A. Advisory Business Kensys, Ltd (referred to herein as “Kensys,” “Firm,” “we,” and “our”) is an independent investment advisory firm registered as an internet-only investment adviser with the U.S. Securities and Exchange Commission (“SEC”). An internet-only investment adviser provides investment advice to almost all of its clients exclusively through an interactive website. The company was formed in 2020 as a Limited company in the United Kingdom and is currently owned by Stéphane Renard and Edwy Zoonekynd primarily. For more information about them please see the brochure supplement (Form ADV Part 2B). B. Portfolio Management Services Portfolio management services are provided on a discretionary basis. This means the client grants the Firm ongoing and continuous discretionary authority to make, and to enter orders with a broker/dealer for the execution of, its investment recommendations in accordance with the client’s investment profile without the client’s prior approval of each specific transaction. All transactions in the clients’ account shall be made in accordance with the directions and preferences provided to the Firm by the client. The client will execute instructions regarding the Firm’s trading authority as required by each account custodian. Clients engaging us will be asked to grant such authority upon signing our Investment Advisory Agreement. If a client engages us to perform portfolio management services, Kensys’ website will ask a series of questions designed to determine suitability of different investment options for a particular client. Kensys determines a suitable proposed investment plan by performing a review of each client’s individual account and suitability parameters. This review may include the client’s preferred investment universe, investment objective, risk profile, preferred investment ethos, and preferred strategy type, as well as financial situation. Based on client suitability parameters, Kensys will design, revise, and reallocate a client’s custom portfolio. After a suitability analysis is conducted, Kensys utilizes the information from the questionnaire to create portfolio recommendations customized to Clients’ risk tolerance, financial parameters and investment objectives. For each Client’s portfolio recommendations, Kensys considers the Client’s employment status, income, investment goals and reasons to invest, time horizon and net assets. Kensys also specifically looks at Client’s answers to questions about desired investment universe, investment style, investment ethos, and alternative vs. traditional strategy preference. Kensys evaluates each Client’s responses and proposes a portfolio plan. For example, if a Client is looking for a less aggressive, mid-cap universe, traditional investment strategy that follows a value style with special consideration to environmental concerns, Kensys creates a portfolio with these 5 factors and other suitability factors in mind. The portfolio recommendations created by Kensys for each Client are based solely upon the information provided by the Client through the Firm’s website. As

such, the suitability of the investment plan recommendations is limited by and relies on the accuracy and completeness of the information provided by the Client. Kensys does not capture any additional information not covered in the questionnaire in making its risk assessment and providing its investment advice. Clients’ portfolio is invested through the client’s own brokerage account(s) – Kensys is able to operate buying/selling of securities within these accounts, but cannot control the deposit or withdrawal of cash. The types of restrictions a Client may impose on their recommendations include the degree of risk level (concentrated, balanced, diversified), investment universe (Small-Mid cap or Large cap), Investment style (Value, Dividend, Growth, Momentum, Core), Investment ethos (ESG impact with footprint and exclusions), and strategy type (Traditional or Alternative) based on the information provided in the questionnaire. Clients are obligated to update their information through the Firm’s website promptly if there are changes to their financial situation, goals, objectives, personal circumstances, time horizon or if other relevant information changes or becomes available. A Client must connect an existing securities brokerage account and provide discretionary authority over that account to Kensys. Brokerage accounts, agreements, and order processing will be conducted through the Client’s own existing brokerage relationships. Kensys will not store secure brokerage account information (like the password) but will rather store a related token that allows it to connect securely to the brokerage account and execute trades. Certain transactional costs will still be paid by the Client, including transaction fees for the purchase or sale of securities, expenses related to the use of margin, wire transfer fees, the fees (including expense ratios) charged to shareholders of mutual funds or ETFs, short-term redemption fees, mark-ups and mark-downs, spreads, odd-lot differentials, paper statement fees, fees charged by regulatory agencies, exchange fees, American Depositary Receipt fees, transfer taxes, fees required by law. These fees may be charged by Client’s brokerage account provider, but not charged by Kensys. A client’s portfolio may be comprised of publicly-traded stocks or ETFs through US markets. We will also monitor the client’s accounts to ensure that they are meeting the client’s investment objectives and other requirements. If any changes are needed to the client’s investments, we will make the changes or recommend the changes to the client. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash or some liquid alternative. The client will receive written or electronic confirmations from the client’s account custodian after any changes are made to the client’s account. The client will also receive statements at least quarterly from the client’s account custodian. Our Investment Advisory Agreement outlines the responsibilities of both the client and Kensys.