Cybersecurity Risk Management Processes for Assessing, Identifying, and Managing Threats [Text Block]

Cybersecurity Risk Management and Strategy

As an externally managed company, the Company does not maintain a standalone cybersecurity organization. The Company’s cybersecurity risk management is conducted through, and governed by, the policies, procedures, and controls of I Squared and its affiliates, which provide investment management, operational, technology, compliance, and administrative services to the Company. The Company relies on I Squared to assess, identify, and manage material cybersecurity risks relevant to the Company’s operations, information assets, and reliance on third-party service providers.

Because the Company depends on I Squared’s technology infrastructure and personnel, a significant cybersecurity incident affecting I Squared’s systems could disrupt the Company’s operations, including investor communications, financial reporting, access to portfolio or investor data, or other administrative functions performed on the Company’s behalf.

I Squared maintains firmwide policies addressing information handling, data privacy, and information security that are integrated into its broader risk management and compliance framework. Oversight of firmwide risks, including technology and cybersecurity risks, is conducted through I Squared’s risk governance structure, including its Risk Committee and senior management. These policies are designed to support compliance with applicable regulatory requirements, including those under the Advisers Act and other applicable laws, and are informed by recognized industry standards and best practices.

As part of I Squared’s risk management and compliance program, its cybersecurity risk management activities include:

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Governance and Senior Management Oversight. Responsibility for information security and cybersecurity risk management resides with I Squared’s senior management and designated compliance, risk, and technology personnel. I Squared’s Risk Committee oversees firmwide risks, including cybersecurity and technology-related risks. Cybersecurity matters are escalated through established reporting channels to senior management and, as appropriate, communicated to senior management of the Company. In connection with any identified cybersecurity incident, senior management of I Squared, in consultation with legal and compliance personnel, evaluates the nature and scope of the incident, including whether it is material and whether disclosure or other regulatory obligations are triggered. The Director of Technology at I Squared has more than twenty years of experience in information technology. For over a decade, he has led the I Squared’s technology and cybersecurity functions, overseeing strategy, infrastructure, and security initiatives.

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Cross-Functional Risk Management. I Squared employs a coordinated, cross-functional approach to cybersecurity risk management involving personnel from technology, compliance, legal, operations, finance, and risk management. This approach is designed to facilitate the identification, assessment, mitigation, and escalation of cybersecurity risks and incidents, including those that could affect the confidentiality of client information, portfolio data, or other sensitive information relating to the Company.

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Information Security Controls. I Squared maintains administrative, technical, and physical safeguards designed to protect information systems and confidential information from unauthorized access, misuse, disruption, or loss. These safeguards include access controls, multi-factor authentication, system monitoring, endpoint protection, and other security measures. I Squared periodically reviews and enhances these controls in light of evolving threats, regulatory expectations, and business needs.

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Incident Response and Testing. I Squared maintains policies and procedures addressing the identification, escalation, and response to cybersecurity incidents and information security events. These procedures are designed to promote timely internal reporting, investigation, remediation, and escalation to senior management and affected stakeholders, including senior management of the Company, as appropriate. I Squared periodically reviews and tests aspects of its incident response and cybersecurity controls as part of its risk management processes. Cybersecurity incident response procedures are coordinated with I Squared’s broader business continuity and disaster recovery planning to support operational resilience and continuity of critical functions.

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Third-Party Risk Management. I Squared applies a risk-based approach to the oversight of third-party service providers that may have access to I Squared systems or I Squared-related information, or that perform functions critical to I Squared’s and the Company’s operations. This approach includes due diligence, contractual protections, and ongoing monitoring, as appropriate, based on the nature of the services provided and associated risk profile.

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Training and Awareness. I Squared provides periodic cybersecurity, privacy, and information security training to its personnel, including programs designed to promote awareness of phishing and other cyber threats and reinforce compliance with I Squared’s policies and procedures.

I Squared periodically reviews and assesses the effectiveness of its information security and cybersecurity controls through internal reviews and, where appropriate, third-party assessments, audits, or testing activities. Findings from these reviews are addressed through I Squared’s established risk man agement and compliance processes, and policies and controls are updated as necessary to respond to identified risks and evolving threat conditions. To the Company’s knowledge, cybersecurity risks and incidents have not materially affected, and are not reasonably likely to materially affect, the Company’s business strategy, results of operations, or financial condition. Nevertheless, the Company remains exposed to cybersecurity risks, including risks associated with reliance on I Squared’s systems, third-party service providers, and the increasing sophistication of cyber-related threats.

Cybersecurity Governance

The Company’s Board is responsible for overseeing the Company’s risk management, including risks related to cybersecurity. In fulfilling this responsibility the Board receives periodic updates regarding cybersecurity risks relevant to the Company, including developments in the threat environment, information security practices, and the status of any significant incidents, and may receive additional updates as warranted by specific events or risk developments.

I Squared’s governance framework supports cybersecurity oversight through its Risk Committee, senior management, and compliance and risk management functions. Designated technology leadership is responsible for implementing and maintaining I Squared’s information security program, in coordination with compliance and risk personnel. Cybersecurity risks are monitored as part of I Squared’s overall compliance and supervisory program applicable to its advisory activities, including those performed on behalf of the Company.

Potentially significant cybersecurity incidents are escalated internally in accordance with I Squared’s policies and, as appropriate, communicated to Company management to support timely evaluation and response. The Company’s Board expects to receive periodic updates regarding cybersecurity risks relevant to the Company, including developments in the threat environment, information security practices, and any material incidents, should they occur.

Cybersecurity Risk Management Processes Integrated [Text Block]

The Company relies on I Squared to assess, identify, and manage material cybersecurity risks relevant to the Company’s operations, information assets, and reliance on third-party service providers.

Cybersecurity Risk Materially Affected or Reasonably Likely to Materially Affect Registrant [Flag]

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Cybersecurity Risk Board of Directors Oversight [Text Block]

Governance and Senior Management Oversight. Responsibility for information security and cybersecurity risk management resides with I Squared’s senior management and designated compliance, risk, and technology personnel. I Squared’s Risk Committee oversees firmwide risks, including cybersecurity and technology-related risks. Cybersecurity matters are escalated through established reporting channels to senior management and, as appropriate, communicated to senior management of the Company. In connection with any identified cybersecurity incident, senior management of I Squared, in consultation with legal and compliance personnel, evaluates the nature and scope of the incident, including whether it is material and whether disclosure or other regulatory obligations are triggered. The Director of Technology at I Squared has more than twenty years of experience in information technology. For over a decade, he has led the I Squared’s technology and cybersecurity functions, overseeing strategy, infrastructure, and security initiatives.

Cybersecurity Risk Role of Management [Text Block]

Cross-Functional Risk Management. I Squared employs a coordinated, cross-functional approach to cybersecurity risk management involving personnel from technology, compliance, legal, operations, finance, and risk management. This approach is designed to facilitate the identification, assessment, mitigation, and escalation of cybersecurity risks and incidents, including those that could affect the confidentiality of client information, portfolio data, or other sensitive information relating to the Company.

Cybersecurity Risk Management Positions or Committees Responsible [Text Block]

I Squared’s governance framework supports cybersecurity oversight through its Risk Committee, senior management, and compliance and risk management functions. Designated technology leadership is responsible for implementing and maintaining I Squared’s information security program, in coordination with compliance and risk personnel. Cybersecurity risks are monitored as part of I Squared’s overall compliance and supervisory program applicable to its advisory activities, including those performed on behalf of the Company.