Commission Regulation. Certain Portfolio Investments in which the JP Funds invest can potentially invest in “commodity interests” (which include, among other things, futures contracts, options on futures contracts, swaps, and non-deliverable currency forwards). As a result of its investment in such Portfolio Investments, absent reliance on an exemption or other relief, a JP Fund will potentially be considered a “commodity pool” under the regulations of the CFTC, and Jordan Park will potentially be considered the “commodity pool operator” (“CPO”) of such commodity pools. However, Jordan Park does not currently operate the JP Funds in accordance with most of the CFTC regulations applicable to CPOs because Jordan Park currently relies on an exemption from registration with the CFTC as a CPO pursuant to the temporary no-action relief granted by the CFTC staff to operators of “funds-of- funds” issued in a November 2012 letter and could also in the future rely on the no-action relief granted to certain investment managers to qualified eligible persons issued in December 2025 (collectively, the “No-Action Relief”), or the exemption provided by CFTC Rule 4.13(a)(3). If the No-Action Relief is no longer available, Jordan Park will determine whether to rely on another exemption, including without limitation the exemption provided by CFTC Rule 4.13(a)(3). As long as Jordan Park is not registered as a CPO, unlike a registered CPO operating a commodity pool, Jordan Park will not be required by the Commodity Exchange Act of 1936, as amended, or the regulations of the CFTC to deliver a disclosure document or a certified annual 36  report to the investors in the JP Funds. However, Jordan Park delivers certain periodic and annual reports to all investors. Concentration of Ownership. Concentrated ownership of interests in the JP Funds by a few large investors can negatively impact the investments the JP Funds may make due to tax, legal, regulatory or other considerations (e.g., considerations to avoid the application of “excess business holdings” rules or similar rules under the IRC). Concentrated ownership may also harm smaller investors in other ways. For example, defaults or withdrawals by large investors could materially adversely impact a JP Fund and smaller investors. Additionally, concentrated ownership could incentivize the Firm to favor larger investors over smaller ones. Tax Considerations. The JP Funds’ tax reporting to investors is dependent upon reporting by Portfolio Investments. Investors should consult with their tax advisors to ensure the requisite extensions are obtained as necessary due to the timing associated with reporting of tax information by the JP Funds. The tax consequences of investments in the JP Funds are highly complex, including the potential for unrelated business taxable income and excess business holdings that could impact certain investors, and all investors are urged to consult with their own tax advisors. ITEM 9. DISCIPLINARY INFORMATION Jordan Park and its employees have not been involved in any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm, its business, or the integrity of its management. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Important information about Jordan Park’s other financial industry activities and affiliations is provided below. These affiliations create conflicts of interest and, in many cases, incentivize Jordan Park to recommend an affiliate’s services versus other, similar, non-affiliated providers. Additionally, some of Jordan Park’s employees serve in multiple capacities that may, at times, conflict. Related Pooled Investment Vehicles. As described in Item 4 and Item 6, Jordan Park sponsors and manages the JP Funds, and in cases where it serves as the general partner or manager of the JP Fund, it receives both an Advisory Fee and in many cases, a fund management fee, an Incentive Fee, and/or a fund accounting and operations fee. Jordan Park and its employees also have financial interests in some of the JP Funds and certain of the Portfolio Investments. In addition, certain entities under common control with Jordan Park serve as the general partner of the JP Funds and receive fund management fees, Incentive Fees and/or fund accounting and operations fees. Because the JP Funds have limited or no liquidity, an investment in a JP Fund will be subject to the applicable liquidity restrictions, if any, that can result in delays in payment of a client’s or investor’s request for withdrawal or redemption proceeds from the applicable JP Fund(s) (see “Limited or No Liquidity; Restrictions on Transfer” under Item 8). Once an investor is no longer 37  a client of Jordan Park, its investment in a JP Fund will cease to be subject to the Advisory Fee and instead will become subject to a fund management fee in accordance with the JP Fund’s governing documents (which is wholly or partially waived for Jordan Park clients paying an Advisory Fee and higher than the Advisory Fee). Fund management fees, Advisory Fees, and other fees and expenses described in Item 5 are payable to Jordan Park without regard to the overall success of, or income earned by, the JP Funds. This creates a conflict of interest for Jordan Park between its responsibility to manage the JP Funds for the benefit of investors and its interest in maximizing the profits it will receive from an Incentive Fee, if earned, or the payment of a fund management fee, if the client terminates its advisory relationship with Jordan Park. Investments in or with Relationship Parties and Associated Conflicts. In managing client Portfolios, Jordan Park seeks to leverage the experience and resources of the entrepreneurs, business leaders, investors, philanthropists, innovators, and other persons within its network (together with their affiliates and related persons, “Relationship Parties”) to source investment opportunities for our client’s Portfolios, including investments made on behalf of a JP Fund. Relationship Parties also include entities in which Jordan Park has invested its own capital. Such investments could include an investment in a vehicle or product sponsored, managed, or advised by Relationship Parties, or an investment in a company affiliated with a Relationship Party. Relationship Parties include existing or prospective Jordan Park clients, as well as other persons that provide services to, or that have existing or prospective business, personal, political, financial, or other relationships with, Jordan Park, its employees or principals, and Jordan Park clients (including the JP Funds). Investments involving Relationship Parties can create conflicts of interests due to potential direct or indirect benefits to Jordan Park, including an increase in the value of any Jordan Park investment in a Relationship Party or in an investment sourced by a Relationship Party, and the potential to gain additional clients or increase an existing client’s assets under management because of an investment involving a Relationship Party. To manage these conflicts, Jordan Park has developed policies and procedures to identify and either mitigate or eliminate such conflicts, which include, as appropriate, obtaining consent from clients or investors prior to making an investment in a Relationship Party or providing specific disclosures at the time of such investment. The identification and management of conflicts, and the Firm’s adherence with the related policies and procedures, are overseen by the Conflicts Committee. As a result, Jordan Park’s relationships with the Relationship Parties (and Jordan Park’s interest in furthering and promoting those relationships for its own business goals or those of its affiliates) could influence Jordan Park’s decision-making as it identifies, structures, and negotiates the terms of particular investments, resulting in terms that despite Jordan Park’s efforts to treat all clients fairly might be different than terms agreed by two parties operating at “arms’ length” (and thus could be less favorable to clients). Similarly, after making an investment in a Relationship Party or in any investment vehicle or product sponsored, managed, or advised by a Relationship Party, Jordan Park has incentives to avoid disposing of the investment or pursuing remedies against the Relationship Party out of concern that doing so can damage its relationship with a Relationship Party, which could adversely affect clients. 38  To mitigate these conflicts, and those discussed in the following section, Jordan Park seeks to identify, structure, negotiate and manage each client’s Portfolio, including when selecting underlying investments for the JP Funds, with due regard to the investment fundamentals and the interests and investment objectives of the client or JP Fund, and without preference for its own interests. In addition, Jordan Park has implemented an investment process culminating in a committee approval process for Portfolio Investments. See Item 8 for more details. Jordan Park Trust Company. Jordan Park is under common ownership with a private trust company. JPTC is chartered in the State of New Hampshire as a non-depository trust company that specializes in serving families of substantial means who want highly customized trust and wealth advisory services. Jordan Park introduces its clients to JPTC and will typically refer a client only to JPTC if it provides the types of services requested or needed by the client; however, clients are free to work with any trust services provider they choose. Jordan Park Holding Company LLC (“JPHC”), which owns Jordan Park and its affiliates, receives the benefit of fees paid by any such clients who choose to work with JPTC to the extent JPTC is profitable and makes a distribution of such profits. Similarly, JPTC engages Jordan Park for investment advisory services for such clients and for certain special purpose vehicles managed by JPTC and will continue to retain Jordan Park over other investment advisers. As a result, a conflict of interest exists whenever we recommend JPTC to an investment advisory client, and conversely, when JPTC recommends Jordan Park for investment advisory services. JPTC’s fees are in addition to any Advisory Fees paid to Jordan Park under the Client Agreement between Jordan Park and JPTC. In addition, under a services agreement, JPTC agrees to pay Jordan Park for a variety of services that Jordan Park provides to JPTC. JP Portsmouth Capital. Jordan Park is under common ownership with a limited purpose broker-dealer. JPPC is a broker-dealer registered with the SEC and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). JPPC offers limited brokerage and consulting services to clients pursuant to the terms of an engagement agreement with each client, primarily in connection with private placements of securities or privately negotiated transactions involving unregistered or registered securities. JPPC also refers execution to other broker-dealers for certain transactions involving registered, unrestricted securities. These services will be offered to clients on a non-discretionary basis. Jordan Park introduces some of its clients to JPPC and will typically refer a client only to JPPC and not another unaffiliated broker-dealer if JPPC provides the type of services requested or needed by the client; however, clients are not obligated to select JPPC for its brokerage services in order for Jordan Park to continue providing its investment advisory services to the client. JPHC, which owns Jordan Park and its affiliates, receives the benefit of fees paid by any such clients who choose to work with JPPC to the extent JPPC is profitable and makes a distribution of such profits. As a result, a conflict of interest exists whenever we recommend JPPC to an investment advisory client as JPPC’s fees are in addition to and separate from any Advisory Fees paid to Jordan Park under the Client Agreement. In addition, under a services agreement, JPPC has agreed to pay Jordan Park for a variety of services that Jordan Park provides to JPPC. Other Business Relationships. In certain cases, Jordan Park employees can serve individually as trustees, general partners, managers, or other similar authorized persons for entities 39  beneficially owned or controlled by Jordan Park clients. These individuals will ordinarily take direction from the client in selecting the investment advisor but will generally recommend that they consider the services of Jordan Park. In addition, Jordan Park provides investment advisory services to certain affiliated persons with respect to their own personal assets. Certain JP Funds and JPHC currently own interests in third-party entities that provide certain services to Jordan Park and/or its clients, and the conflict is mitigated, in part, by the fact that use of such third-party entities as service providers for clients was made prior to and independent of the investment by the JP Funds or JPHC in such entities, and further mitigated by Jordan Park’s policies and procedures governing the selection and monitoring of third-party service providers. Nevertheless, Jordan Park has an incentive to refer clients to these service providers, or to engage these service providers to provide services to Jordan Park, to potentially enhance the return on the JP Funds’ or JPHC’s investments in these service providers. Other Investment Advisers. As discussed in detail under Item 4 and Item 5 above, the Firm selects sub-advisors on behalf of clients to manage portions of their Managed Assets pursuant to the terms and conditions of an agreement with the relevant sub-advisor. Jordan Park will from time to time enter into consultancy or joint venture agreements with third- party investment advisers. At the same time, Jordan Park invests, on a discretionary basis, client assets in separately managed accounts or in funds managed by such third-party investment advisers. As a result, allocating assets to such third-party investment advisers can indirectly benefit Jordan Park and certain of its clients, and thus creates a conflict of interest. To mitigate the conflict of interest, Jordan Park will typically re-allocate all the fees earned through the consultancy or joint venture agreement to clients who invested in accounts or funds managed by the third-party investment adviser via an Advisory Fee reduction or will provide disclosure to clients regarding the fee arrangement with the third-party investment adviser. In all cases, Jordan Park will undertake its normal process of initial and ongoing investment and operational due diligence of such third-party investment advisers in accordance with Jordan Park’s policies and procedures. See Item 6 and Item 8 for further information about how Jordan Park addresses the conflicts of interest discussed above. ITEM 11. CODE OF ETHICS Jordan Park has a fiduciary duty to its clients. All investment activities of the Firm and members, officers, and employees of Jordan Park (collectively “Firm Personnel”) are subject to this fiduciary duty of care to the Firm’s clients. Jordan Park has adopted a Code of Ethics (the “Code”), pursuant to Rule 204A-1 under the Advisers Act, that sets forth the ethical standards of business conduct that we require of all our Firm Personnel, including compliance with all applicable federal and state securities laws and the fiduciary duties we owe to our clients. Jordan Park also maintains a list of securities that employees are restricted from trading in their own or related accounts. All Firm Personnel are required to conduct themselves with integrity and to follow the principles and policies outlined 40  in our Code. A copy of our Code is available to any client, prospective client, or investor on request by contacting us using the information on the cover page of this Brochure. Our Code and related policies address specific conflicts of interest that either we have identified or that we believe could likely arise. All Firm Personnel are provided with a copy of the Code and must, upon hire and annually thereafter, certify that they have received it and have complied with its provisions. In addition, any Firm Personnel who becomes aware of any potential violation of the Code is obligated to report the potential violation to our Chief Compliance Officer. Employee Personal Trading. Our Code also imposes certain trading restrictions and reporting obligations on Firm Personnel related to personal securities transactions. As necessary to place client interests ahead of Firm Personnel interests, Firm Personnel are generally not permitted to transact in a security while the Firm is actively trading that security on a discretionary basis across client accounts or JP Funds, with the exception of securities with substantial market capitalization. Firm Personnel are permitted, however, to buy or sell securities for their own accounts at different times than Jordan Park buys or sells such securities for its clients, which can potentially result in Firm Personnel achieving superior returns. Participation or Interest in Clients’ Transactions. Individual securities, including private fund interests, will from time to time be bought, held, or sold by Firm Personnel that are also recommended to or bought, sold, or held for a client. In certain cases, Jordan Park permits Firm Personnel, in accordance with its policies and procedures, to buy, sell, and hold the same securities or investments that we also recommend to or transact in for clients. As described in Item 5, certain Firm Personnel have invested and could in the future invest in the JP Funds. Firm Personnel who invest in JP Funds do not pay the fund management fee, Advisory Fee, Incentive Fee, or fund accounting and operations fee. Firm Personnel also do not pay an Advisory Fee if Jordan Park manages assets on behalf of an employee. Conflicts of interest will also arise from time to time in allocating time, services, or other resources among our Firm’s clients, including the investment activities of the JP Funds. The Firm mitigates conflicts of interest in the ways described in Item 6 and Item 10. Jordan Park and Firm Personnel have investment considerations that will differ from those of Jordan Park’s clients. Similarly, not all clients will have the same investment considerations. As a result, in the exercise of its fiduciary duties and consideration of its or Firm Personnel’s circumstances and those of its clients (and provided that Jordan Park and Firm Personnel abide by their fiduciary duty to place client interests ahead of their own interests), Jordan Park can take action on behalf of any of its clients that differs from actions it takes on behalf of other clients or actions it takes on its behalf, or that differs from actions that its personnel take on their own behalf. For example, Jordan Park and/or its personnel or a client could buy or sell specific securities that are not deemed appropriate for other clients, including JP Funds, at the time. Material Non-Public Information/Confidentiality. Our policies strictly prohibit engaging in insider trading. As a result, if Firm Personnel come into possession of material non-public information, Jordan Park could be limited in its ability to act with respect to a security or investment held on behalf of clients, even though such action would otherwise be in the best 41  interest of a client. Additionally, the Code also requires that any information relating to clients is kept confidential, to the extent permitted by law. Business Entertainment. Employees may be occasionally provided with reasonable and de minimis meals and entertainment from other financial service providers or third parties, including potential or existing sub-advisors and managers with whom Jordan Park has invested, or may invest, client Portfolios. This may present a conflict of interest in that we have an incentive to maintain a relationship with such providers or third parties. However, all such business entertainment will be conducted in accordance with our Code of Ethics and Gifts and Entertainment policies, and we will act in our clients’ best interests when engaging in any business with such third parties. ITEM 12. BROKERAGE PRACTICES Recommendation of Custodian(s) and Best Execution. All clients must place their assets with a qualified custodian. Clients are required to engage the custodian to retain their funds and securities and direct Jordan Park to utilize that custodian for the client’s security transactions. Jordan Park does not have discretionary authority to select the custodian for custody and execution services. The client will engage a custodian to custody client assets and execute trades, and the client will authorize Jordan Park to direct trades to the custodian as agreed upon in the Client Agreement. Although Jordan Park does not exercise discretion over the selection of the custodian, Jordan Park recommends one or more custodian(s) to clients for custody and execution services. Clients are not obligated to use the recommended custodian; however, the services Jordan Park it is able to provide can be limited if the recommended custodian is not engaged by the client. Jordan Park recommends the custodian based on criteria such as, but not limited to, reasonableness of commissions and fees charged to the client and services made available to the client. Jordan Park will generally recommend that clients establish their account(s) at Fidelity Family Office Services, a division of Fidelity Clearing and Custody Services, a part of Fidelity Brokerage Services LLC (together with all affiliates "Fidelity"), and Charles Schwab & Co., Inc. (“Schwab”), each a FINRA-registered broker-dealer and member of SIPC (collectively the “Custodians”). Jordan Park has discretionary authority over the placement of clients’ brokerage trades executed in Direct Investment Accounts, or placement of trades on behalf of the JP Funds. In such discretionary trading, Jordan Park will typically direct trades to the custodian of the client’s Managed Assets or the custodian of a JP Fund’s security positions. Jordan Park is obligated to seek best execution for all trades, but in seeking best execution the determinative factor is not the lowest possible cost or solicitation of competitive bids, but whether the transaction represents the best qualitative execution, taking into consideration the full range of services. The current custodial relationships provide our clients with trading, custodial, and other related services, and we seek to negotiate preferred terms for our clients, thereby providing them with the benefits associated with economies of scale and Jordan Park’s knowledge of the custody market. Other benefits include the custodians’ facilities, reliability, reputation, experience, financial responsibility in particular markets, and familiarity both with investment practices generally and techniques employed by Jordan Park. Jordan Park reviews the accuracy, 42  timeliness and execution of trades processed through the designated custodians but does not guarantee that a client will receive the most favorable execution of trades, which in turn could result in a higher cost to the client than if the trade was executed at another custodian or broker- dealer. Research and Other Soft Dollar Benefits. The Firm does not have any formal soft dollar arrangements; however, in the normal course of business, it receives research customarily made available by broker-dealers to their clients. Jordan Park believes that it would obtain such research regardless of the amount of commission it generates throughout the year, and any receipt of such research will be in accordance with the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934, as amended. Certain brokers and custodians utilized by us provide general assistance to us, including, but not limited to, technical support, consulting services, waivers of fees, and consulting services related to staffing needs. They also extend the same fee schedule negotiated for Jordan Park clients to services provided to Jordan Park employees. In selecting a broker, we consider the scope of general assistance, waivers of fees, and consulting services provided. To the extent we would otherwise be obligated to pay for such assistance, the Firm would have a conflict of interest in considering those services when selecting a broker. However, our selection is supported by the scope, quality, and price of services to our clients and not the services that benefit us. Brokerage Services in Exchange for Client Referrals. Jordan Park’s selection or recommendation of a broker-dealer does not consider whether that broker-dealer has referred clients to the Firm. Client-Directed Brokerage. Jordan Park will accommodate a client request to direct trading activity to a specific broker or custodian. If a client directs us to use a specific broker not recommended by us, the client will be responsible for negotiating the terms and conditions of the broker’s services (including, but not limited to, commission rates). In these circumstances, Jordan Park does not have any responsibility to obtain the best prices or a particular commission rate with or through any such broker, and the commission or other fees can be higher than if the client follows the Firm’s recommendation for brokerage services. Aggregating and Allocating Trades. Jordan Park can (but is not required to) combine orders on behalf of one client account with orders for other client accounts for which it or its principals have trading authority, or in which it or its principals have an economic interest. The Firm will generally allocate the securities or proceeds arising out of those transactions (and the related transaction expenses) on an average price basis among the various participants. We believe combining orders in this way will, over time, be fair to all participants. However, the average price could be less advantageous to a client than if that client had been the only account involved in the transaction or had completed its transaction before the other participants. Jordan Park will place orders for the same security for different clients at different times and in different relative amounts due to differences in investment objectives, cash availability, size of order, the client’s custodian, and practicability of participating in “block” transactions. The level of participation by different clients in the same security will also be dependent upon other factors relating to the suitability of the security for a particular client. 43  Where execution opportunities for a particular security are limited, we attempt in good faith to allocate such opportunities among clients in a manner that, over time, is equitable to all clients. Jordan Park monitors, but is not responsible for, the execution of transactions by the third-party sub-advisors or manager of the Portfolio Investments. Administrative Trade Errors. From time to time, Jordan Park may make an error in the execution of a trading instruction for a client’s Portfolio. Trading errors may include but are not limited to: • The wrong security is bought or sold for a client; • A security is bought instead of sold (or vice versa); • A transaction is executed for the wrong account; • Securities transactions are completed for a client that had a restriction on such security; or • Securities transactions are allocated to the wrong accounts. Upon discovering a trade error, the Firm will seek to correct the error promptly in a way that mitigates losses or any ongoing impact on the client. The actions taken to correct the error will depend on the facts and circumstances of the error but would generally involve cancelling the erroneous trade from the client’s account and placing a correcting trade or entry with the account custodian. Jordan Park will generally bear the cost of an error, and gains associated with an error will be retained by the affected client, including in some cases allowing trades to remain in client accounts if they result in a net benefit to the client, unless it is not permissible due to legal or other reasons, or the client decides to forego the gain (e.g., due to tax reasons). If an error results in a reimbursement to a client for any loss relating to the error (e.g., where a trade correction is not possible or feasible), the Firm will arrange to reimburse the impacted client through an adjustment of the fees paid to Jordan Park either directly at the time of the error or through a waiver or reduction of future fees payable by the client as agreed to with the client. In some cases, Jordan Park may send the reimbursement amount directly to the client in the form of a wire transfer, check or through a journal of funds deposited into the client’s account at the custodian. The amount of reimbursement will generally impact the form of repayment. Jordan Park will determine in good faith whether losses arising from an error are borne by the client, Jordan Park, or a third party, such as a custodian, sub-advisor or vendor, by applying the standard of liability and standard of care set forth in the Client Agreement or as set forth in any other applicable documents. ITEM 13. REVIEW OF ACCOUNTS Jordan Park regularly reviews the Portfolios, at least on an annual basis, and provides clients with either detailed reports on a quarterly basis or ongoing access to portfolio details through an online portal within the Firm’s reporting system. Reviews generally include assessing performance, liquidity, and suitability of investments. Reviews will also be conducted and tailored when and as requested by a client. The frequency and extent of the reviews vary by client and are driven generally by client circumstances, changes to a client’s financial situation, and assets and investments currently held or proposed to be held. Other factors that could 44  trigger a review include extraordinary events, changes in the tax law, or major investment developments. Client accounts are also reviewed regularly by the Investment Team to assess the appropriateness of asset allocation, risk management, risk-adjusted return expectations, liquidity, and to determine whether changes should be implemented across client accounts. Members of the Client Advisory Team, with support from the Investment Team, are responsible for the regular monitoring and review of client accounts. A client’s custodian provides quarterly reports to the client showing the assets held in each client account at the custodian, the market value, and each account’s performance for the quarter. Reports will generally be provided in electronic format, when agreed upon by the client. Certain assets, such as interests in JP Funds, will not be held in these custodial accounts. Consequently, the reports provided by the custodians will not cover the assets in the JP Funds. Investors in the JP Funds will receive separate reporting from the fund administrator. In addition, Jordan Park provides consolidated performance reporting for the client’s Managed Assets, and in some cases, develops customized reporting to include other assets not managed by Jordan Park. Clients are urged to compare the account statements received directly from the custodians to the reports provided by Jordan Park. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION Jordan Park will from time to time enter into arrangements with certain unaffiliated SEC- investment advisers (each, a “Third-Party Adviser”) under which we pay compensation in exchange for client referrals. Such compensation creates a conflict of interest because the referring adviser has a financial incentive to recommend our services. These arrangements are structured to comply with Rule 206(4)-1 under the Advisers Act (the “Marketing Rule”), including the endorsement provisions requiring appropriate disclosures, a written agreement, and oversight of the referral activity. Clients will receive the required disclosures regarding the nature of the compensation and related conflicts of interest at the time of the referral. The Firm also provides as a reference to prospective clients certain individuals (who may also be clients) who have a non-controlling indirect economic interest in a Jordan Park affiliate. Such individuals have minimal involvement in the management of Jordan Park but are expected to consult with the Firm upon reasonable request and receive a small share of the revenues of the affiliate each year. Although they receive this share regardless of whether any prospective clients decide to do business with Jordan Park, in order to mitigate the conflict of interest that exists when they speak to prospective clients, Jordan Park monitors who is acting as a reference for prospective clients and sends all prospective clients this brochure prior to or in connection with the Client Agreement in accordance with SEC and any other applicable rules. ITEM 15. CUSTODY Jordan Park is deemed to have custody of client assets in connection with its investment advisory services to clients because of our authority to deduct, or instruct the custodian to deduct, Advisory Fees directly from clients’ accounts. We also are deemed to have custody in other circumstances, such as arrangements authorizing Jordan Park to withdraw assets from a 45  client’s custodian account, that require the Firm to undergo an annual surprise examination (as described below). The clients’ qualified custodian will provide quarterly statements to each client showing the assets held in the account at the custodian, the market value, and including the amount of fees paid to Jordan Park directly. Reports will generally be provided in electronic format, when agreed upon by the client. Interests in the JP Funds that undergo annual financial statement audits will not be reflected in custodian statements, nor will the underlying assets held within the JP Funds. However, investors in such JP Funds will receive annual financial statements as described below. Jordan Park sends periodic reports to clients as well or provides portfolio details through an online portal within the Firm’s reporting system. Clients are urged to carefully review and compare the statements sent by the custodians with those sent or provided by us. Should there be any discrepancies, clients are advised to rely on the information in their custodians’ account statements. In accordance with the SEC’s custody rule and related guidance and no-action letters, accounts over which Jordan Park is deemed to have custody are subject to an annual surprise examination, except for the JP Funds that undergo annual financial statement audits performed by an independent public accountant and for which the annual financial statements are delivered to investors as required under current regulations. ITEM 16. INVESTMENT DISCRETION Each Client Agreement generally authorizes Jordan Park to invest and trade the client’s Managed Assets in a broad range of investments, to be selected at the Firm’s sole discretion. Specific limitations applicable to a client’s Portfolio, such as limitations on the type of investments, security or sector restrictions, or desired amount of leverage in the portfolio, are specified in the client’s investment guidelines. Each client authorizes Jordan Park to execute certain documents necessary to facilitate the client’s investments. Clients provide prior written consent by signing a subscription document before Jordan Park will include any JP Fund in the client’s Portfolio. Jordan Park also exercises discretionary investment authority over the investments made by the JP Funds. In making investments, Jordan Park exercises its discretion in a manner consistent with the goals and investment objectives of a client or JP Fund. litigation, bankruptcy Jordan Park clients periodically receive notices of class action proceedings and settlements involving a security held in their accounts. These notices provide clients with the opportunity, as shareholders, to participate in the proposed litigation or settlement of claims. Jordan Park is not authorized to respond to notices on behalf of its clients. However, if authorized by a client’s account opening documentation with the relevant custodian, Financial Recovery Technologies (“FRT”), a class action service provider engaged by Jordan Park, will file proof of claims in class actions and other matters with administrative processes for all potentially eligible client accounts. The matters will only involve compensation to the organizers of the recovery efforts on a ‘no win, no fee’ basis. As compensation for their 46  services, FRT retains 20% of any gross recovery amount distributed to a client, other than gross amounts of less than or equal to $25 which will be 100% retained by FRT. ITEM 17. VOTING CLIENT SECURITIES Unless otherwise retained by a client, Jordan Park exercises voting authority over proxies for Direct Investment Accounts managed by Jordan Park and has adopted proxy voting policies and procedures in accordance with current regulation. These policies are reasonably designed so that Jordan Park can vote proxies received in a manner consistent with the best interests of the client. With respect to securities held in Separate Accounts, Jordan Park generally delegates the voting authority to the applicable third-party sub-advisors, who will vote or abstain from voting proxies according to their own proxy voting policies and procedures. Jordan Park’s proxy voting policies require us to vote client proxies in a prudent and diligent manner intended to enhance the economic value of the assets of the clients. However, the policies also permit us to abstain from voting proxies if, in Jordan Park’s judgment, the client’s economic interest in the matter being voted upon is limited relative to the client’s overall portfolio or the impact of the client’s vote will not influence its outcome or the client’s economic interests. Once Jordan Park has agreed to vote proxies on behalf of a client account, it will instruct the client’s custodian to forward all proxy materials to Institutional Shareholder Services (“ISS”), a proxy voting service provider engaged by Jordan Park to administer proxy voting. Although Jordan Park expects to vote proxies according to ISS’s recommendations, certain votes may need to be considered on a case-by-case basis due to the diverse and continually evolving nature of corporate governance issues. If such cases should arise, then Jordan Park will devote appropriate time and resources to consider those issues. Where a proxy proposal raises a material conflict between Jordan Park’s interests and the interests of the clients, we will seek to resolve the conflict in the best interest of the clients, whether by following ISS’s recommendations, abstaining from voting, or otherwise, to ensure that proxy voting decisions are made in accordance with our policies and procedures. In certain markets, proxy voting involves logistical issues which can affect Jordan Park’s ability to vote such proxies, as well as the desirability of voting such proxies. These issues include but are not limited to untimely notice of shareholder meetings, restrictions on a foreigner’s ability to exercise votes, “share blocking” requirements that impose restrictions on the disposal of shares for a period of time, among other issues. Such issues can result in Jordan Park’s inability to vote proxies despite our intention or willingness to do so. If a client wishes to inquire about, or direct the vote for, a proxy solicitation directed to Jordan Park, ISS or a sub-advisor as described above, clients may contact their Client Advisory Team. Where the client retains the authority to vote proxies and Jordan Park or a third-party sub- advisor does not vote on their behalf, clients will receive proxy materials directly from the applicable custodian(s) or issuer’s proxy agent and should direct any questions as instructed in the specific proxy matter. 47  Clients can obtain a copy of the Firm’s complete proxy voting policies and procedures upon request by contacting us using the information on the cover page of this Brochure. Clients can also obtain information from us about how we voted any proxies on behalf of their account(s). ITEM 18. FINANCIAL INFORMATION Jordan Park has no financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. In addition, we are not currently, nor at any time in the past ten years have we been, the subject of a bankruptcy petition. 48