Description of the Firm MAVROS CAPITAL MANAGEMENT, LLC (“MAVROS” or the “Firm”) is a California-based investment adviser. The Firm was founded in 2023 as a Delaware limited liability company. The Firm’s managers are Isaac Richard III, David Russell and Michael Germain, and the Firm’s sole owner is Mavros Capital Group, Inc. Mavros Capital Group, Inc. is owned by (1) Mejia Capital Group, LLC, which is 100% owned by Lisette Mejia, (2) Bouyer & Co., LLC, which is 100% owned by David Russell, and (3) Michael Germain. Description of Services Offered Mavros may provide investment advisory services on a discretionary and non - discretionary basis, as described below. Investment Management MAVROS provides portfolio management services primarily to individuals, high net worth individuals or families, as well as trusts, foundations, endowments, non -profit organizations, retirement plans and plan sponsors, and other business entities herein referred to each as a “Client” and collectively the “Clients.” As a fiduciary, MAVROS acts in the Clients’ best interest and fulfills its obligation by working closely with Clients to identify and understand their investment objectives while building a long-term relationship. Our portfolio management services may include:
• Monitoring of accounts on an ongoing basis.
• Providing ongoing advice regarding strategic investment opportunities.
• Sourcing, evaluating, selecting and monitoring alternative private fund managers.
• Integrating existing holdings, including real estate and non-liquid assets, into investment objectives
• Developing diversification strategies for low basis securities.
• With respect to certain Clients that are “insiders” of publicly traded companies, assisting in the development of 10b5-1 plans. Mavros tailors its advice to clients. In order to provide tailored advice to Clients, MAVROS works with Clients to develop a formal Investment Policy Statement (“IPS”) that reflects the Client’s investment objectives, financial circumstances (including income, non-liquid assets and real estate assets), time horizons and liquidity requirements, risk tolerances, and other important information required by MAVROS or provided by a Client. Clients can also identify investment restrictions and other bespoke requests in the IPS which Mavros will comply with. Clients must inform us of any changes to their financial circumstances, investment objectives or risk tolerance, or of any modifications or restrictions that are imposed on the management of the client's account. An IPS will typically be applicable to an entire household. Once we construct an IPS for a client, we will monitor the portfolio's performance on a periodic (typically quarterly) basis unless otherwise agreed, and will make adjustments and reallocations as necessary due to changes in market conditions and the client's circumstances, as communicated to us. Mavros primarily invests Client assets in stocks, money-market fund shares, certificates of deposit, and other cash instruments, exchange-traded and over-the-counter securities, passively and actively managed mutual funds and index funds, debt securities, municipal securities, options, variable(no- load) annuity products, and alternative private investments. Clients may impose reasonable restrictions and guidelines on investing in certain securities, types of securities or industry sectors. We expect all such restrictions to be timely communicated to us. Client restrictions and guidelines may negatively affect investment performance. MAVROS may also engage one or more third-party sub-advisers (“Sub-Adviser”) to manage a portion of client assets if it is deemed to be in the best interest of a Client. MAVROS will generally execute a sub-advisory agreement with each Sub-Adviser. If a Sub-Adviser is granted any trading authority, it will be pursuant to a limited power-of- attorney and over only those assets that MAVROS directs the Sub-Adviser to manage. Where Sub-Advisers are granted trading authority, such advisers may be authorized to buy, sell and trade on behalf of a Client’s account and to give instructions, consistent with their authority, to the relevant broker-dealer/custodian. Fees charged by Sub-Advisers will be disclosed to Clients in account statements provided by the custodian and will be deducted from the Firm’s advisory fee. However, Clients may incur transaction and custodial fees on assets managed by a Sub-Adviser. Mavros will conduct due diligence into each Sub- Adviser and will monitor and review all sub-advised accounts on a periodic basis. MAVROS may also recommend Clients to enter into a separate advisory relationship with a third- party investment adviser (“Independent Managers”). In such cases, Clients will need to enter into a separate advisory agreement with the Independent Manager, and that agreement will define the scope of the Independent Manager’s services to Clients. Fees charged by Independent Managers will be disclosed to Clients in account statements provided by the custodian and will be separate from and additional to the Firm’s advisory fee. Clients may also incur transaction and custodial fees on assets managed by an Independent Manager. Mavros will conduct due diligence into each Independent Manager and will monitor and review all independently managed accounts on a periodic basis. Mavros’ goal is to assist certain clients in addressing their wealth management needs and has launched the Mavros Family Office Services team. To this end, MAVROS will identify a select group of independent professional firms which can provide certain outsourced family office services (e.g., tax advisory, trust and estate planning, bill pay etc.) to Mavros’ clients. Mavros may recommend such outsourced family office service providers to Mavros clients, at a no cost basis. Neither Mavros nor its employees will earn any direct compensation as part of such recommendations, although an independent professional firm might decide to refer prospective clients to Mavros, on his/her own accord. In addition, Mavros employees might be clients of certain of these professional firms in their personal capacity. In fact, some recommendations might be based, in part, on such personal experience. Neither MAVROS, nor any of its employees, however, provides legal or tax advice, and Clients should consult with their own tax and legal counsel for advice specific to them. A Client who wishes to learn more information about this program is encouraged to reach out

to his/her service team. If MAVROS advises Client to enter into a sub-advisory or independent manager agreement, Clients may be asked to open new custodial accounts with a custodian to separate the sub-advised or independently managed assets from assets advised directly by MAVROS. Financial Planning Services Financial planning is an evaluation of a Client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans while also understanding personal values, goals, and objectives. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the Client. MAVROS will provide financial planning and consulting services to Clients, as outlined in a Financial Planning Agreement executed by Client and MAVROS. Services are offered in several areas depending on the Client’s goals and objectives. Generally, such financial planning services will involve a written report, which provides the Client with a detailed financial plan to assist the Client in achieving his or her financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to: financial position, risk tolerances, capital appreciation objectives, income and liquidity requirements, tax considerations, employee benefits, investment analysis, insurance analysis, retirement analysis, death and disability considerations, investment horizon, and estate planning. Retirement Plan Services MAVROS engages with retirement plan Clients in a wide range of capacities. MAVROS advises plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), as an ERISA Section 3(21) fiduciary providing investment recommendations to the plan sponsor and/or plan trustee, or as an ERISA Section 3(38) “investment manager” with discretionary authority to make investment decisions on behalf of the plan. In addition to allocating plan assets and portfolio management, these services can include assistance in setting up an Investment Policy Statement for the portfolio, managing cash and liquidity needs, selecting professional record‐ keepers, administrators and custodians, and providing quarterly or annual reviews of the portfolio’s performance and our outlook on financial market conditions. MAVROS also provides advisory services to clients with respect to their retirement accounts, such as individual retirement accounts (“IRAs”). The Firm has adopted policies and procedures designed to comply with the ERISA fiduciary standards when advising retirement asset rollovers as set forth in the Department of Labor Prohibited Transaction Exemption 2020-02. Donor Advised Fund Services Some Mavros Clients will establish donor advised funds through various third -party charitable programs (each, a “Charitable Platform”). The funds will be managed in accordance with the specific investment policies and guidelines of the applicable Charitable Platform. Clients will establish a donor advised account, transfer funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred into an account opened on a Charitable Platform. The funds remain in such account until the Client designates a charity, an amount and a date to donate to such charity. Under independent advisor programs established within each Charitable Platform, donors nominate an independent investment adviser, which could include MAVROS, to manage accounts established on the Charitable Platforms. If nominated, MAVROS will manage the donor’s account pursuant to investment guidelines established by each Charitable Platform. Reporting on Non-Advisory Assets As a service to certain Clients, Mavros provides consolidated reporting on Client non- advisory assets. Non-advisory assets are assets independently owned by Clients and held- away. Mavros will not have any custody or control of such assets, and the assets will not be included as assets under management by Mavros. These non-advisory assets will not be subject to Mavros’ portfolio management or monitoring, and Mavros will not provide any investment advice with respect to such assets. Mavros will report the value of the non- advisory assets to the Client, based solely on the valuations received by Mavros from the third-party managers of the non-advisory assets or other third parties such as the custodian of the non-advisory assets. Mavros will not have any obligation to independently examine, confirm or revise non-advisory asset valuations. Any fees or costs associated with maintaining non-advisory accounts will be owed to the third- party services that offer these accounts and will be governed by the terms and conditions of third parties. Mavros has no role in negotiating or formulating the provisions of such third-party terms and conditions. The success of investments conducted through third parties may vary. Ancillary Services for Ancillary Assets As a service to Clients, MAVROS may provide ancillary services as well as reporting on ancillary assets as agreed upon by the Client and MAVROS under a separate Ancillary Services Agreement. Pursuant to such an agreement, MAVROS shall provide the Client quarterly valuation reports on such ancillary assets. The value of such assets will be based solely on, at the Client’s election, either (i) the valuations received by MAVROS from third parties or (ii) at cost as reported by the Client. Mavros shall not have any obligation to independently examine, confirm or revise the valuation of the ancillary assets. The Client shall pay Mavros an annual services fee that is specified in the Ancillary Services Agreement, which will be paid quarterly in advance in accordance with the Client’s IMA. MAVROS may assist certain clients with the formulation of a 10b5 -1 trading plan. Rule 10b5-1 of the Exchange Act allows ‘insiders’ of public company to trade securities of their company in compliance with insider trading laws through the development of a pre- determined trading plan that provide for sales of securities according to pre-determined parameters. MAVROS may provide this service pursuant to an Ancillary Services Agreement or as part of its normal investment management services. Assets under Management (Regulatory Assets Under Management) As of August 5, 2023, Mavros has total regulatory assets under management of $0.