Advisory Business A. Intesa Sanpaolo Wealth Management (“Intesa Sanpaolo Wealth Management” or the “Firm”) is a Luxembourg bank that offers a number of banking, wealth management, and investment advisory services. Intesa Sanpaolo Wealth Management was formed in 2007 and has offices in Luxembourg and Ghent and Brussels, Belgium. Intesa Sanpaolo Wealth Management is a wholly owned subsidiary of Fideuram – Intesa Sanpaolo Private Banking S.p.A., which is ultimately owned by Intesa Sanpaolo S.p.A., listed at the Milan Stock Exchange. B. Intesa Sanpaolo Wealth Management offers tailored investment advisory services to its clients in addition to an array of banking, investment and other financial services. Advisory arrangements vary in the types of investments recommended, general market advice rendered, and/or discretionary authority afforded to Intesa Sanpaolo Wealth Management and the Intesa Sanpaolo Wealth Management investment professional tasked with managing the client relationship (the “Client Relationship Manager” or “CRM”). A portfolio management agreement (each, a “Portfolio Management Agreement”) governs the Firm’s provision of advisory services to each client. Portfolio Management Agreements are negotiated with clients and contain information regarding the investment objectives, strategies and other relevant terms applicable to each account. Both discretionary and non-discretionary mandates are offered to clients, covering a variety of financial instruments. Clients opt into strategies that can, among other things, permit or restrict different asset classes, aim to achieve certain levels of liquidity, target particular time horizons, or take on certain volatility characteristics. Client Portfolio Management Agreements (i) outline constraints that limit the portfolio to a target allocation of investments in, among other instruments, equities, bonds, debentures, derivatives, shorts, commodities, third-party managed funds, including alternative investment funds (e.g., hedge funds, private equity funds, real estate funds), cash, money market products, and/or currencies, or (ii) be generally unrestricted from investing in particular asset classes. The Firm is headquartered in Luxembourg and is regulated by the Luxembourg Commission de Surveillance du Secteur Financier in addition to being registered with the SEC. As a non-U.S.-based investment adviser, the Firm relies on various positions of the SEC and its staff that permit a non-U.S.-based adviser to apply the substantive provisions of the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”) and related rules only to its clients deemed to be United States persons (“U.S. Clients”). As a result, specific SEC compliance obligations are applied by the Firm only to clients and potential clients who are U.S. persons and those individuals associated with the Firm who provide services to U.S. Clients. The Firm provides three primary types of investment advisory service offerings: Discretionary Portfolio Management Mandates Under discretionary portfolio management mandates, portfolio management is conducted by a dedicated team of portfolio managers who ultimately have discretion over investment decisions, with no discretion at either the client level or CRM level. Dedicated Portfolio Management Mandates Under dedicated portfolio management mandates, client portfolios are managed by the relevant CRM who has the ultimate discretion over investment decision. The client may be involved to a certain extent in the decision-making process, pursuant to the terms negotiated in the relevant Portfolio Management Agreement. The investment sourcing and due diligence process is done in coordination with the Firm’s dedicated team of portfolio managers. Due to the MiFID II regulation implemented in Europe, a vast number of such mandates have been switched to Discretionary Portfolio Management Mandates. Active Advisory Mandates The CRM, supported by the Firm’s team of investment professionals, actively supervises the client’s portfolio and makes investment recommendations consistent with the objectives stated in the client’s Portfolio Management Agreement. The client ultimately has the discretion over investment decisions. Intesa Sanpaolo Wealth Management has built a network of relationships in the investments space, and actively leverages this network in servicing its clients. When suitable opportunities are identified, the Firm will place (or recommend the placement of) client assets in private pooled investment funds managed by third-parties or other investment advisers in the ISP Group (collectively, Intesa Sanpaolo Wealth Management, Fideuram – Intesa Sanpaolo Private Banking S.p.A. and Intesa Sanpaolo S.p.A, are the “ISP Group”). In some cases, the Firm’s team of investment professionals may approach a third-party or ISP Group manager to create and manage a tailored structured product based on a particular thesis or strategy (such tailored investment vehicles, “Structured Products”). In other cases, the Firm may decide to invest

(or recommend the investment of) client assets in existing private investment funds managed by third-parties or advisers within the ISP Group, or other private funds not specifically tailored to the needs of the Firm and its clients (such non-tailored investment vehicles, “Third-Party Managed Funds”). In all cases, the Firm and applicable CRM strive to make decisions in the best interests of the Firm’s clients, and only make investment recommendations consistent with each client’s investment mandate. The Firm also provides trade execution services with respect to certain client order accounts but does not provide such accounts with regular and continuous investment advisory services. This service offering is not available to U.S. Clients. From time to time, the Firm also grants credit to certain advisory clients (but not to U.S. Clients) to use as leverage. Upon a client’s request, a credit line may be granted against a pledge over such client’s portfolios held with the Firm. The borrowed funds are reinvested in investments that are also held with the Firm (and possibly also pledged in favor of the Firm, pursuant to the terms of the relevant credit agreement). This Brochure describes the Firm’s current service offerings and will be amended to the extent the advisory arrangements offered by the Firm change in the future. C. The Firm provides discretionary and non-discretionary investment advisory services to the clients in accordance with each client’s investment objectives and limitations. Such investment objectives and limitations may be tailored through close conversations among the client, the CRM, and other investment professionals of the Firm, as applicable, Portfolio Management Agreement. D. Certain clients pay a single “all-in” fee (an “All-in Management Fee”) to the Firm and/or its affiliates for the provision of investment advice and other related services, which may include, but are not limited to, brokerage services, custodial services, and transaction/execution services. Such arrangements are commonly known as “wrap-fee programs”. The terms of each client arrangement, including services to be provided by the Firm and its affiliates and fee arrangements, are outlined in the applicable Portfolio Management Agreement. The All-in Management Fee (i) is typically calculated as a percentage of a client’s assets under management; (ii) varies from client-to-client; and (iii) can change at the discretion of the Firm and/or applicable CRM, if permitted pursuant to the applicable Portfolio Management Agreement. This process is further described in Item 5 of this Brochure. In certain cases, the All-in Management Fee will cover most execution charges for equity trades executed through the Firm and/or its affiliated banking entities (although certain execution charges for transactions effected through the Firm and/or its affiliates, such as dealer markups or mark-downs, odd-lot differentials, transfer taxes, handling charges, exchange fees, wire transfer fees, offering concessions, related fees for purchases of public and private offerings of securities, other miscellaneous charges and other charges imposed by law may not be included in the All-in Management Fee). With respect to U.S. Clients under a combined fee structure, such fee generally covers investment advisory fees, custodial fees and other administrative fees associated with the account, but expressly does not cover transaction-based fees. The Firm does not (i) provide execution services to U.S. Clients, (ii) receive transaction-based compensation from U.S. Clients, or (iii) offer any wrap fee programs to U.S. Clients. Execution services are paid for separately by U.S. Clients to third-party brokers. The Firm’s Portfolio Management Agreements with clients under the All-in Management Fee structure, inclusive of execution services, typically permit the Firm to place transactions through third-party brokers or dealers if and when the Firm and/or its affiliates are unable to effect a particular transaction, or if the Firm and/or applicable CRM believes that executing a transaction through an unaffiliated broker or dealer is otherwise in the best interests of the underlying client. In determining the broker or dealer through which to execute a transaction, the Firm considers relevant factors such that the Firm reasonably believes that the broker-dealer selected can be reasonably expected to provide best execution under the circumstances and it determines in good faith that the commission cost is reasonable in relation to the value of the brokerage and, where applicable, research services provided. The Firm is not obligated to solicit competitive bids for such transaction or to seek the lowest available commission cost. Rather, the Firm takes a holistic approach to assessing broker-dealers in light of its best execution obligations. Please see Item 12 of this Brochure for a further description of the Firm’s brokerage practices. E. As of December 31, 2022, the Firm managed approximately $3,880,439,899 in assets on a discretionary basis and $612,181,149 in assets on a non-discretionary basis.