Firm Description Avalor Investment AG (“Avalor Ltd” or “the Firm” or “we”), a Swiss corporation based in Zurich, Switzerland, provides investment advisory services to clients resident in the United States (“US”). We also serve US taxpayers or dual citizens living outside the US and clients who have no connection to the US. Avalor Ltd is a corporation organized under Swiss law in 2005. Principal Owners Amaury Jordan principally owns Avalor Ltd. Services Avalor Ltd provides a comprehensive range of services in the areas of discretionary portfolio management and non-discretionary (advisory) management, as well as investment consolidation / reporting to high net worth and ultra-high net worth private clients and their families. Avalor does not render any Legal or Tax advice. Discretionary Portfolio Management Services Avalor Ltd offers discretionary portfolio management services to individuals, high and ultra-high net worth clients and their families who wish to have their assets fully managed by Avalor Ltd. This service includes asset allocation, investment selection, active portfolio management and portfolio rebalancing in accordance with each client’s personal circumstances. Avalor Ltd discusses a client's prior investment history, as well as family situation and background. As part of this information- gathering process, Avalor Ltd determines the client's individual investment objectives, risk tolerance, time horizon, liquidity needs and tax situation, and, taking into account these factors, develops a tailored investment policy for that client (“investment profile”). Each client’s assets are managed in a separate account (an “Account”) maintained at a third-party financial institution (custodian bank). As part of its discretionary portfolio management service Avalor Ltd purchases and sells securities for the client’s Account without prior consent of or notification to the client. Avalor Ltd determines the securities that are bought and sold for the client’s Account and the total amount of the purchases and sales. Avalor Ltd’s authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the asset management agreement entered into between Avalor Ltd and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Client Accounts are broadly managed in a similar manner. However, differences in each portfolio may occur due to client-specific investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations, reference currency, legal restrictions and overall suitability. Avalor Ltd’s client portfolios are globally diversified across multiple asset classes. Accounts may include, without limitation: equity securities, fixed income and other debt securities, mutual funds, exchange traded funds, hedge funds, options, structured products, precious metals and other alternative investments consistent with the client’s investment profile and overall suitability. For the purpose of diversification, client Accounts will hold non-dollar securities in markets outside the United States. Whilst Avalor Ltd generally makes investments with a longer time horizon, the Firm may make changes to allocations, resulting in underweight

or overweight positions, in an attempt to take advantage of short-term developments in economic conditions. When doing so, Avalor Ltd will make every attempt to Avalor Investment AG, CRD: 283227 4 be sensitive to transaction costs and taxes, as applicable. Avalor’s advice is limited to the types of securities and transactions as set forth in Item 8. Non-Discretionary (Advisory) Services Non-discretionary (advisory) services are similar to discretionary portfolio management services in terms of the investment approach; however, Avalor Ltd requires client consent before effecting any securities transaction. Avalor Ltd provides portfolio advice and trading recommendations but all decisions regarding the investment of the Account reside with the client. This service is designed for clients who desire holistic management of their Account but who want to retain involvement in every investment decision. As a result, clients under this service offering may not be invested in the same manner as those clients using discretionary portfolio management services. If explicitly required by a non-discretionary client, Avalor Ltd may implement investment ideas which do not pertain to Avalor Ltd’s investment universe. Avalor Ltd will disclose to the client, if an investment idea is not part of its investment universe. Investment Consolidation and Reporting Services Avalor Ltd offers global consolidation and reporting services for clients with financial Accounts at more than one financial institution (including Accounts that Avalor Ltd does not manage or advise upon) for purposes of evaluating global asset exposure. Avalor Ltd will: (i) examine bank statements received at the direction of the client; (ii) prepare a consolidated statement of assets on a monthly, quarterly and/or annual basis; (iii) regularly analyze structure and performance of all individual portfolios as well as of the consolidated whole, serving as a basis for a coordinated implementation of investment policy and for the identification of possible improvements; and (iv) monitor and report on banking costs. Avalor Ltd has no authority to advise on the Accounts it does not manage. However, Avalor Ltd may be asked by a client to comment on and provide general counselling about certain aspects of the client’s overall wealth structure. For example, Avalor Ltd may, on client request, be asked to recommend wealth management specialists for its clients, possibly including other investment managers. In such cases, Avalor Ltd’s recommendation will generally include a selection of several such advisors or specialists. The recommendation will strongly depend on the client’s personal circumstances. The final selection is left entirely up to the client, and Avalor Ltd receives no remuneration from any person or firm that it may recommend under such circumstances. Wrap Fee Programs Avalor Ltd does not participate in wrap fee programs. Assets under Management and Advisement Avalor Ltd managed approximately USD 1’609 million on a discretionary basis and USD 464 million on a non-discretionary (advisory) basis as of December 31, 2022. In addition to this, Avalor Ltd offered consolidation and reporting services over a further USD 546 million as of December 31, 2022.