A. General Description Raison Asset Management Corp., a British Virgin Islands business company limited by shares, incorporated on 8 July 2015 and authorized and licensed by the Financial Services Commission (“FSC”) under the Securities and Investment Business Act, 2010 (“SIBA”) and Investment Business (Approved Managers) Regulations, 2012 in the British Virgin Islands (“BVI”), (Certificate No. IBR/AIM/15/011) to act as an investment manager or investment advisor to different types of funds organized in BVI and other Recognised Jurisdictions and a person that is incorporated, formed or organized outside the BVI in a non-recognised jurisdiction and to such other person as the FSC may approve on a case by case basis in other Recognised Jurisdictions. In December 2020 Raison Asset Management finished the rebranding process with a renaming of Threesixty Elements S.A. Raison Asset Management is fully owned by Raison FinTechnologies, Inc. directly. We are a privately held company with representative offices in Estonia: Roosikrantsi 11, 10119, Tallinn. Raison Asset Management concentrates on discretionary trading and investment advisory services, also on investment management of pool investment vehicles structured as open- and closed-ended private, professional and public funds. Additional information about Raison AM products and structure is provided in Part 1 of Form ADV which is available online at http://www.adviserinfo.sec.gov. We encourage you visiting our website raison.am for any additional information. B. Summary of company’s Advisory Services Raison AM specializes in managing funds and segregated portfolios for private clients, corporations and trusts. Our investment objective is to generate long-term capital appreciation through consistent and superior risk- adjusted absolute returns in all market environments. The trading strategy is in accordance with the company’s assessment of the capital market situation as well as the general prospects of the investment instruments. Our clients’ assets are invested worldwide according to the principle of distribution of risks. Raison AM intends to trade in a broad range of

markets and instruments traded. C. Tailored Services and Investment Restrictions Our clients’ investment portfolios may be comprised of any type of the following instruments: A. Global Derivatives (Exchange Traded Futures & Options) I. Global Equity Indices 1. Dow Jones, S&P 500, NASDAQ-100, Russell 2000, MidCap, S&P 60 (Canada), FTSE, DAX, CAC-40, Euro Stoxx 50, SMI, MIB30, IBEX, AEX, Nikkei 225, WIG 20, HKEX, RTS, BOVESPA, Volatility indices. II. Major & Minor World Currencies 1. Euro, Japanese Yen, Swiss Franc, British Pound, Australian Dollar, Canadian Dollar. III. Global Interest Rates 1. US 30Y, US 10Y, US 5Y, US 2Y, Eurex Bunds, Long Gilt, JGB IV. Metals 1. Gold, Silver, Copper B. Global Listed Equities (stocks, exchange-traded funds/depository shares, options) Any stock listed on global stock exchange with an emphasis on highly liquid, large-cap U.S. equities or option on such stock. C. Global FOREX (Spot, Futures, Options, Forwards, EFPs) (i) Majors: Euro, Japanese Yen, Swiss Franc and British Pound. (ii) Minors: Australian Dollar, Canadian Dollar and Russian Rouble. D. Private equity. Raison AM investment services are based on modern portfolio theory that makes it possible for anyone to access state-of-the-art portfolio management. Our separate portfolios are tailored to each individual’s unique risk characteristics and investment constraints. Since each client has his/her own unique separately managed account, when applicable, they may impose certain restrictions on specific securities or types of securities. D. Wrap Fee Programs At present Raison AM operates as a fee paid advisor, and is compensated as a percentage of Net Liquidation Value entered as an annualized percentage, applied on a monthly basis. We may additionally receive a part commissions of any kind from brokers, custodians, or investment funds and educational courses we organize. We are not supplied with third party research credits. E. Assets Under Management As of the end of December 2021 Raison AM managed about $54 000 000 in total under discretionary management and in a non-discretionary capacity.