Wembley is a limited liability company formed under the laws of the State of Delaware. Wembley was founded in 2019 by Sam Behboudi who is the Managing Member and owner of Wembley. The Firm registered as an investment adviser with the SEC pursuant to the Investment Advisers Act of 1940 (the “Advisers Act”) in 2019. The Firm operates from a single office in New York, NY. Investment Management and Supervisory Services Wembley provides portfolio management and investment advisory services to ultra-high net worth individuals and their families (each “Separately Managed Accounts” and together “Separately Managed Accounts”); and special purpose vehicles that are structured as private funds (each a “Fund” and collectively the “Funds”). Unless otherwise noted, herein in this Brochure, Separately Managed Accounts and the Funds each a “Client”, “Client Account” and collectively the “Clients” or “Client Accounts”. As a fiduciary, Wembley acts in the Clients’ best interest. Wembley fulfills its obligation by working closely with Separately Managed Accounts Clients to identify and understand their investment objectives while building a long-term relationship. Wembley offers discretionary and non-discretionary investment advisory services tailored to each Separately Managed Account as described in more detail in such Separately Managed Account’s investment management agreement (“IMA”) between the account owner and Wembley. The terms, nature and scope of the advisory services provided by Wembley to its Separately Managed Accounts and to prospective investors in a Separately Managed Account are subject to negotiation by Wembley and the applicable investor, based on the investor’s specific financial and investment objectives, risks and goals. The Separately Managed Accounts have individual investment guidelines and objectives, as detailed in their respective IMA. Wembley cannot transfer the management of a Separately Managed Account’s to another party without the Separately Managed Account’s express written consent. Separately Managed Account Clients generally sign a five (5) year IMA and can terminate by providing

six (6) months notice after the third anniversary of the effective date of the IMA. Wembley develops integrative wealth and investment strategies for its Clients and focuses on investing in equity and equity-related securities, fixed income, currencies, commodities, structured credit products, direct and indirect investments in real estate and other assets, and alternative investments. Wembley identified and may also identify in the future certain investment and co-investment opportunities in other business ventures (“Private Investments”). Upon Separately Managed Account Client request, Wembley sources and conducts due diligence on Private Investments in accordance with the Separately Managed Account Client’s IMA or Governing Documents (described below). Such investment advisory services are non-discretionary. Wembley also sources single asset investments for Separately Managed Accounts who express an interest in such investment opportunities. Wembley structures and manages the Funds to facilitate such investments. Wembley provides investment advisory services directly to the Funds and not to the individual investors in the Funds. Wembley tailors its advisory services to the needs of the Funds but not to the individual needs of underlying investors. Wembley provides discretionary investment advisory services to the Funds and manages the Funds in accordance with the investment objectives and limitations set forth in each Fund’s offering memoranda, governing documents, subscription agreements, side letters, limited partnership agreements, IMAs and other relevant documents between Wembley and the Funds (collectively, “Governing Documents”), as applicable. The general partner of each Fund is an affiliate of Wembley. Wembley’s advisory services are further described below under “Item 8- Methods of Analysis, Investment Strategies and Risk of Loss.” Wembley does not participate in wrap fee programs. Assets under Management (Regulatory Assets Under Management) As of December 31, 2023, Wembley has $660,047,852 regulatory assets under management (“RAUM”) of which $222,570,043 are managed on a discretionary basis and $437,477,807 are managed on a non-discretionary basis.