A. Description of the Advisory Firm Volaris Capital Management LLC (hereinafter “VCML”) is a Limited Liability Company organized in the State of New Jersey. The firm was formed in October 2016, and the principal owner is Vivek Kapoor. B. Types of Advisory Services Portfolio Management Services VCML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VCML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring VCML provides investors with access to opportunities in the options market based on exchange listed contracts with widely publicly disseminated prices. See below and Item 8 below for additional details on specific strategies. Volatility Income: This strategy seeks to create returns by selling optionality to the market in the form of spreads, always buying at least as many options as sold on the same underlying (S&P 500 Index). This program typically buys more options units than sold to seek to limit its risks. The strikes of options trades reflects assessments of relative value through a detailed and systematic quantitative process, as well as outright limitations on the maximum intrinsic value of options sold to be a small fraction of mandate size. Call Write: This program seeks to create liquidity for holders of concentrated stock positions via selling Call Options on those stocks. Selling a Call Option on a stock while owning the stock limits the upside gains incurred by the Client in the event of an increase in the value of the stock. The strikes sold Call Options on the stock reflect assessments of probability of those contracts expiring in the money and can be tailored to Clients aversion to their stock position being called away in an upward march of the underlying stock. Tail Risk Hedging: This program seeks to provide protection against oversized and rare movements of the underlying markets while

controlling for carry-costs and risks. This program involves either outright purchasing of options, or selling option spreads – selling near money and buying at least twice as many further out of the money options. VCML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. VCML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. VCML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VCML’s economic, investment or other financial interests. To meet its fiduciary obligations, VCML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VCML’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VCML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. C. Client Tailored Services and Client Imposed Restrictions VCML offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. VCML does not participate in any wrap fee programs. E. Assets Under Management VCML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 455,116,484 $0 12/29/2023