Terms of Use

1. Eligibility and Qualified Eligible Person Standard

Access to the Portal is limited to persons whom the CPO reasonably believes are Qualified Eligible Persons ("QEPs") within the meaning of Commodity Futures Trading Commission Regulation 4.7(a)(2). By accessing the Portal you represent and warrant that:

1. You qualify as a QEP under at least one of the categories enumerated in CFTC Rule 4.7;
2. The information you provided in the attestation process is true, accurate, and complete;
3. You are accessing the Portal solely to evaluate a potential investment in one or more of the Phoenix Agentics funds and not for any other purpose;
4. You are not a resident of any jurisdiction in which the receipt of the information made available on the Portal would be unlawful; and
5. You are at least eighteen (18) years of age and have the legal capacity to agree to these Terms.

If at any time you cease to qualify as a QEP, or any representation you made becomes inaccurate, you must promptly cease using the Portal and notify the CPO at investors@phoenixagentics.com.

2. Account, Credentials, and Authorized Use

Access to non-public areas of the Portal requires authentication using credentials provided to you by the CPO.

• Credentials are personal to you. You may not share them with any other person, including a member of your household, an employee, a colleague, an advisor, or a related entity, except as expressly permitted in writing by the CPO.
• You are responsible for all activity that occurs under your credentials. You must notify the CPO immediately at investors@phoenixagentics.com of any suspected unauthorized access.
• Authorized representatives of an entity QEP may be provided with separate credentials. Each individual representative is bound by these Terms in their own capacity.
• The CPO may suspend or revoke credentials at any time, including without notice where suspension is necessary to address suspected misuse, regulatory inquiry, or risk to the Portal or its other users.

3. Confidentiality and Non-Disclosure

All information accessible through the Portal — including performance data, fund structure information, methodology descriptions, narrative commentary, reconciliation detail, exposure metrics, and benchmark analyses (collectively, "Confidential Information") — is proprietary and confidential to Phoenix Agentics. You agree that:

• Confidential Information is provided to you on a strictly confidential basis for your use in evaluating a potential investment in the Funds and for no other purpose.
• You will not reproduce, redistribute, forward, publish, post, transmit, or otherwise disclose any Confidential Information to any third party, including without limitation through email, messaging, file-sharing, screen-sharing, screenshots, photographs, recordings, or any other medium, without the prior written consent of the CPO.
• You will not use Confidential Information to derive, train, or improve any model, dataset, index, or analytical product, whether for internal use or for distribution.
• You will limit access to Confidential Information within your organization to those of your directors, officers, employees, professional advisors, and authorized service providers who (i) have a need to know in connection with your evaluation of an investment, (ii) are informed of and agree to be bound by confidentiality obligations no less restrictive than these Terms, and (iii) for whose breaches you are responsible.
• You will protect Confidential Information using the same degree of care you use to protect your own confidential information of a similar nature, and in no event less than reasonable care.
• If you are required by subpoena, court order, regulator, or other legal process to disclose Confidential Information, you will, to the extent permitted by law, provide the CPO with prompt prior notice so that the CPO may seek a protective order or other remedy.

These confidentiality obligations survive termination of your access to the Portal for so long as the information remains non-public and continue to bind you and your representatives following any termination of these Terms.

4. No Offer; Governing Documents

Nothing displayed on or made available through the Portal constitutes:

• an offer to sell or a solicitation of an offer to buy any interest in any fund;
• investment, tax, accounting, legal, or other advice;
• a recommendation to enter into or refrain from any transaction; or
• a guarantee of any future return, allocation, or fund availability.

Any actual offering of interests in any Phoenix Agentics fund is made only pursuant to the applicable Confidential Private Placement Memorandum, subscription documents, limited partnership agreement (or equivalent constitutive documents for the Cayman Feeder), side letters where applicable, and other definitive offering and constitutive documents (collectively, the "Governing Documents"). In the event of any inconsistency between the Portal and the Governing Documents, the Governing Documents control.

5. Nature of the Information Shown

Performance information on the Portal is presented from two independent sources:

• Opus Fund Services — the Fund's independent administrator — produces official month-end NAV statements. The reportable basis for subscriptions, redemptions, and the Fund's annual audit.
• Marex Capital Markets — the Fund's Futures Commission Merchant — produces daily end-of-day statements. The Portal derives pro-forma, unaudited, management-level estimates from these statements between official month-end closes. Daily figures capture master-fund futures trading P&L only, exclude the bank/cash sleeve, and are subject to monthly reconciliation against Opus.

Risk-adjusted statistics (Sharpe, Sortino, alpha), drawdown measures, regression-based metrics, and per-regime breakdowns are particularly sensitive to sample length and are marked "pending" where the available history does not yet meet the documented observation threshold. Figures shown are accurate descriptions of what has happened to date; they are not estimates of future distributions.

The Portal may contain typographical errors, calculation errors, or omissions. The CPO does not warrant the accuracy, completeness, or timeliness of any figure displayed and reserves the right to correct any error without notice.

6. Prohibited Conduct

You will not, and will not permit any other person to:

1. access the Portal using any automated means, including scrapers, crawlers, headless browsers, or robotic process automation, except as expressly authorized by the CPO in writing;
2. reverse-engineer, decompile, disassemble, or attempt to derive the source code of any software or system component of the Portal;
3. circumvent or attempt to circumvent any authentication, rate-limiting, audit-logging, or security mechanism;
4. interfere with, disrupt, or impair the integrity or performance of the Portal;
5. access the Portal from a jurisdiction in which doing so is unlawful;
6. use the Portal in connection with the development of any product or service competitive with the Funds;
7. upload, transmit, or distribute any virus, worm, Trojan horse, ransomware, or other malicious code;
8. use the Portal in violation of any applicable law, regulation, or rule of any self-regulatory organization, including without limitation the rules of the National Futures Association and the regulations of the CFTC; or
9. use the Portal to harass, threaten, defame, or harm any person.

7. Intellectual Property

The Portal — including its layout, typography, code, structure, methodology descriptions, narrative content, calculation logic, the Phoenix Agentics name and logo, and any reports, charts, and analyses displayed — is the exclusive property of Phoenix Agentics Capital Management LLC and its affiliates, or is licensed to them, and is protected by U.S. and international copyright, trademark, and other intellectual-property laws.

Subject to your continued compliance with these Terms, the CPO grants you a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to access and view the Portal for the sole purpose of evaluating a potential investment in the Funds. No other right is granted by implication, estoppel, or otherwise.

Nothing on the Portal grants any license or right to use any trademark, service mark, trade name, or logo of Phoenix Agentics or any third party without the prior written consent of the owner.

8. Monitoring, Audit, and Suspension

You acknowledge and agree that:

• The Portal logs user activity — including attestations, logins, page views, uploads, and data clearings — to satisfy NFA Compliance Rule 2-10 and CFTC Regulation 1.31 recordkeeping obligations.
• The CPO may review audit-log records at any time and may share such records with regulators, auditors, and law enforcement as described in the Privacy Policy.
• The CPO may suspend, restrict, or terminate your access to the Portal at any time, with or without notice, including for breach of these Terms, suspected misuse, regulatory request, or operational necessity.
• Termination of access does not relieve you of any obligation you incurred under these Terms before termination, including the confidentiality obligations in Section 3.

9. Third-Party Services and Links

The Portal may incorporate or link to third-party services (for example, content delivery networks for typography and JavaScript libraries) and may link to third-party documents (for example, the CFTC eCFR text of Rule 4.7). The CPO does not control these third-party services or sites and is not responsible for their content, availability, terms, or privacy practices. Your use of any third-party service is at your own risk and is subject to that third party's terms.

10. Privacy

Your use of the Portal is also governed by the Portal Privacy Policy, which is incorporated by reference into these Terms.

11. Disclaimer of Warranties

12. Limitation of Liability

Nothing in this Section limits or excludes any liability that cannot be limited or excluded under applicable law, including any liability of an investment adviser or commodity pool operator for fraud or willful misconduct under federal or state securities and commodities laws — your rights under those laws are not waived.

13. Indemnification

To the maximum extent permitted by applicable law, you agree to indemnify, defend, and hold harmless the Phoenix Parties from and against any and all claims, demands, actions, losses, liabilities, damages, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to:

1. your access to or use of the Portal;
2. your breach of any representation, warranty, or covenant in these Terms — in particular, the confidentiality obligations in Section 3;
3. your violation of any applicable law or third-party right; or
4. any unauthorized use of your credentials, except to the extent attributable to the CPO's gross negligence or willful misconduct.

The CPO reserves the right, at its expense, to assume the exclusive defense and control of any matter for which you are required to indemnify the Phoenix Parties, and you will cooperate with the CPO's defense of any such matter.

14. Governing Law and Dispute Resolution

These Terms and any dispute arising out of or relating to these Terms, the Portal, or your use of either will be governed by the laws of the State of Delaware, without regard to its conflict-of-laws principles, and by applicable U.S. federal law.

Subject to the next paragraph, you and the CPO consent to the exclusive jurisdiction of the state and federal courts located in New Castle County, Delaware for any action arising out of or relating to these Terms or the Portal. Each party waives any objection based on inconvenient forum or improper venue.

Notwithstanding the foregoing, the CPO may seek injunctive or other equitable relief in any court of competent jurisdiction to enforce its rights or protect its Confidential Information.

Jury Trial Waiver. To the maximum extent permitted by applicable law, each party irrevocably waives any right to a trial by jury in any action arising out of or relating to these Terms or the Portal.

Nothing in this Section limits your right to pursue any remedy available under federal or state securities or commodities laws that cannot be waived by contract.

15. Jurisdictions Outside the United States

The Phoenix Agentics funds are offered to U.S. Qualified Eligible Persons and, in respect of the Cayman Feeder, to non-U.S. investors in jurisdictions where the offering complies with local law. The CPO does not solicit investors in the European Union, the United Kingdom, or any other jurisdiction in which solicitation would constitute a regulated cross-border activity.

If you accessed the Portal at your own initiative without any solicitation by the CPO (a "reverse solicitation"), you represent that doing so is lawful under the law of your jurisdiction and that you are solely responsible for compliance with any local requirements applicable to your evaluation of an investment. The CPO makes no representation that the materials on the Portal are appropriate for use in any jurisdiction other than the United States.

16. Changes to These Terms

The CPO may amend these Terms from time to time. Material changes will be indicated by an updated Effective Date and Version number at the top of this page. Where a change is material, authenticated users may be required to re-acknowledge the Terms before continuing to use the Portal. Your continued use of the Portal following the Effective Date of a change constitutes acceptance of the changes.

17. Miscellaneous

• Entire Agreement. These Terms, together with the Privacy Policy and any attestations or acknowledgments you provided, constitute the entire agreement between you and the CPO regarding the Portal, and supersede any prior agreement on the same subject matter. In the case of any inconsistency between these Terms and the Governing Documents, the Governing Documents control.
• Severability. If any provision of these Terms is held invalid or unenforceable, that provision will be enforced to the maximum extent permitted and the remaining provisions will continue in full force.
• No Waiver. The CPO's failure to enforce any right or provision of these Terms is not a waiver of that right or provision.
• Assignment. You may not assign or transfer these Terms or your rights under them. The CPO may assign these Terms in connection with a corporate transaction, restructuring, or successor service provider.
• Notices. Notices to you may be delivered by email to the address associated with your credentials or by posting on the Portal. Notices to the CPO must be sent to investors@phoenixagentics.com.
• Force Majeure. The CPO is not liable for any failure or delay in performance to the extent caused by circumstances beyond its reasonable control, including without limitation acts of God, government action, war or terrorism, civil unrest, labor disturbance, internet or telecommunications failure, denial-of-service attack, or pandemic.
• Headings. Section headings are for convenience only and do not affect interpretation.
• Survival. Sections 3 (Confidentiality), 7 (Intellectual Property), 11 (Disclaimer), 12 (Limitation of Liability), 13 (Indemnification), 14 (Governing Law), and 17 (Miscellaneous) survive any termination of these Terms.

18. Contact

Questions about these Terms should be directed to:

Phoenix Agentics Capital Management LLC
Attn: Investor Relations
investors@phoenixagentics.com