About the Firm Stonehage Fleming Investment Management Limited (“SFIM” or the “Firm”) was established in December 2001, and provides investment management for high-net-worth (“HNW”) individuals, Charities, other Investment Advisers, Corporations and Trusts. SFIM is wholly owned by Stonehage Fleming (UK) Limited, which is wholly owned by Stonehage Fleming Financial Services Holdings Limited, which is wholly owned by Stonehage Fleming Family & Partners Limited, which has the following principal owners (those owning 25% or more):  Caledonia Investments Plc (having a 36.05% interest)  Spes Bona Limited having a 27.73% interest. Spes Bona Limited is 41.76 % owned by Libertas Investment Group Limited, which in turn is 100% owned by the Primafides (Suisse) S.A as Trustee of the Libertas International Trust. No other owners hold more than 25% of Spes Bona Limited No other owners hold over 25% of Stonehage Fleming Family & Partners Limited. Please see Schedules A and B of the ADV Part 1 – for a list of owners. https://adviserinfo.sec.gov/firm/summary/313913. The Group employs over 900 people in 19 offices across 14 geographies. SFIM has 62 staff members, all based in the London office. The Group manages and advises over $21.3 billion of assets, of which approximately $15.134 billion is managed by SFIM (as at 31 March 2023). SFIM is authorized and regulated by the United Kingdom Financial Conduct Authority (“FCA”) to carry out investment business and is a registered investment adviser registered with the Securities and Exchange Commission (“SEC”). As a registered investment adviser, SFIM acts as a fiduciary related to the conduct of its investment advisory services. As such SFIM has an obligation to act in the best interest of its Clients guided by the core fiduciary duties of loyalty and care. In February 2022, Stonehage Fleming acquired the Private Client Services business of Maitland, a privately owned global advisory, administration and family office firm. In March 2023, Stonehage Fleming acquired the business and assets of Rootstock Investment Management (“Rootstock”), an investment firm based in South Africa. Investment Gatekeeper For clients with significant liquid wealth (typically $100m+) the Firm offers an Investment Gatekeeper service (non-discretionary). The Firm acts as the client’s “outsourced” Chief Investment Officer, providing counsel on governance of the investment process, structure, asset allocation, investment strategy, selection and oversight of external/third party managers, and specific investment recommendations on a range of assets including Equities, Fixed Income, Cash, mutual funds, alternative funds (including private capital and hedge funds), exchange traded funds, and derivatives. SFIM may or may not manage a proportion of the assets, depending on the client’s investment requirements. Depending on the client‘s requirements, SFIM can provide consolidated reporting and portfolio analysis. The investor makes the

ultimate decision regarding the purchase or sale of investments.
Portfolio Management Bringing together the Firm’s Equity Management, Fixed Income, and Cash Management Teams, SFIM will build a discretionary or non-discretionary portfolio for clients, tailored to individual client needs. Portfolios can be Equity only (stocks), Fixed Income only (bonds), cash only, Mutual Funds, alternative funds (including private capital and hedge funds), and Exchange Traded Funds only, or a combination of these assets (multi asset). The Firm can also use Forward Currency Contracts for hedging purposes. Prospective clients enter into an investment management agreement (“IMA”) which details the services to be provided and the authority and discretion SFIM is given to manage the assets in the client’s portfolio. In each case, discretion can be limited through the client’s specific investment guidelines and restrictions (companies, investment sectors or geographies) that they prefer or those they wish to exclude from their portfolio. Clients should understand that some restrictions could be exceeded or compromised as a result of events beyond the control of SFIM. For non- discretionary accounts, the retail investor makes the ultimate decision regarding the purchase or sale of investments.
The Firm follows a four step suitability process as set out below in order to create the right portfolio for each client, which includes their preferences. 1. Knowledge & Experience SFIM confirms the client’s preferred service type (e.g. discretionary versus non- discretionary). 2. Fact Find SFIM will undertake a detailed Fact Find with the client to understand: Investment objectives  Currency requirements  Restrictions Performance Comparators Income and draw-down requirements Liquidity requirements The client’s investment horizon  Knowledge and experience Tax requirements 3. Risk The client answers a series of questions to help the Firm assess the client’s risk appetite in relation to the portfolio, considering their risk and return expectations, as well as their capacity for loss. The output of the questionnaire is then assessed through a third party risk assessment system which helps the Client Relationship Director to determine the most suitable mandate for the client, taking into account the client’s requirements and any client- directed mandate restrictions from the Fact Find. 4. Investment Proposal Report An Investment Proposal Report (IPR) is prepared for the client, setting out the outputs from the suitability process, including any changes to asset allocation guidelines and any restrictions specified by the client in terms of exclusions of certain types of investment. If the client agrees with the service and mandate set out in the IPR, an Investment Management Agreement (“IMA” is prepared and sent out for the client to sign. SFIM does not participate in wrap fee programs. Regulatory Assets As of 31 March 2023, the Firm’s regulatory assets under management were $15.12 billion. Of this amount, the Firm managed approximately $11.34 billion on a discretionary basis and $3.78 billion on a non-discretionary basis.