BUSINESS AND OWNER 33 Capital Management LLC (referred to as “33 Capital”, “we”, “us”, “our”, firm” or “advisor”) is a Delaware limited liability company which was formed in 2023 and has its principal place of business in Greenwich, Connecticut. It commenced operation as an investment adviser in 2023. The firm is wholly owned by 33 Capital Management, Ltd., which in turn is majority owned by Zuaiter Capital Holdings, LLC. The Chairman is Abbas “Eddy” Zuaiter. ADVISORY SERVICES OFFERED INVESTMENT SOLUTIONS 33 Capital works closely with each client to identify their personal and business goals, investment objectives, risk tolerance, liquidity needs, financial situation, and estate/succession planning priorities to formulate customized investment solutions. Our solutions are centered on asset allocation, manager selection, asset selection, risk management, and strategic advice. We start with a model, an “all-seasons” strategy to safeguard our clients’ wealth while targeting risk-adjusted returns. Then, 33 Capital works closely with each client to formulate a customized Risk/Return Framework. Using the Risk/Return Framework as a guide, we build out the investment solution for the client. Investment solutions are primarily offered on a discretionary basis. 33 Capital will monitor client account(s), make trades, and rebalance, as appropriate to the client’s investment strategy. Please see Item 16 – Investment Discretion for more information. Generally, when creating a portfolio, we will utilize stocks, bonds, options, commodities, currencies, other derivatives, private placements (including equity and debt), exchange traded funds (ETFs), mutual funds, sub-advisors, and third-party managers. Additionally, if a portfolio has legacy or non- model positions, we will assist our clients in managing these holdings. This assistance can be provided on a discretionary or non-discretionary basis. Additionally, for those clients that meet the necessary eligibility thresholds, 33 Capital will provide non- discretionary consulting services related to the purchase and sale of interests in unaffiliated private placement offerings. This will require that the client be an “accredited investor”

as defined in Section 501(a) of Regulation D under the Securities Act of 1993, as amended; a “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940, as amended, or a “qualified purchaser” within the meaning of Section 2(a)(51) of the Investment Company Act of 1940, as amended. When providing non-discretionary consulting services related to the purchase and sale of interests in unaffiliated private placement offerings, we will provide the client with a recommendation. The ultimate investment decision shall remain with the client. CONSULTING MACROECONOMIC RESEARCH/ANALYSIS Insights into the factors underpinning market behavior, as well as research into prospective flows of funds, fiscal and monetary policy, and the global macroeconomic landscape. BUSINESS STRUCTURING We support our clients across a range of business scenarios, including the acquisition and divestiture of assets, public listings, recapitalization, and other corporate events. SUCCESSION AND ESTATE PLANNING We have extensive experience supporting clients together with their accountants and attorneys in efficiently managing tax, legal, familial, and other considerations inherent in cross-generational planning. BESPOKE ADVICE Personal guidance across a range of areas, including dispute resolution, negotiation, and other concerns around wealth transference. 33 CAPITAL MANAGEMENT LLC| Form ADV 2A | Page| 5 OTHER CONSULTING 33 Capital has been engaged by another financial institution to contribute ranking of securities within a specific equity index universe. CLIENT NEEDS AND RESTRICTIONS Our investment advice is tailored to each client, as described above. 33 Capital allows clients to impose reasonable restrictions on the management of the account(s). Reasonable restrictions, including special instructions and limitations, regarding the portfolio management of the account(s) must be provided in writing. Clients are responsible for notifying us of any updates regarding their financial situation, investment objectives, or risk tolerance and whether they wish to impose or modify any existing investment restrictions. WRAP FEE PROGRAMS 33 Capital does not participate in any wrap fee programs. ASSETS UNDER MANAGEMENT As of this filing, we have $88,300,000 in discretionary and $15,000,000 in non-discretionary regulatory assets under management.