Legal & Regulatory Disclosures

Official regulatory notices, institutional compliance standards, performance calculation methodologies, and private fund investor qualifications.

Master Governance Policy

This master regulatory statement governs all informational materials, research publications, performance records, multimedia content, and correspondence published by Lemelson Capital Management, LLC.

1. Notice & General Views Expressed

This material is presented for informational and educational purposes only and expresses the views, analyses, and opinions of Lemelson Capital Management, LLC (the “Advisor,” “Investment Manager,” or “General Partner”) as of the date indicated. Such views, analyses, and opinions are subject to change at any time without notice. The Advisor undertakes no duty or obligation to update, revise, or maintain any information, research, or commentary contained herein. This material contains views and opinions which, by their nature, are subject to uncertainty and involve inherent risks. Certain information concerning economic trends, industry data, and financial markets is derived from independent third-party sources. While the Advisor believes such sources to be reliable, it has not independently verified the accuracy or completeness of such data and assumes no responsibility for third-party errors or omissions.

2. No Offer, Solicitation, or Investment Advice

This material is not intended to constitute legal, tax, accounting, or investment advice. Prospective investors should consult their own professional advisors about such matters. This material does not constitute an offer to sell or the solicitation of an offer to purchase any interest in any private investment fund or other vehicle managed or sponsored by the Advisor (including, without limitation, The Amvona Fund, LP, The Spruce Peak Fund, LP, or any affiliated fund).

Any such offer or solicitation may only be made to qualified prospective investors by means of delivery of the fund’s definitive Confidential Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement (collectively, the “Offering Documents”), which describe the significant risks, terms, and fee arrangements associated with an investment. Prospective investors must review the Offering Documents in their entirety and consult their own legal, tax, and financial advisors prior to making any investment decision.

3. Private Fund Exemptions & Qualified Investor Standards

Interests in the funds have not been registered under the Securities Act of 1933, as amended, the securities laws of any state, or the laws of any non-U.S. jurisdiction, and the funds are not registered as investment companies under the Investment Company Act of 1940, as amended. The securities and partnerships described herein have not been recommended, approved, or disapproved by the U.S. Securities and Exchange Commission (SEC), FINRA, or any other federal, state, or foreign regulatory authority.

Interests in the Advisor’s private investment partnerships are offered exclusively in private transactions exempt from registration pursuant to Section 4(a)(2) of the Securities Act and Regulation D thereunder, and are available solely to qualified investors who meet the definition of “Accredited Investors” under Rule 501 of Regulation D, “Qualified Clients” under Rule 205-3 of the Investment Advisers Act of 1940, and/or “Qualified Purchasers” under Section 2(a)(51) of the Investment Company Act. Investments in private investment funds are speculative, illiquid, subject to substantial restrictions on transfer and redemption, and involve a high degree of risk, including the potential loss of the entire principal amount invested.

4. Performance Data & Calculation Methodology

Past performance is no guarantee of future results. All investments involve substantial risk, and the value of investments and the income derived from them can fluctuate significantly.

Any performance data included with respect to any fund or client account represents net performance after the deduction of all vehicle-level expenses (including brokerage commissions, management fees, performance allocations/carried interest, audit, legal, and administrative operating costs) and reflects the reinvestment of dividends, interest, and capital gains.

Any performance presented does not represent the return of any individual investor. An individual investor’s net return in any collective investment vehicle may differ significantly from any net performance as stated herein due to differences in fee arrangements, high-water marks, hurdle rates, and the timing of capital contributions and withdrawals. In fact, any net returns of a vehicle shown herein may be significantly higher than an investor’s actual return. Returns are estimated and unaudited unless specifically indicated as audited figures, and actual returns may vary from the performance information presented. Actual performance figures are only computed and audited yearly. Future returns are not guaranteed, and a loss of principal may occur.

5. Benchmark & Index Comparisons

Comparisons to market indices (such as the S&P 500 Total Return Index, the Barclay Hedge Fund Index, or the Dow Jones/Credit Suisse Hedge Fund Index) are provided for informational and context purposes only. Indices are unmanaged, reflect the reinvestment of dividends, and do not reflect the deduction of advisory fees, brokerage commissions, or vehicle operating expenses, which reduce returns.

The investment programs and strategies of the Advisor’s funds do not mirror any index, and the holdings, sector concentrations, leverage, and volatility of the funds may differ materially from the indices. In addition, the funds invest in a different mix of securities and sectors than the indices, which may cause differences in performance. You cannot invest directly in an index.

6. Specific Securities, Activist Research & Trading Conflicts

Any specific securities, issuers, or special situations identified, analyzed, or discussed in this material do not represent all of the securities purchased, sold, or recommended for any account, and should not be construed as a recommendation to buy, sell, or hold any security. The audience should not assume that investments in the securities identified and discussed have been or will continue to be profitable. Investment examples and activist case studies are included merely to illustrate the research processes and investment strategies that may be utilized by the Advisor. Client accounts currently own numerous other securities in various other industries and sectors unrelated to these securities. The purchase of these securities only will not create a diversified portfolio.

The Advisor, its affiliated funds, partners, and personnel hold, have held, or may in the future establish long or short positions, options, debt, or other derivative contracts in the securities discussed, and stand to benefit financially from movements in the market price of such securities that align with stated theses. The Advisor explicitly reserves the right to buy, sell, cover, hedge, increase, or liquidate any position in any security mentioned at any time, before or after publication, without notice to anyone.

7. Third-Party Ratings, Rankings & Accolades

References to third-party rankings, ratings, or awards (including, without limitation, rankings by Barron’s, Morningstar, Preqin, and HFR) reflect historical industry recognitions based exclusively on criteria and historical data evaluated by the respective independent rating organizations.

Such rankings reflect historical performance over specific past evaluation periods and do not represent client endorsements, customer satisfaction, or a guarantee of future fund performance. The Advisor did not pay any direct or indirect compensation to be included in, or to receive, any third-party ranking, rating, or award.

8. Forward-Looking Statements & Risk Management

Statements contained herein that are not historical facts—including statements containing words such as “anticipate,” “believe,” “continue,” “estimate,” “expect,” “forecast,” “intend,” “may,” “plan,” “project,” “target,” “will,” or the negative thereof—constitute forward-looking statements. Such statements are subject to known and unknown risks, economic uncertainties, operational hazards, competitive market developments, and other factors that could cause actual market outcomes, operational results, or returns to differ materially from those expressed or implied.

Any portfolio risk management processes discussed herein are an effort to monitor and manage risk, but should not be interpreted as and do not imply low risk or the ability to control risk. Risk policies and limits imposed by the Advisor are subject to change without notice and may be exceeded from time to time due to market fluctuations.

9. Jurisdictional & Cross-Border Restrictions

This website and its contents are directed solely at persons in jurisdictions where the distribution of this information is lawful. This information is not directed to, or intended for distribution to or use by, any person or entity in any jurisdiction or country where such distribution, publication, availability, or use would be contrary to local law or regulation, or which would subject the Advisor or its funds to any registration or licensing requirement within such jurisdiction.

Inquiries & Confidential Communications

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