Black Swift Group, LLC (“Black Swift” or “Adviser” or “Firm”) is a registered investment adviser with the Securities and Exchange Commission (“SEC”). Black Swift was formed in 2016 and is organized as a Colorado limited liability company. Black Swift is headquartered in Boulder, Colorado and is principally owned and controlled by Greg Casals, the Managing Member of Black Swift. Black Swift provides investment management services primarily for high-net-worth individuals, corporations, trusts, foundations, and other entities through separately managed accounts (“SMA”). Black Swift also provides investment advisory services to five private funds, the Black Swift Special Situations Fund, LP, the Black Swift Healthier Focus Fund, LP, the Black Swift Partners Fund, LP, the Pro Cyclist Fund, LP, and the Pro Cyclist Institutional Fund, LP, collectively referred to as the “Funds.” The Funds are structured as U.S. Limited Partnerships. Collectively, Funds and SMAs are referred to as “Accounts.” SMAs We serve as investment manager to clients with respect to assets held in SMAs in accordance with the terms, conditions and limitations set forth in the applicable investment management agreement with each client. As part of these services, we (i) establish each client’s investment objectives after considering such factors as the client’s investment time horizon, liquidity needs and risk tolerance; (ii) buy and sell portfolio securities on our clients’ behalf and, from time to time, reallocate the securities in our clients’ portfolios; and (iii) periodically meet with our clients regarding their portfolio holdings and their holdings’ valuation, their transactions and their portfolio’s performance. The equity securities we select for our clients derive from our equity strategy which consists of a sector allocation approach. Within this diversified equity approach, we compose our equity sector choices based on a top-down approach, utilizing index sector baskets or individual equities which capture sector and economic trends. Fundamental analysis, or a bottom-up approach to investing can also be used in tandem to our top-down research. Fixed income investments are utilized to enhance portfolio return or provide portfolio income. Securities such as closed-end funds, structured credit, corporate credit, treasury, agency, or other credit securities may be utilized for portfolio construction. Alternative investments, such as investments in private funds including Black Swift’s Funds, or other niche investments strategies may be utilized as satellite strategies to provide further diversification. Derivative securities, such as options, may be used to hedge investment exposure, or to more efficiently utilize capital. Our services and processes are designed to determine and address each client’s specific investment needs and objectives through a series of meetings with that client designed to collect information as to his or her investment and financial circumstances and objectives, investment

time horizon and risk tolerance. The client may also impose restrictions on our ability to implement particular types of transactions or strategies on his or her behalf. We maintain for each SMA, a risk tolerance questionnaire that is updated on a periodic basis as needed. Funds An affiliate of Black Swift, Black Swift Partners, LLC (“Black Swift Partners”), a Delaware limited liability company, serves as general partner to the Black Swift Special Situations Fund, LP, the Black Swift Partners Fund, LP, the Pro Cyclist Fund, LP, and the Pro Cyclist Institutional Fund, LP. Black Swift Partners has sole and complete discretionary authority to manage the funds and has delegated investment authority over the assets of the funds to Black Swift. The Black Swift Special Situations Fund, LP invests in niche credit and equity investments. The Fund may also invest in other investment securities including, but not limited to: fixed income investments, equities, ETFs, options and private investments including limited partnership investments in real estate. The Fund has the ability to employ leverage and invest in derivative instruments. The Black Swift Partners Fund, LP seeks capital appreciation principally through investing in investment funds managed by third-party investment managers primarily focused on investing long and short in equity securities. The Fund may adjust market or risk exposure by entering into transactions using both long and short ETFs, fixed income, single stocks, mutual funds or closed-end funds, or derivatives such as total return swaps, options and futures. The Pro Cyclist Fund, LP and the Pro Cyclist Institutional Fund, LP, invests primarily in equities and ETFs, and has the ability to establish short positions in both index ETFs and single stocks, employ leverage and invest in derivative instruments. The fund may also invest in private investments, and other investment securities including, but not limited to fixed income investments and closed-end funds. Black Swift Group, LLC is the general partner to Black Swift Healthier Focus Fund, LP. Black Swift has sole and complete discretionary authority to manage the Black Swift Healthier Focus Fund, LP and has investment authority over the assets. The Black Swift Healthier Focus Fund, LP invests primarily in equities and ETFs, and has the ability to establish short positions in both index ETFs and single stocks, employ leverage and invest in derivative instruments. The fund may also invest in private investments, and other investment securities including, but not limited to fixed income investments and closed-end funds. Complete information concerning the Funds, including advisory fees, minimum account requirements (if any) and termination provisions, is disclosed in the Funds’ offering documents. Assets under Management As of February 29, 2024, Black Swift manages $467,575,192 of assets on a discretionary basis. Black Swift does not currently manage any assets on a non-discretionary basis.