Disclosures - Belle Haven Investments

Firm Compliance & Investment Disclosures

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is a dually registered investment adviser and broker-dealer specializing in the trading and management of separately managed taxable and tax-exempt fixed income investment strategies. The Firm manages taxable and tax-exempt portfolios which invest in U.S. municipal, corporate, government, and Treasury securities. The Firm serves as a subadvisor to an investment company registered under the Investment Company Act of 1940, and acts as a portfolio manager for one or more wrap fee programs sponsored by third-party financial institutions.

Belle Haven is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The Firm is also a member of the Financial Industry Regulatory Authority (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”), through its affiliated broker-dealer activities. Additional information about Belle Haven Investments is available on the SEC’s website at www.adviserinfo.sec.gov.

CLIENT RELATIONSHIP SUMMARY (FORM CRS)

Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at www.investor.gov/CRS which also provides educational materials about broker-dealers, investment advisors and investing. For additional information about Belle Haven, the Firm’s Form ADV 2A can be found at https://adviserinfo.sec.gov/firm/summary/29278.

Belle Haven Investments, L.P. Form CRS Relationship Summary - March 2026

Belle Haven Investments, L.P. Disclosure Brochure - May 2026

FORM ADV PART 2A

This brochure provides information about the qualifications and business practices of Belle Haven Investments, L.P. (“Belle Haven”). If you have any questions about the contents of this brochure, please contact us at (914) 816-4633 or by email at compliance@bellehaven.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.

Belle Haven is a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Registration of an investment adviser does not imply a certain level of skill or training. Additional information about Belle Haven is also available on the SEC’s website at www.adviserinfo.sec.gov.

Belle Haven Investments, L.P. - Form ADV Part 2A - March 2026

PRIVACY NOTICE

Belle Haven is committed to protecting the confidentiality and security of the nonpublic personal information entrusted to us. This Privacy Notice describes the categories of information we collect, how such information is used and shared, and the safeguards we maintain to protect such information in accordance with applicable laws and regulations.

Belle Haven does not sell nonpublic personal information. The Firm discloses such information solely as described in this Privacy Notice, in order to service client relationships, fulfill legal and regulatory obligations, and maintain the quality and integrity of its investment advisory services.

If you have any questions regarding this Privacy Notice or would like additional information, please contact Belle Haven at (914) 816-4633 or compliance@bellehaven.com.

Belle Haven Investments, L.P. - Privacy Notice March 2026

ERISA 408(b)(2) DISCLOSURE STATEMENT

Belle Haven provides disclosures intended to satisfy the requirements of Section 408(b)(2) of the Employee Retirement Income Security Act of 1974 ("ERISA") for covered plan fiduciaries. These disclosures should be reviewed in conjunction with Belle Haven’s Form ADV Part 2A and, if applicable, the Investment Management Agreement. This disclosure is intended solely for Plan Administrators.

Belle Haven Investments L.P. ERISA 408(B)(2) Disclosure Statement March 2026

BUSINESS CONTINUITY PLAN

Belle Haven maintains a Business Continuity Plan ("BCP") designed to respond to significant business disruptions, including natural disasters, pandemics, or other emergencies. The Firm’s principal office is located at 800 Westchester Avenue, Suite N607, Rye Brook, NY 10573, and the main telephone number is (914) 816-4633. In the event the Firm cannot be reached at this number, clients may contact (914) 816-4622 or Belle Haven’s clearing firm, BNY Pershing, LLC, at (201) 413-3333 or by visiting pershing.com. Clients may also contact their account custodian directly for access to funds or securities.

Belle Haven Investments, L.P. - Business Continuity Plan Disclosure Statement

Belle Haven Investments, L.P. - Business Continuity Plan - Pandemic Mitigation and Airborne Infectious Disease Exposure Prevention Plan Statement

INVESTOR EDUCATION AND REGULATORY RESOURCES

SECURITIES INVESTOR PROTECTION CORPORATION (“SIPC”) INFORMATION
Information regarding SIPC, including a SIPC brochure, may be obtained by contacting SIPC via its website at www.sipc.org or by telephone at (202) 371-8300.

FINANCIAL INDUSTRY REGULATORY AUTHORITY (“FINRA”) INVESTOR EDUCATION AND PROTECTION
A brochure that includes information describing FINRA BrokerCheck and Public Disclosure Program may be obtained from FINRA at www.finra.org. The FINRA BrokerCheck hotline number is (800) 289-9999 or by accessing https://brokercheck.finra.org/.

MUNICIPAL SECURITIES RULEMAKING BOARD (“MSRB”) RULE G-10 INVESTOR AND MUNICIPAL ADVISORY CLIENT EDUCATION AND PROTECTION
An investor brochure that describes the protections available under MSRB rules, and instructions on how to file a complaint with an appropriate regulatory authority can be found on the MSRB website at www.msrb.org.

GENERAL INVESTMENT RISKS

Investing in securities involves risk of loss, and clients should be prepared to bear such risks. The risks associated with fixed income investments will vary based on the investment strategy employed and the specific securities held within an account. There can be no assurance that any investment objective will be achieved or that a positive return will be realized.

The significance and impact of investment risks will differ depending on factors including portfolio composition, market and economic conditions, and changes in interest rates, credit environments, and liquidity. Clients should carefully consider these risks in light of their individual investment objectives and financial circumstances.

Fixed income and municipal bond investments are subject to a variety of risks, including, but not limited to: interest rate risk, credit and default risk, call risk, liquidity risk, reinvestment risk, inflation risk, and general market risk, as well as risks associated with sector or geographic concentration. Changes in economic conditions, issuer financial health, tax laws, or market structure may adversely affect the value and performance of these investments.

Municipal securities may not be appropriate for all investors or account types. Income generated may be subject to federal, state, or local taxes, including the alternative minimum tax, and investors may also be subject to capital gains taxes. Tax-aware strategies, including tax loss harvesting, may not be suitable for all investors and may result in increased transaction activity and associated costs.

Additional information regarding the risks associated with Belle Haven’s investment strategies is available in the Firm’s Form ADV Part 2A, which should be reviewed carefully.

Materials prepared or distributed by Belle Haven are provided for informational purposes only and should not be considered a substitute for official account records. Custodial account statements and trade confirmations are the authoritative records of account activity, holdings, and valuations. Clients are encouraged to review and compare all information received from Belle Haven with statements provided by their custodian.

Belle Haven does not provide tax or legal advice. Each client’s tax and financial circumstances are unique, and investment decisions should be made based on the client’s individual objectives and circumstances, in consultation with their professional tax, financial, and/or legal advisers.

INVESTMENT DEFINITIONS

Alpha represents the risk-adjusted excess return of an investment relative to its benchmark index.

Average Coupon is the measure of the average income (interest payments) generated by a bond's face or par value.

Average Maturity is the measure of the average length of time until the bonds in the portfolio mature or the principal is repaid.

Average Rating refers to the market-weighted average of portfolio securities rated by Moody's and Standard & Poor's. Securities not rated by either agency are excluded from the calculation.

Beta is a measure of an investment’s volatility relative to the broader market.

R2 measures the proportion of an investment’s price movements attributed to movements in its benchmark index.

Sharpe Ratio evaluates an investment's return relative to its risk.

Up Capture Ratio measures the percentage of market gains an investment experiences in a rising market.

Down Capture Ratio measures the percentage of market losses an investment experiences in a declining market.

Standard Deviation measures how much an investment's returns vary from its average return.

Duration measures the sensitivity of an investment’s price to changes in interest rates.

Yield-to-Maturity (YTM) measures the total expected return on a bond if held to maturity.

Yield-to-Worst (YTW) measures the lowest yield received on a bond if held to maturity or to the earliest callable date, without the bond defaulting.

Tax-Equivalent Yield (TEY) measures the yield on a tax-exempt investment, such as a municipal bond, expressed as if it were subject to federal income tax and the ACA tax.

RATING DISTRIBUTION

Credit ratings are provided by nationally recognized statistical rating organizations (NRSROs) and are subject to change. Bond ratings, reflecting the issuer's financial strength, range from AAA (best) to D (worst) and may vary over time. Securities rated BBB and above are classified as investment-grade. Ratings are not a guarantee of credit quality and do not eliminate market risk. The holdings and characteristics of a portfolio, including their weightings, are subject to change and may fluctuate over time.

FIRM AND WEBSITE DISCLOSURES

The views and opinions expressed are as of the date of publication (or as otherwise noted) and are subject to change without notice. Material is provided for educational purposes only and is not intended to be relied upon as a forecast, research, or investment advice, nor should it be considered a recommendation, offer, or solicitation for the purchase or sale of any security, or to adopt a specific investment strategy. Information presented, including any links to third-party websites or content, is obtained from sources believed to be reliable, but its accuracy or completeness is not guaranteed. References or links to third-parties are provided for informational purposes only and do not constitute an endorsement or approval of the content, products, services, or opinions expressed therein.

Material may include forward-looking statements based on certain assumptions about future events. Actual outcomes may differ from those projected. Material may also include hypothetical performance provided for informational purposes only, which does not reflect the performance of an actual client portfolio. Hypothetical performance has inherent limitations, does not reflect actual trading, and may not reflect the impact of material economic or market factors. Investment decisions should be made based on an investor’s objective and circumstances, and in consultation with their professional tax, financial, or legal advisor.

Material should not be considered tax or legal advice, and investors should contact their tax professional for information regarding their tax situation. Investing in municipal bonds for the purpose of generating tax-exempt income may not be appropriate for investors in all tax brackets or for all account types. There may be less public information available on municipal fixed income securities than found on public corporations. Municipal bonds may be less liquid than corporate bonds. A portion of the income may be taxable by state or local taxing authorities. Municipal bond holders may also be subject to capital gains taxes and interest income may be subject to alternative minimum tax. In addition, bonds incur ongoing fees and expenses. An investment in a portfolio involves various risks, including the risk that an investor can lose money. Investing in the bond market is subject to certain risks including market, interest rate, issuer, credit, inflation, and liquidity risk. While the Manager strives to attain the investment objective of the strategy through research and portfolio management skills, there is no guarantee of successful performance, that the objective can be reached or that a positive return can be achieved. Past performance is no guarantee of future results.

Material is not directed to, or intended for distribution or use by any person or entity if Belle Haven Investments, L.P. is prohibited or restricted by any legislation or regulation in any jurisdiction from making it available to such person or entity. Reports may not be reproduced, re-distributed, or passed to any other person or published in whole or in part for any purpose without prior consent of Belle Haven Investments, L.P.

Belle Haven Investments, L.P. is registered with the Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (”FINRA”) and Municipal Securities Rulemaking Board (“MSRB”). Additional information about Belle Haven Investments is also available on the SEC’s website at www.adviserinfo.sec.gov.

Belle Haven adheres to the Global Investment Performance Standards (“GIPS®”). GIPS® is a registered trademark of the CFA Institute. The CFA Institute does not endorse or promote Belle Haven, nor does it guarantee the accuracy or quality of the content provided. For more information about Belle Haven, including GIPS-compliant performance data for the Firm's strategies and products, please contact service@bellehaven.com.

SOCIAL MEDIA DISCLOSURES

All content published, posted, or otherwise disseminated by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) on any social media platform, including but not limited to, X (formally Twitter), LinkedIn, Spotify, and iTunes (collectively, “Belle Haven Social Media Platforms”), is obtained from sources believed to be reliable; however, Belle Haven does not guarantee the accuracy, completeness, or timeliness of such information. Opinions expressed reflect the views of Belle Haven as of the date of publication (or any earlier referenced date) and are subject to change without notice.

Nothing published or disseminated on Belle Haven Social Media Platforms should be construed as a forecast, research, or investment advice, nor as a recommendation, offer, or solicitation to buy or sell of any security or to adopt any investment strategy. Any information provided is for informational purposes only. Investment decisions should be based on an investor’s individual objectives, financial circumstances, and risk tolerance, and should be made in consultation with the investor's professional tax, financial, and legal advisors.

Content published or disseminated on Belle Haven Social Media Platforms (including any attachments, links, or references) is not intended to provide tax or legal advice. Investors should consult their own tax or legal professionals regarding their specific circumstances. Investments in municipal bonds or other fixed income securities may not be suitable for all investors and are subject to various risks, including but not limited to market risk, interest rate risk, issuer risk, credit risk, inflation risk, and liquidity risk. Municipal securities may have limited publicly available information and may be less liquid than other securities. In addition, municipal bond income may be subject to state or local taxes, capital gains taxes, or the alternative minimum tax. Bonds and investment portfolios are also subject to fees and expenses, and investing involves the risk of loss of principal. While Belle Haven seeks to achieve the investment objectives of its strategies through research and portfolio management, there is no guarantee that such objectives will be achieved or that any investment will generate positive returns. Past performance is no guarantee of future results.

Any securities referenced or discussed on Belle Haven Social Media Platforms are provided for illustrative purposes only and do not represent the full range of securities purchased, sold, or recommended for client accounts. There should be no assumption that any securities discussed were or will be profitable. Belle Haven may or may not currently hold, and may not intend to hold, any securities referenced. Belle Haven does not accept purchase or sell orders through its Social Media Platforms and advises users not to disclose personal, confidential, or financial information through these channels. Belle Haven reserves the right to remove, edit, or report any posts or comments on its Social Media Platforms, including advertising, promotional, or inappropriate content.

Third-party content shared, reposted, or otherwise referenced on Belle Haven Social Media Platforms reflects the views of the third party and not necessarily those of Belle Haven. Belle Haven does not endorse, guarantee, or assume responsibility for the accuracy, completeness, or appropriateness of any third-party content, including hyperlinks. Links to external websites are provided solely for informational purposes and do not imply any affiliation, sponsorship, or endorsement by Belle Haven. Belle Haven is not responsible for the content, privacy practices, or policies of any third-party websites and assumes no liability for information, opinions, products, or services available through such sites. The failure to remove third-party content does not constitute an endorsement. Belle Haven reserves the right to remove, modify, or restrict access to any third-party content at its discretion.

Neither the U.S. Securities and Exchange Commission (“SEC”) nor any federal, state, or non-U.S. regulatory authority has approved, verified, or passed upon the accuracy or adequacy of the information published or disseminated by Belle Haven on its Social Media Platforms. Any representation to the contrary is unlawful. Content published on Belle Haven Social Media Platforms is not directed to, or intended for distribution to or use by, any person or entity in jurisdictions where such distribution or use would be contrary to applicable laws or regulations. Content may not be reproduced, redistributed, forwarded, or published, in whole or in part, without the prior written consent of Belle Haven Investments, L.P.

AWARDS AND RECOGNITION

Any awards or recognitions referenced are issued by independent third-party organizations and may be based on performance or other criteria. The criteria, methodologies, and evaluation processes used to determine such awards may vary by organization and are subject to change. Belle Haven Investments, L.P. does not verify or guarantee the accuracy, completeness, or consistency of any third-party rankings, evaluations, or methodologies. Additional information regarding the criteria used to determine any award, as well as further details about Belle Haven’s strategies or recognitions, is available upon request. For more information, please contact service@bellehaven.com.

Lipper Criteria

While the Lipper Investment Manager Database is very open in terms of accepting a variety of calculation and reporting methodologies, only those performance streams which meet the qualifications outlined below are considered for the World's Best Money Managers rankings.

Once again, Lipper does not imply or represent that only performance which meets these qualifications are "valid”. Rather, the qualifications are enforced for the sole purpose of ensuring comparability between managers. If you have any comments regarding these requirements, feel free to Contact Us.

Here are the minimum criteria for inclusion in Best Money Managers:

1. Performance must be calculated "net” of all fees and brokerage commissions. This means after all fees have been deducted.

This standard is somewhat controversial, as the SEC requires that only "net” of fees numbers be presented publicly, while GIPS (Global Investment Performance Standards) prefers that "gross” numbers be presented along with a fee schedule.

Since the SEC is a regulatory authority, and since complete fee schedule presentation would be impractical in this "ranking" format, we require "net” numbers.

2. Performance must be calculated inclusive of all cash reserves.

To explain, any given investment portfolio will hold some level of cash over a particular reporting period. Even equity portfolios which specifically seek to be fully invested in the market at all times will temporarily have dividend payments and other ordinary cash flows which cannot instantaneously be invested in the market.

These cash holdings obviously will have an effect on the performance of the overall portfolio – negative when cash returns are low relative to returns of the asset class, and positive if the opposite is true.

While presentation of "equity-only” (for example) returns may provide a valuable insight into the security selection skills of the manager, we require for comparability's sake that performance results be inclusive of cash reserves for consideration in the rankings.

3. Performance results must be calculated in U.S. dollars, that is, from the perspective of a U.S.-based investor.

Currency holdings can have a very significant impact on the performance of a portfolio with international holdings. While this will always be the case (as we do not make distinctions between hedged and unhedged portfolios), we require that performance must be translated into U.S. dollars to ensure comparability to the point where these are all returns that would be seen by a U.S.-based investor.

4. Performance results must be calculated on an asset base which is at least $10 million in size for "traditional” U.S. asset classes (equity, fixed income, and balanced accounts) or at least $1 million in the case of international and "alternative” U.S. asset classes.

This minimum ensures that the firm and product are somewhat established. The goal is to not taint the rankings with "flashes in the pan” while also not excluding promising emerging managers.

The minimum asset base requirement, therefore, is set at a level which balances these objectives.

5. The classification of the product must fall into one of the categories which we rank. We only publish rankings for categories/time period combinations for which we have at least 20 contenders.

PSN Top Guns Criteria

Commingled Fund Universes: include commingled funds and pooled funds.

Non-Commingled Fund Universes: include PSN Products excluding mutual funds, commingled funds, pooled funds collective trusts, limited partnerships, offshore funds, wrap products, hedge funds and MLP's.

1 QTR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on current quarter returns.

1 Year CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the one year period.

3 Year CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the three year period.

4 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. The top ten returns for the latest three-year period then become the TOP GUNS.

5 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five year period equal or less than the median standard deviation for the peer group. The top ten returns for the latest three-year period then become the TOP GUNS.

6 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five year period equal or less than the median standard deviation for the peer group. The top ten information ratios for the latest five-year period then become the TOP GUNS.

Manager of the Decade

Top Guns Manager of The Decade Criteria: The PSN universes were created using the information collected through the PSN investment manager questionnaire and use only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Mutual fund and commingled fund products are not included in the universe. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the latest ten year period. Moreover, products must have returns greater than the style benchmark for the latest ten-year period and also standard deviation less than the style benchmark for the latest ten-year period. At this point, the top ten performers for the latest ten-year period become the PSN Top Guns Manager of the Decade.

The content of PSN Top Guns is intended for use by qualified investment professionals. Please consult with an investment professional before making any investment decisions using content or implied content from PSN Top Guns. Due to the short term nature of a one quarter performance benchmark, please be advised that the 1 QTR PSN Top Guns award is intended for informational purposes only and should be used only in a one-on-one and face-to-face presentation where an investment professional is present. Any other usage of the 1 QTR PSN Top Guns is strictly prohibited, not advised, and not permitted by Informa Business Intelligence.

All Rights Reserved. PSN Top Guns is powered by PSN. PSN is an investment manager database and is a division of Informa Business Intelligence (IBI). No part of PSN Top Guns may be reproduced in any form or by any means, electronic, mechanical, photocopying, or otherwise without the prior written permission of Informa Business Intelligence.

Because of the possibility of human or mechanical error by IBI sources or others, IBI does not guarantee the accuracy, adequacy, completeness or availability of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. THERE ARE NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall IBI be liable for any indirect, special or consequential damages in connection with use of any information or derived using information based on PSN Top Guns results.

The content of the PSN Top Guns is intended for use by qualified investment professionals. Please consult with an investment professional before making any investment decisions using content or implied content from PSN Top Guns.

ORDER ROUTING

Disclosure Pursuant to SEC Rule 606 - Order Routing

Pursuant to the Securities and Exchange Commission (“SEC”) Rule 606, Belle Haven is obligated to disclose, on a quarterly basis, certain statistical information regarding its order routing practices. Belle Haven routes customer equity and option orders to its clearing firm, BNY Pershing, LLC, for execution.

For further details regarding how your order was routed, please contact us, in writing, with the details of your trade inquiry. We will be happy to provide that information. Specific information regarding our order routing is available at the website of our clearing broker, BNY Pershing, LLC, at https://www.orderroutingdisclosure.com.

ANTI-MONEY LAUNDERING: CUSTOMER IDENTIFICATION PROGRAM

Important Information You Need to Know About Opening a New Account

Federal law requires financial institutions to obtain, verify, and record information identifying individuals and entities opening accounts. Belle Haven may request personal or organizational identifying information and documentation. Failure to provide required information may result in account restrictions or closure. Belle Haven complies with all applicable sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).