Firm Description Alpen Partners International AG (“API” or “the Firm” or “we”), a Swiss corporation based in Bäch, Switzerland, provides investment advisory services to clients who are resident in the United States (“US”). We may also serve US taxpayers or dual citizens living outside the US. API is a corporation organized under Swiss law and was founded in 2017. Principal Owners Pierre Gabris owns 100% of the outstanding shares of API. Services API provides a comprehensive range of services in the areas of discretionary portfolio management and non-discretionary management, as well as investment consolidation / reporting to high net worth and ultra-high net worth private clients and their families. API does not render any Legal or Tax advice. Discretionary Portfolio Management Services API offers discretionary portfolio management services to individuals, high and ultra-high net worth clients and their families who wish to have their assets fully managed by API. This service includes asset allocation, investment selection, active portfolio management and portfolio rebalancing in accordance with each client’s personal circumstances. API discusses a client's prior investment history, as well as family situation and background. As part of this information- gathering process, API determines the client's individual investment objectives, risk tolerance, time horizon, liquidity needs and tax situation, and, taking into account these factors, develops a tailored investment policy for that client (“investment profile”). Each client’s assets are managed in a separate account (an “Account”) maintained at a third- party financial institution (“custodian bank”) selected by the client. As part of its discretionary portfolio management service API purchases and sells securities for the client’s Account without prior consent of or notification to the client. API determines the securities that are bought and sold for the client’s Account and the total amount of the purchases and sales. API’s authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the portfolio management agreement entered into between API and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Client Accounts are broadly managed in a similar manner. However, differences in each portfolio may occur due to client-specific investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations, reference currency, legal restrictions and overall suitability. API’s client portfolios are globally diversified across multiple asset classes. Accounts may include, without limitation: equity securities, fixed income and other debt securities, mutual funds, exchange traded funds, hedge funds, options, structured products, precious metals and other alternative investments consistent with the client’s investment profile and overall suitability. For the purpose of achieving diversification, client Accounts may hold non- dollar securities in markets outside the United States. Whilst API generally makes investments with a longer time horizon, the Firm may make changes to allocations, resulting in underweight or overweight positions, in an attempt to take advantage of short-term

developments in economic conditions. When doing so, API will make every attempt to be sensitive to transaction costs and taxes, as applicable. API’s advice is limited to the types of securities and transactions as set forth in Item 8. Non-Discretionary Services Non-discretionary services are similar to discretionary portfolio management services in terms of the investment approach; however, API requires client consent before effecting any securities transaction. API provides the client with investment and divestment recommendations and, if necessary, recommendations on how compliance with the non-discretionary Portfolio and the Investor Profile may be restored. In case the structure of the non-discretionary Portfolio significantly deviates from the Portfolio Investment Profile, API proposes to the Client relevant adjustments to the non-discretionary Portfolio. However, all decisions regarding the implementation of the investment/divestment recommendations provided by API, reside with the client. This service is designed for clients who desire holistic management of their Account but who want to retain involvement in every investment decision. As a result, clients under this service offering may not be invested in the same manner as those clients using discretionary portfolio management services. If explicitly required by a non-discretionary client, API may implement investment ideas which do not pertain to API’s investment universe. API will disclose to the client if an investment idea is not part of API’s investment universe. Investment Consolidation and Reporting Services API offers global consolidation and reporting services for clients with financial Accounts at more than one financial institution (including Accounts that API does not manage or advise upon) for purposes of evaluating global asset exposure. API will: (i) examine bank statements received at the direction of the client; (ii) prepare a consolidated statement of assets on a monthly, quarterly and/or annual basis; (iii) regularly analyze structure and performance of all individual portfolios as well as of the consolidated whole, serving as a basis for a coordinated implementation of investment policy and for the identification of possible improvements; and (iv) monitor and report on banking costs. API has no authority to advise on the Accounts it does not manage. However, API may be asked by a client to comment on and provide general counselling about certain aspects of the client’s overall wealth structure. For example, API may, on client request, be asked to recommend wealth management specialists for its clients, possibly including other investment managers. In such cases, API’s recommendation will generally include a selection of several such advisors or specialists. The recommendation will strongly depend on the client’s personal circumstances. The final selection is left entirely up to the client, and API receives no remuneration from any person or firm that it may recommend under such circumstances. Wrap Fee Programs API does not participate in wrap fee programs. Assets under Management and Advisement As of March 27, 2024, API managed USD 585,989,666 on a discretionary basis and USD 439,323,532 on a non-discretionary basis.