To achieve the Program's objective, the Advisor uses a combination of net credit put and/or call spreads for options on monthly crude oil futures contracts to generate profits when the spot price of the underlying asset remains in a specific range determined at the time of contract entry. Probabilities, technical analysis, and trend lines will be most commonly used to determine portfolio positions. The Advisor intends to closely monitor current events that it believes may influence fundamentals such as supply and demand during its investment selection process. The Advisor expects to restrict its investment to only option contracts that it believes have an approximate 85-90% chance of expiring during the contract period, although there is no guarantee that the contracts that the Advisor purchases for clients will meet such threshold. For each contract period, the Advisor will set a target profit threshold for each contract entry. The Advisor intends each client to hold its option positions through the expiration date of the contract and only exit early if the options positions generate profits that meet such a pre-defined threshold or as part of a risk-management strategy. Each month, upon the expiration date, all open contracts are expected to expire with anticipation of full profit to be received. Afterward, the contract process begins for the next month with an expectation of 100% portfolio turnover each month. The Advisor will employ portfolio margin in its investing.

A multi-faceted risk approach is taken including bull and bear spreads entered strategically at different times using technical indicators to allow for a greater degree of volatility during holding periods. Spreads on one side of the market hedge potential drawdowns on opposite side. Proprietary formulas utilize option greeks to determine a benchmark for position entry and exit. Capital is preserved at pre-defined drawdown levels specific to each position by exiting positions early when appropriate. Underlying asset is chosen for its historically high liquidity. Volume and open interest are evaluated monthly for alignment with aggregated program portfolio. Platform settings include position limits to inhibit fat-fingered trading errors Position size and credit spread widths are selected to pre-define portfolio leverage below 20%.

Heather Alleman is the Founder and Portfolio Manager of Alleman Capital Management, LLC, where she oversees all investment decisions, portfolio management, and operational strategy. She has been a full-time, self-employed trader since August 2022 and formally registered as a Principal and Associated Person of Alleman Capital Management, LLC on February 15, 2024. She became an NFA Associate Member on February 27, 2024.

Ms. Alleman's path into alternative investments and securities began in 2018 while preparing for the Series 65 exam. Her deep analytical skills and operational expertise, combined with a strong background in math and science, enabled her to develop a passion for derivatives trading. She quickly focused on commodity futures, leveraging her Louisiana roots and firsthand exposure to the energy sector's economic impact. By March 2020, she was exclusively trading options on crude oil futures, setting the foundation for her transition into fund management.

Prior to launching Alleman Capital Management, Ms. Alleman held executive leadership roles at Unitech Training Academy, where she served as Chief Operations Officer from February 2021 to August 2022 and Vice President of Student Affairs from September 2009 to February 2021. As COO, she managed daily business operations for a multi-campus proprietary college system, overseeing strategic planning, financial management, and institutional growth initiatives. Her responsibilities included optimizing business practices, managing a multi-million-dollar budget, and ensuring alignment with the organization's long-term vision. In her role as Vice President of Student Affairs, she developed and implemented policies across enrollment, financial aid, academic affairs, and career services.

Ms. Alleman holds a Master's degree in Educational Administration in Higher Education and a Bachelor of Science in Education from the University of New Orleans, earned in 2002 and 1997, respectively. Today, she applies her leadership experience and deep market expertise to managing risk and generating returns in the crude oil derivatives market.