A. Description of the Advisory Firm. SAL was established in 2019 as a limited company organized under the laws of the Cayman Islands with a principal place in New York, New York. SAL is a wholly-owned subsidiary of Secfi, Inc. (“ Secfi ”), a Delaware corporation established on February 9, 2017. Secfi’s largest shareholders are co-founders Frederik Mijnhardt and Wouter Witvoet. Secfi operates and manages the Secfi.com platform (the “ Platform ”) which seeks to identify persons holding unregistered shares of stock in private technology-enabled companies who are seeking liquidity (“ Shareholders ”) as well as provide Shareholders with educational tools regarding private company options and equity. The Platform serves as an online portal, whereby Shareholders seeking liquidity may provide details regarding their stock holdings so that they may ultimately be matched with investors that desire exposure to such holdings (the “ Shares ”), typically in late-stage and growth-stage private technology-enabled companies (each, a “ Portfolio Company ”). SAL is an affiliate of Secfi Securities, LLC (“ Secfi Securities ”), a San Francisco-based Financial Industry Regulatory Authority (“ FINRA ”) member and SEC-registered broker-dealer (the “ Broker ”). Secfi Securities is also wholly-owned by Secfi. B. Types of Advisory Services. SAL engages in two distinct advisory business lines. It provides discretionary and non-discretionary investment advisory services to institutional investors. SAL also offers financial planning and wealth management services to individual clients. Some financial planning and wealth management clients are Shareholders that use the Platform. 1. Discretionary and Non-Discretionary Institutional Investment Advisory Services. SAL serves as either discretionary investment manager or non-discretionary sub-adviser to private investment funds that seek to acquire exposure to Portfolio Company Shares by entering into variable prepaid forward contracts with Shareholders (“ Forward Contracts ”). The forward contracts are structured to preserve the applicable private placement exemptions under the Securities Act of 1933, as amended, pursuant to which the Portfolio Company issued those shares, and potentially acquired by Shareholder directly from the Portfolio Company in a primary issuance of Shares. As used herein, the term “ Managed Fund ” means private investment funds to which SAL serves as investment manager that purchase Forward Contracts and “ Advised Fund ” means private investment funds to which SAL serves as non-discretionary sub-adviser solely with respect to the recommendation, negotiation, and execution of Forward Contracts. Collectively, Managed Funds and Advised Funds are “ Forward Contract Funds .” SAL is the manager (the “ Manager ”) of the Sonoma 2022 Fund and the Rioja Fund I (collectively, the “Funds”). The Manager is responsible for handling accounting, recordkeeping, custody of Funds Assets, distributions, investor communications and compliance, and other matters consistent with the Fund’s offering documents and/or governing documents (“ Fund Documentation ”), including all management decisions regarding the business of the Funds. Various managers serve as Manager to the Advised Funds. Each Manager is responsible for handling accounting, recordkeeping; custody of Advised Fund assets, Advised Fund distributions, investor communications and compliance, and other matters consistent with the relevant Advised Fund Documentation, including all management decisions regarding the business of the particular Advised Fund. 2. Financial Planning and Wealth Management Advisory Services. Financial Planning. SAL helps clients make important personal and financial transitions in their lives by helping them plan, protect and grow their assets, provide for their families and achieve their personal and financial objectives. Depending on the complexity of a client’s personal needs and desires, this will be accomplished by providing some or all of the following financial planning services: ● Stock Option Exercise Planning. Educating clients on potential value, tax considerations, and exercising possibilities of current and upcoming equity compensation. This involves modeling multiple exercise scenarios that include possible costs, taxes, and profits. ● AMT/Income Tax Planning. Recommending tax optimization strategies specific to a client’s personal situation and coordinating with a client’s accountant or tax advisor regarding the projection of the client’s estimated tax liability, withholdings, estimated quarterly payments and others. ● Pre-Exit Liquidity Planning. Modeling multiple exit scenarios and discussing tax and financial planning considerations within each scenario. This involves educating the client on diversification benefits, tax implications, and potential lockup considerations upon an exit event or when considering a secondary sale

or tender offer. ● Post-Exit Sales Strategy. Providing a customized sales plan based on the client's specific timeline, upcoming goals, and risk tolerance. The planner will assist with the coordination of settling financial contracts, transferring shares into an individual investment account, and investment implementation strategy for post-exit sales proceeds. ● Goal-Based Life Planning. Assisting clients in identifying their life goals (i.e. buying a home, paying off student loans, etc.) and determining the costs to pursue these goals. The planner will assist clients in taking an inventory of current assets and then work with clients to develop a plan to make their future goals financially attainable. ● Cash Flow Analysis. Analyzing a client’s current income and expenses (including income taxes) and recommending a specific course of action with regard to the appropriate savings necessary to fund the client’s various financial objectives. ● Retirement Analysis. Utilizing retirement income computer models to project cash flow needs and income available for retirement, analyze the impact of inflation on retirement income and evaluate client's retirement plan pay-out options and maximum benefits available through any employee benefit programs. If appropriate, coordinating client's retirement income and employee benefits with the asset allocation and investment strategy recommended by SAL. ● Asset Protection and Estate Planning Coordination. Advising clients on asset protection techniques and coordinating with the client's estate planning attorney in order to develop and implement a comprehensive estate plan. This plan may involve the implementation of wills, revocable living trusts, irrevocable life insurance trusts, durable powers of attorney, health care powers of attorney and other estate planning techniques. This type of planning normally will require significant involvement of the client's attorney and accountant to assure optimal implementation of the plan. If a client chooses to implement a SAL financial plan, SAL may recommend the services of other professionals and/or that of its affiliates. Accordingly, clients are advised that a conflict of interest exists if SAL recommends its own services or that of its affiliates. Clients are under no obligation to act upon any of the recommendations made by SAL or its supervised persons under a financial planning arrangement and/or engage the services of any such recommended professional or affiliate. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of SAL’s or its supervised persons’ recommendations. SAL will cooperate with any attorney, accountant, broker or other adviser chosen by the client regarding implementation of any such recommendations. Wealth Management. SAL offers wealth management services to individual clients, some of whom are expected to be Shareholders (the “ Wealth Management Clients ”). Such wealth management services involve helping Wealth Management Clients develop greater insight about the financial markets and designing their personalized investment strategy. Wealth Management Client portfolios will primarily use mutual funds, Exchange Traded Funds (“ ETFs ”) and Separately Managed Accounts (“ SMAs ”) and individual stock options; however, SAL will use other vehicles where it is appropriate. SAL creates an investment policy statement for each Wealth Management Client, that outlines the client’s current risk tolerance profile and details the inputs to the asset allocation and investment strategy decision. Wealth Management Client services include, but are not limited to, investment strategy, asset allocation, risk tolerance, personal investment policy, asset selection, rebalancing, and regular portfolio monitoring, along with on-going financial planning services. C. Client Tailored Services and Client Imposed Restrictions. For Managed Funds, the investment objective and appropriate level of risk, and any applicable investment limitations or restrictions, and set forth in that Managed Fund’s Fund Documentation. For Advised Funds, SAL’s advisory services are limited exclusively to providing non-discretionary investment advice with respect to Forward Contracts. Accordingly, SAL does not have discretion to make investments on behalf of such fund save for recommending, facilitating and negotiating Forward Contracts consistent with the general strategy and investment guidelines of the relevant fund. SAL tailors its advisory services to the Advised Funds consistent with their investment objectives and guidelines. For Wealth Management Clients, an investment policy statement outlines client-specific investment strategies, restrictions, and limitations. D. Participation in Wrap Fee Programs. SAL does not participate in wrap fee programs. E. Assets Under Management. As of December 31, 2023, SAL manages approximately $122,066,189 on a discretionary basis and $34,250,000 on a non-discretionary basis.