A. Firm Information Kailasa Capital Management, LLC (“Kailasa” or the “Advisor”) is a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Delaware. Kailasa was founded in June 2017 and is owned and operated by Yongjun (Frank) N. Li (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Kailasa. B. Advisory Services Offered Kailasa offers investment management services to individuals, high net worth individuals, trusts, estates, family offices, retirement plans, endowments, foundations, other institutions, registered investment advisors, and pooled investment vehicles (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Kailasa’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Kailasa generally provides Clients with wealth management services, which generally includes a broad range of comprehensive financial planning and consulting services in connection with discretionary management of investment portfolios. These services are described below. Investment Management Services – Kailasa provides discretionary and non-discretionary investment management services for its Clients either as a component of wealth management services, or as a separate, stand-alone engagement. Kailasa works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order determine the most appropriate portfolio construction based on its internal investment strategies. Kailasa will typically construct Client portfolios with individual equity and individual fixed income positions. For exposure to international and certain asset classes, the Advisor may utilize exchange- traded funds (“ETFs”) and/or mutual funds. The Advisor may employ options strategies for downside protection and may utilize other types of investments, as necessary for certain Clients. The Advisor often liquidates legacy positions to implement its investment strategies but may retain certain holdings to avoid tax implications. Kailasa’s investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client, or due to market conditions. Kailasa will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Kailasa evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Kailasa may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Kailasa may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Kailasa may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services – Kailasa may also provide a variety of financial planning and consulting services to Clients as a component of its comprehensive wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and

other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. Kailasa may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect the transaction through the Advisor. Sub-Advisory Services Kailasa will engage with other investment advisors to provide its investment management services through a sub- advisory relationship. In such instances, the Advisor will be appointed as the sub-advisor to manage sub-advised assets as directed by the other investment advisor. Private Fund Management Services The Advisor serves as the general partner and as the investment manager to pooled investment vehicles (each a “Fund” and collectively the “Funds”). These services are detailed in the offering documents for each Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor manages the Funds based on the investment objectives, policies, and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Advisor may enter into side letter agreements with one or more investors that may alter, modify, or change the terms of interest held by investors. Certain types of side letters create a conflict of interest between the Advisor and the investors in the Funds, and/or between investors themselves. Currently, the only side letters in place in the Funds are for lower or waived fee arrangements. For more detailed information on investment objectives, policies, and guidelines, please refer to the respective Fund’s Offering Documents. Retirement Plan Advisory Services Kailasa provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis and Recommendations
• Plan Participant Enrollment and Education Tracking
• Investment Oversight Services (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance These services are provided by Kailasa serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Kailasa’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Kailasa to provide investment management services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy – Kailasa, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Kailasa will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Kailasa will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Kailasa will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Kailasa does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Kailasa.. E. Assets Under Management As of December 31, 2023, Kailasa manages approximately $203,707,541 in discretionary assets and $58,375,237 in non-discretionary assets. Total assets under management are approximately $262,082,778. Clients may request more current information at any time by contacting the Advisor.