A. Description of the Advisory Firm Picea Capital LLC (hereinafter “Picea”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in February 2020, and the principal owners are Rodolfo Antonio Garcia-Esquer and Javier Mijares-Margain. B. Types of Advisory Services Portfolio Management Services Picea offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Picea creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Picea evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Picea will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Picea seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Picea’s economic, investment or other financial interests. To meet its fiduciary obligations, Picea attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios,

and accordingly, Picea’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Picea’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments Picea generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), commodities and non-U.S. securities. Picea may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Picea offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Picea does not participate in any wrap fee programs. E. Assets Under Management Picea has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 38,267,599.00 $ 0.00 December 2022