A. Description of the Advisory Firm Ceeto Capital Group, LLC (hereinafter “CCG”) is a Limited Liability Company organized in the State of Florida. The firm was formed in November 2016, and the principal owner is Brian William Canida. B. Types of Advisory Services Portfolio Management Services CCG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCG creates an Investment Policy Statement for each client, which outlines the client’s current situation. 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 CCG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CCG 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. CCG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCG’s economic, investment or other financial interests. To meet its fiduciary obligations, CCG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CCG’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 CCG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients

on a fair and equitable basis over time. Selection of Alternative Fund Managers CCG may recommend alternative fund managers. Before selecting alternative fund managers for clients, CCG will verify that all recommended fund managers are properly licensed, notice filed, or exempt in the states where CCG is recommending the alternative fund managers to clients. Services Limited to Specific Types of Investments CCG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. CCG may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CCG 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. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCG from properly servicing the client account, or if the restrictions would require CCG to deviate from its standard suite of services, CCG reserves the right to end the relationship. 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. CCG does not participate in any wrap fee programs. E. Assets Under Management CCG has the following regulatory assets under management.: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 333,225,088 $ 59,152,049 December 2023