Brightstone Capital Management, LLC (“Brightstone” or the “Investment Adviser”) is an alternative asset manager headquartered in Trinidad and Tobago. Founded in 2017, Brightstone was established with a vision to pursue investment opportunities globally. Brightstone forges financial acumen, independent analysis with hands-on operational expertise to deliver investment returns. Brightstone prides itself by taking an active approach to investing. Brightstone’s investment strategies include a broad range of various types of investments in global markets. Brightstone is owned and controlled by Mr. Andy Jogie and was founded to pursue investment opportunities on behalf of its Clients globally. Brightstone, taking an active approach to investment, forges financial acumen, independent analysis with hands-on operational expertise to deliver investment returns to its Clients. Brightstone offers portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each Client. Brightstone requires discretionary authority from Clients in order to select securities and execute transactions without permission from the Client prior to each transaction. Brightstone seeks to provide that investment decisions are made in accordance with its fiduciary obligations owed to its Clients and without consideration of Brightstone’s economic, investment or other financial interests. To meet its fiduciary obligations, Brightstone attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage any Client portfolios. It is Brightstone’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among all of its Clients on a fair and equitable basis over time. Each Client is required to enter into an Investment Brightstone Contract (“IAC”) with Brightstone that defines the terms, conditions, authority and responsibilities of Brightstone and the Client. Client authorizes Brightstone to respond to inquiries from, communicate and share information with Client’s accountants, attorneys, advisors and other consultants or professionals as deemed necessary by Brightstone to provide its services to Client and/or as requested by Client. No services other than those discussed in the IAC, such as financial planning, are implied or guaranteed, except as individually negotiated and confirmed in writing. Brightstone is responsible only for the assets over which Client has provided Brightstone discretionary authority and not for the diversification or prudent investment of any other assets of Client. Brightstone acts as a fiduciary regarding its investment advisory services for each Client and must put the Client’s interests above its own in managing a Client’s account. Brightstone agrees to provide these services to a Client in a manner consistent with its fiduciary duty to Clients and the provisions of all applicable laws, including the Investment Advisers Act of 1940. Before signing the IAC and periodically during the parties’ advisory relationship, Brightstone will provide Client written disclosures

of any conflicts of interest that might reasonably compromise Brightstone’s impartiality or independence. Brightstone represents and warrants that Brightstone does not receive compensation or other remuneration that is contingent on any Client’s purchase or sale of a financial product. Brightstone does not receive a fee or other compensation from another party based on the referral of a Client or Client’s business. Brightstone may refrain from rendering any advice or services concerning securities of companies in which Brightstone may have substantial economic interest or other conflict, unless Brightstone discloses such conflict to Client before providing such advice or services with respect to Client’s account. These services include the following:
• Establishing an Investment Policy Statement – Brightstone, in connection with the Client, will develop a statement that summarizes the Client’s investment goals and objectives along with the strategy[ies] to be employed to meet the objectives. Brightstone then creates an Investment Policy Statement (“IPS”) for each Client. Brightstone may invest Client’s account in securities of any kind, including but not limited to, common or preferred stock, warrants, rights, corporate, municipal or U.S. Treasury bonds or notes, and mortgage-backed securities, so long as such investments are consistent with the investment objectives set forth in the incorporated Statement of Investment Policy. Brightstone may hold all or a portion of Client’s account in cash.
• Risk tolerance levels are documented in the IPS, which is given to each Client. An IPS generally includes specific information on the Client’s stated goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any restrictions imposed by the Client.
• Asset Allocation – Brightstone will develop a strategic asset allocation that is targeted to meet the Client’s investment objectives, time horizon, financial situation and risk tolerance.
• Portfolio Construction – Brightstone will construct a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Brightstone will provide investment management and ongoing oversight of the Client’s investment portfolio. Brightstone will monitor Client’s account on an ongoing basis and conduct periodic portfolio reviews with Client. Brightstone will generally be available to discuss Client’s account during normal business hours and will contact Client periodically. Brightstone will attempt to meet with Client at least annually to discuss Client’s investment needs, goals and objectives. Brightstone will also review Client’s account performance and the continued suitability of investments recommended by Brightstone for Client at least quarterly. Clients may terminate the IAC at any time and immediately upon written notice to Brightstone. Brightstone is required to disclose the assets under management as of December 31, 2023. As of December 31, 2023, Brightstone had $12,567,533 of assets under management.