A. Description of Advisory Firm Slater Investments Limited (hereinafter “Slater Investments”) is a Limited Liability Company. The firm was incorporated in England and Wales in October 1993, and the principal owner is Northglen Investments Limited. It is authorized and regulated by the UK Financial Conduct Authority in addition to the US Securities and Exchange Commission. B. Types of Advisory Services Portfolio Management Services Slater Investments offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Slater Investments creates an Investment Guidelines for each client which outlines the client’s investment objectives and investment restrictions. Portfolio management services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring Slater Investments evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Slater Investments will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Slater Investments seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Slater Investments’ economic, investment or other financial interests. To meet its fiduciary obligations, Slater Investments attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Slater Investments’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Slater Investments’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis

over time. Services Limited to Specific Types of Investments Slater Investments generally limits its investment advice to equities. Slater Investments may use other securities as well to help diversify a portfolio when applicable and subject to the Investment Guidelines of the individual client. Written Acknowledgment of Fiduciary Status When we provide investment advice to you, we are fiduciaries. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Slater Investments offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Guidelines which outlines each client’s current situation including the client’s investment objectives and investment restrictions. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs or regulatory requirement. However, if the restrictions prevent Slater Investments from properly servicing the client account, or if the restrictions would require Slater Investments to deviate from its standard suite of services, Slater Investments reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Slater Investments does not participate in wrap fee programs. E. Assets under Management As of December 31, 2023, Slater Investments had $1,760,008,997 of assets under management on a discretionary basis.