General Bancolombia is a limited liability company organized in the State of Florida and registered as an Investment Adviser with the SEC. Bancolombia is wholly owned by Bancolombia Capital Holdings USA LLC, and indirectly owned by Valores Bancolombia S.A. Valores Bancolombia S.A is owned by Bancolombia S.A., who is the parent company incorporated and domiciled in Colombia. Description of Advisory Services Bancolombia provides asset/portfolio management and financial advice to individuals, institutions and corporations. Bancolombia’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 Bancolombia’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, restrictions, time horizon and risk profile as described by each client. The overall advisory services offered by Bancolombia fall within the following categories: ➢ Customized Discretionary Portfolios Adviser offers discretionary separately managed accounts that are customized to each client’s investment objective and risk profile. 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 certain programs and may restrict the types of investments made in such programs. Bancolombia tailors investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation or managed account agreement. Client profiles are created to reflect the stated goals and objectives according to the new account documentation or the Investment Policy Statement (IPS), as applicable. Bancolombia’s clients are allowed to impose restrictions on certain programs on the investments in their accounts. All limitations and restrictions placed on accounts must be presented to Bancolombia in writing. o Sub-Advisory Services Under a discretionary portfolio and based upon the stated investment objectives of the client, the Adviser can hire an affiliated sub-advisor to

provide investment sub-advisory services for the benefit of its discretionary client(s). The Adviser will serve as the ultimate portfolio manager and will continue to P a g e| 5 render services to the client and, in addition, monitor and review the performance of the third-party sub- advisor and the performance of the client’s accounts that are being managed accordingly. In order to identify and select an appropriate sub-adviser, the Adviser will typically gather information about each client’s financial situation, investment objectives, as well as any investment targets, limits or restrictions considered for the management of accounts. The sub-adviser only renders advice to Bancolombia with respect to the investment programs it carries out for its client. Typically, after selecting the appropriate sub-adviser based on clients’ needs, the sub-adviser will make available their portfolio strategies or models for our client to invest in. The Adviser will make the ultimate investment decision in their discretionary authority to manage the clients’ account(s). ➢ 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 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. ➢ 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. Bancolombia investment advisory agreements will not be assigned without client consent. Wrap Program Bancolombia currently maintains a Wrap Fee Program, which is described under a separate Brochure. Wrap fee programs are inclusive of most transaction costs and fees; therefore, the costs incurred will include brokerage costs and portfolio management whether on a discretionary or non-discretionary capacity. Bancolombia will receive the differential of the Wrap fee minus brokerage costs. There is no difference in the investment process based on the fee program selected by the client. Assets Under Management As of December 31, 2023, Bancolombia had regulatory assets under management (“RAUM”) of $162,578,510 managed on a discretionary and non-discretionary basis. P a g e| 6