P a g e| 4 General Zest Capital is a limited liability company organized in the State of Florida and registered to conduct business as a Registered Investment Adviser. Zest Capital is wholly owned by Zest Group LLC, a limited liability company organized in Delaware, which in turn is ultimately owned by Arthur do Nascimento Silva (56%) and Alvaro Eduardo Galvez Fernandez (44%). Description of Advisory Services Zest Capital provides portfolio management financial advice and financial planning services to individuals, institutions and corporations. Zest Capital’s investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in Zest Capital’s investment advisory agreement. The Adviser’s discretionary and non-discretionary investment management services include the design, structure, and implementation of various personalized investment strategies for managed Accounts. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies and risk profile as described by each client. The Adviser also provides personalized confidential financial planning services. Advice is provided through consultation with the client and may include: determination and identification of financial objectives, cash flow management, insurance review, investment management, education funding, retirement planning, and educational services. The overall advisory services offered by Zest Capital fall within the following categories: ➢ Customized Discretionary Portfolios Adviser offers discretionary separately managed Accounts that are customized to each client. Managed Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in Item No. 8 or customized for each client based upon varying factors. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. Zest Capital tailors investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation. Client profiles are created that reflect the stated goals and objective. Zest Capital’s clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to Zest Capital in writing. ➢ Other Non-Discretionary Advisory Services Adviser provides non-discretionary advisory services to all types of clients in accordance with a non- discretionary advisory agreement

between Adviser and the client. Each agreement typically defines the services to be provided and if a fee is charged, the fees will also be agreed to in the advisory agreement. Adviser also provides recommendations and research regarding the investment of securities and cash in a P a g e| 5 client’s account. These services are individually tailored to each client’s needs and such advice may be provided to accounts with assets maintained at various third parties. ➢ Investment Funds Adviser provides investment advice to non–U.S. funds (“Investment Funds” or “pooled investment vehicles”). Investor funds are deposited in either a brokerage firm or a bank custodian account. Zest Capital Peru SAC, an affiliate Investment Adviser located in Peru, serves as Administrator, Distributor and/or Fund Manager of the Investment Funds. Jose Francisco De La Colina is the Chief Executive Officer of Zest Capital Peru SAC and therefore maintains responsibility for all activities within the pooled investment vehicles. Please see Item 10 of this Brochure for further details. The Adviser directs the investment and re-investment of the securities, cash, and other assets, in accordance with the information provided by the pooled investment vehicles (“Investment Funds”), which is also managed by Zest Capital Peru SAC, sharing the same responsibilities. All terms are generally established at the time of a pool’s formation and investors may not restrict the investments except as indicated in the fund documents. The Investment Funds authorize the Adviser and Zest Capital Peru SAC to exercise complete and total discretion in the investment of the assets in such Funds. In this connection, the Investment Funds authorize Zest Capital Peru SAC and the Adviser, as agents, to buy, sell, and trade assets in the Funds, in accordance with the terms and conditions of the fund documents and pertaining agreement. Prospective investors in the pooled investment vehicles should be aware of additional risks, restrictions on withdrawals and redemptions and other important information associated with the pooled investment vehicles. Only qualified clients are permitted to participate in the Investment Funds offered by the Adviser. ➢ Other Services Adviser may provide additional services for clients from time to time as agreed between the client and the Adviser. Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. Zest Capital investment advisory agreements may not be assigned without client consent. Zest Capital does not currently participate in any Wrap Fee Programs. Assets Under Management As of December 31, 2023, Zest Capital managed approximately $164,099,782 regulatory assets under management on a discretionary basis, and $6,763,704 regulatory assets under management on a non- discretionary basis. P a g e| 6