A. Description of Firm Berilium Technologies, Inc. (hereinafter referred to as “Berilium”, the “Adviser,” or the “Firm”) is a Delaware corporation, and is registered as an investment adviser with the Securities and Exchange Commission pursuant to Rule 203A-2(e) and will notice-file (register) when appropriate in those jurisdictions in which the Firm conducts investment advisory business and/or we may meet certain exemptions per statute. The Firm is owned by Alberto Guillen Salas, Cedric Priscal, and Dominic Spinozzi (please see Schedules A and B to the Firm’s Form ADV Part 1 for additional information concerning Firm ownership). Berilium personnel operate on a remote basis. Mr. Dominic Spinozzi serves as the Chief Compliance Officer (“CCO”) of the Firm. B. Types of Advisory Services Offered 1. Online Investment Management Services Berilium is an investment advisory firm that provides limited investment management services to its clients exclusively through digital technology solutions. Berilium’s services are provided via its proprietary interactive website at https://berilium.com. Berilium constructs its portfolios using closed-end funds such as Business Development Companies (“BDCs"), Interval Funds, and Tender Offer Funds which are regulated securities under the Investment Company Act of 1940. Berilium’s recommendations and the holdings of its model portfolios are limited to these types of investments. Berilium typically receives full discretion over client assets for fully managed accounts (“Discretionary Accounts”). Berilium can also offer services on a non-discretionary basis, as determined in the discretion of Berilium. Berilium seeks to help clients reach their financial goals by providing access to investment portfolios comprising of closed-end funds, which can offer diversification to traditional stock and bond portfolios. Berilium portfolio recommendations are tailored to each individual’s preferences, objectives, and risk tolerance. The Adviser will collect information from each client through a questionnaire (the “Questionnaire”) on its website. Each client will fill out this Questionnaire prior to signing up for Berilium’s investment management services. Through Berilium’s proprietary algorithm (the “Algorithm”) and based on the input provided by the client, Berilium will recommend a portfolio within the Adviser’s model portfolio offerings that the Firm believes aligns most closely with information and responses provided by the client (see additional details below). Clients will also see options for other investment portfolios offered by Berilium. Clients have the ability to override the Algorithm’s recommendation by selecting one of the other model portfolios offered by the Adviser. The Adviser’s personnel oversees the function of the Algorithm. In the case of clients who use Berilium’s services on a non-discretionary basis, Berilium will only propose one recommended portfolio. The model portfolios are designed to offer differentiated risk profiles, which are assessed based on projected volatility of returns, and downside risk mitigation which is evaluated as a function of both the likelihood and severity of potential losses. The lowest risk model portfolio is comprised of securities that hold income-generating assets which combined are designed to offer stability of returns and downside protection. The model on the high end of the risk spectrum will contain securities intended to generate returns through capital appreciation, offering a higher potential for investment profits but also higher expected volatility and risk of loss. Intermediate risk model portfolios will contain a combination of income generating assets (lower risk) and capital appreciation assets (higher risk) . The Adviser currently offers 10 model portfolios which Berilium has constructed to cover a wide range of risk profiles. Some, but not all, of the closed-end funds (i.e. listed BDCs) included in model portfolios trade on an exchange that allows for purchasing and selling of shares. For the less liquid and illiquid securities in the portfolio for which there is not a readily available market (i.e. non-listed BDCs, Interval Funds, and Tender Offer Funds), the Adviser will rely on the primary market for liquidity via share repurchases. Most securities held in Berilium portfolios fit into this category and are considered “semi-liquid”. For example, the Interval Fund structure requires a minimum of 5% of the Fund NAV to be available for repurchase on a quarterly basis. Generally, Berilium will seek portfolio investments that are able to meet redemptions on a quarterly basis (i.e. ability to fully redeem holdings any quarter); however, there is no guarantee that any such investment will be able to meet all redemption requests at the end of a quarter during which a request is made. If redemptions are not able to be met, portfolio trades would be spread over the following calendar quarters. Clients should not invest in Berilium portfolios if they need access to liquidity in the short term. As part of the investment analysis process, the Adviser assesses liquidity of the securities included in model portfolios. Ability to obtain liquidity is key consideration prior to identifying a security eligible (“Eligible Security”) to be part of portfolios for both traded and non-traded closed-end funds. Berilium discloses to clients and prospective clients the limited liquidity of the certain securities included in model portfolios and how it might negatively impact portfolio rebalancing and liquidation. At the time of determining whether a security is eligible the Berilium model portfolios, the Adviser will define levels for parameters such as bid-ask spreads and price discount/premium to NAV for actively traded securities, and share repurchase oversubscription levels for non- traded securities, at which buy and/or sell orders are halted and the eligibility of the security for model portfolios is reassessed. These features will be programmed into the Algorithm and are designed to act as safeguards in case of extreme market conditions. The Adviser’s approach is, when possible and practical, to incorporate safeguards into the Algorithm designed to protect client portfolios in case of extreme market conditions. The Adviser acknowledges that extreme market conditions are by nature unanticipated and that it is not possible or practicable to model every potential market stress scenario. As such, while expected to occur infrequently, in an extreme market condition, the Adviser will consider whether adjusting the output of the Algorithm is in the best interests of the clients. The actions taken in such a scenario could include updating the programming of the Algorithm to provide updated advice during extreme market conditions. Any such measures are expected to be defensive in nature and temporary in duration. What constitutes an extreme market scenario is determined at the discretion of the Adviser. The Adviser puts first its fiduciary duty to Clients above any of the Firm’s processes, including the Algorithm. For discretionary accounts, the client grants the Adviser full power to direct, manage, and change the investment and reinvestment of the assets in the account, the proceeds and any additions. The Adviser authority over the client’s investments includes discretionary authority to purchase and sell securities for the client’s account, to submit aggregated trade orders for the client and others in order to obtain best execution, and to give instructions concerning these transactions to the qualified custodian(s) with which the client’s account(s) are held. Client assets are allocated to certain investment offerings that align to the client’s corresponding target asset allocation within the recommended portfolio or client-selected portfolio. As a client deposits or withdraws funds from the client’s account, purchases and/or sales of securities are initiated periodically to rebalance the account in line with its target allocation. The Adviser will also rebalance a client’s account if the investment allocations deviate from the model portfolio in excess of certain thresholds established by Berilium or as otherwise specified by the client. The Adviser will seek to execute any such transactions promptly. In addition to the securities listed above, clients’ accounts generally will hold cash and/or be invested in cash equivalents, including but not limited to Treasury Bills and Money Market Funds, during short periods of time or in small amounts to facilitate operations such as paying for fees and portfolio rebalancing. Berilium does not provide: (i) comprehensive financial planning services, and its services are not a complete investment program as they do not take all of a client’s financial and other considerations into account when recommending a model portfolio; (ii) full portfolio advisory services. Berilium will provide investment advice only with respect to limited investments; Berilium’s clients will need to work with a different investment adviser in order to invest in additional asset classes not offered by Berilium (including but not limited to stocks and bonds); (iii) tax, accounting or legal advice; or (iv) custody of account assets. Clients are encouraged to consult with their tax advisor regarding any tax consequences related to their account. Berilium is an internet-based adviser registered with the SEC under reliance upon the Internet Adviser Exemption Rule 203A-2(e), as services are offered through

an interactive, web-based platform. Interested parties must access our secure website where they are offered our current Brochure (Form ADV Part 2A) and Form CRS disclosures that describe our advisory firm, its services, potential fees, as well as any material conflicts of interest that could potentially affect the rendering of unbiased and objective advice. The Brochure, Form CRS and privacy policy statement are delivered to clients before or at the time that they enter into an advisory contract with Berilium, and annually or any time there are material updates to these materials. The Brochure, Form CRS and privacy policy statement can also be downloaded by clients and prospective clients in portable document format (.PDF) or printed on your own local printer. Account holdings that are not part of the client’s portfolio will not be monitored by the Firm. If the client chooses to remove money from their Berilium advisory account(s), there may be additional fees charged by the custodian to liquidate or transfer those securities. It remains each client’s ongoing responsibility to promptly update their information within our system whenever there is a material change to the client’s situation and/or investment objective for the purpose of evaluating or revising investments. Berilium suggests that clients review the information within the Firm’s system and make any necessary updates no less than quarterly. 2. Online Sub-Advisory Services At times, Berilium will provide services under sub-advisory agreements with other non- affiliated third party registered investment advisers (“TPA’s”) who have engaged Berilium to manage holdings in their clients' portfolios. Berilium’s sub-advisory services are provided via Berilium’s proprietary interactive website. Both Berilium and the TPA will be granted trading authority in such situations. Berilium typically has discretionary authority over a portion of a sub advised client’s assets to buy and sell securities based on such client's individual needs. Fees for such sub-advisory services are negotiable and will be included as part of an agreement entered into by and between Berilium and the respective TPA. C. Tailored Services and Investment Restrictions 1. Tailored Advisory Services to the Individual Client Needs Berilium’s software employs several different model portfolios. The model portfolios are constructed using closed-end funds such as Business Development Companies (“BDCs"), Interval Funds, and Tender Offer Funds which are regulated securities under the Investment Company Act of 1940. The Eligible Securities are determined in the discretion of Berilium (see Item 8 for additional information regarding Methods of Analysis, Investment Strategies, and Risk of Loss). The Adviser tailors its advisory services to the individual needs of clients and through the collection of information through the Questionnaire, which enables the Firm to recommend appropriate model portfolio according to the risk tolerance and willingness of the client. The Questionnaire allows clients to impose reasonable restrictions on investing in certain securities or types of securities through providing comments in free text format. At the onset of the relationship, Berilium’s web-based software will require clients to respond to a sequence of online, interactive questions providing such information as their age, investment time horizon, income and/or liquid assets, the amount they plan to invest, among others. Berilium also inquires as to a potential client’s investment tendencies, as well as tolerance or appetite for risk. The Questionnaire includes an open-ended question where the client has the opportunity to include in a free text field any comments on their specific situations, including imposing reasonable restrictions on investing in certain securities or types of securities. Additionally, the Questionnaire requires clients to disclose their investor qualification status (accredited investor, qualified client, or qualified purchaser) which is considered by the Algorithm when selecting a suitable portfolio type. Based on the client’s responses to the Questionnaire, the Firm’s Algorithm will score each Client from 0 to 100 on two metrics: risk capacity and risk willingness. Those scores are utilized by the Algorithm to define the client’s risk profile and to identify one or more suitable model portfolio recommendations that are delivered to the client via the Firm’s website (from which the client is able to locally print if desired). The range given will include the “primary” recommendation (i.e., the model portfolio that most closely aligns with responses provided by the client), as well as an option for the client to “move” up or down by up to two model portfolios. This allows the client the ability to “fine tune” their model portfolio selection between the three options given. If the client were to be offered a model portfolio outside of the generated range and attempts to select it, the client will automatically be prompted with a warning that their selection does not match their indicated answers. The client will be required to acknowledge the warning before making any model portfolio selections that fall outside the range. Berilium’s Algorithm does not take a client’s personal tax situation into consideration when generating the model portfolio range. Clients are encouraged to consult with their professional tax advisor prior to making any selections. After initially creating a portfolio with Berilium, clients are contacted annually to report whether or not they have had any changes in financial situation or investment objectives. On a quarterly basis, clients are reminded to contact Berilium in the event there are any changes to their financial situation or investment objectives. Berilium enters into formal written agreements with its clients setting forth the terms and conditions under which the Firm will provide its advisory services (the “Investment Management Agreement”). The Investment Management Agreement sets forth the scope of the services to be provided and the compensation the adviser receives from the client for such services. Clients agree to accept electronic delivery of the Investment Management Agreement, disclosure documents, statements, and other materials. Berilium will comply with the non-exclusive safe harbor of Rule 3a-4. Specifically: 1. The Adviser will manage each client’s account on the basis of the client’s individual financial situation and investment objectives. Prior to account opening, the Adviser will collect information from clients through a questionnaire. Clients will also be able to communicate any considerations specific to their financial situation or objectives. 2. Clients will be able to update their client information provided to the Adviser any time, and consult with Berilium about such changes through Berilium’s website. Berilium encourages each client to promptly update their information whenever there is a material change to the client’s situation and/or investment objective for the purpose of evaluating or revising investments. On a quarterly basis, Berilium will notify clients in writing to review the information within Adviser’s system and make any necessary updates regarding their financial situation or investment objectives; and, on an annual basis, the Adviser will proactively try to determine if there have been any changes to the client’s financial situation or investment objectives. 3. Prior to account opening, clients are able to include in a free text field any comments on their specific situations, including imposing reasonable restrictions on investing in certain securities or types of securities. 4. Clients will receive at least quarterly a statement of all activity in the account (including transactions made, contributions and withdrawals pertaining to the account, fees and expenses charged to the account, and beginning and ending values). 5. Clients retain all rights of ownership in the underlying securities, including the right to engage in shareholder votes for securities in the account, to sue a security issuer (without being required to proceed jointly with other shareholders), to receive notification of trade confirmations and related documentation, and withdraw funds at any time. In accordance with applicable laws and regulations, Berilium will provide its disclosure brochure (ADV Part 2A), brochure supplement (ADV Part 2B), Form CRS Customer Relationship Summary and most recent Privacy Notice to each client prior to or contemporaneously with the execution of the Investment Management Agreement. The Investment Management Agreement with the client will continue in effect until terminated by either party pursuant to the terms of the Investment Management Agreement. Berilium’s fees (as discussed below) shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither Berilium nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of the Firm shall not be considered an assignment. D. Participation in Wrap Programs Berilium does not participate in any wrap programs at this time. E. Amount of Client Assets Managed As of the date of this Brochure, Berilium has $402,125 under management on a discretionary basis, and does not have any assets under management on a non-discretionary basis.