General BGV is a limited liability company organized in the State of Florida and registered as an Investment Adviser with the SEC. BGV is wholly owned by BGV Securities Holdings USA LLC, and indirectly owned by Grupo Financiero BG, S.A. Grupo Financiero BG, S.A. is 59% owned by Empresa General de Inversiones, S.A. who is domiciled in Panama. Description of Advisory Services BGV provides asset/portfolio management and financial advice to individuals, institutions and corporations. BGV’s investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in BGV’s investment advisory agreement. The Adviser’s discretionary and non-discretionary investment management services include the design, structure, and implementation of various personalized investment strategies for managed Accounts. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies, restrictions, time horizon and risk profile as described by each client. The overall advisory services offered by BGV fall within the following categories: ➢ Customized Discretionary Portfolios Adviser offers discretionary separately managed accounts that are customized to each client. Managed Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in Item No. 8 or customized for each client based upon varying factors. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. BGV tailors investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation or managed account agreement. Client profiles are created to reflect the stated goals and objectives according to the Investment Policy Statement (IPS). BGV’s clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to BGV in writing. ➢ Sub-Advisory Services Under a discretionary portfolio and based upon the stated investment objectives of the client, the Adviser can hire a sub-advisor to provide investment sub-advisory services for the benefit of its client(s). The Adviser will serve as the ultimate portfolio manager and will continue to render services to the client and, in addition, monitor and review the performance of the third-party sub-advisor and the performance of the client’s accounts that are being managed accordingly. P a g e| 5 In order to identify and select an appropriate sub-adviser, the Adviser will typically gather information about each client’s financial situation, investment objectives, as well as any investment targets, limits or restrictions considered for the management of accounts. The sub-adviser only renders advice to BGV with respect to the investment programs it carries out for its client. Typically, after selecting the appropriate sub-adviser based on clients’ needs, the sub-adviser will make available their portfolio strategies or models for our client to invest in. The Adviser will make the ultimate investment decision in their discretionary authority to manage the clients’ account(s). To assist

in the management of certain client accounts, the Adviser hires independent third-party asset management firms that manage various model portfolios and/or give assistance with the client portfolio strategy. In these instances, the client understands and acknowledges that the Adviser manages one or more of the model portfolios in the Account, that will be provided to client through a third-party provider and platform, and to which the Adviser will provide the client with proper access. If, as a result of its ongoing evaluation, the Adviser finds it necessary to either remove the portfolios managed by an investment manager or terminate the investment manager, then that action shall be carried out without the client’s prior consent. There is no communication, including consultations, between applicable clients and any of their accounts’ third party sub-advisors/investment managers. Client’s communications regarding client’s account should be directed to BGV. BlackRock Managed – Model Portfolios Program As part of this service, BGV utilizes a third party automated technology interface in providing online advisory services in the form of model portfolios provided to BGV by BlackRock Financial Management, Inc. (“BlackRock”) as the independent third party asset manager or sub-advisor. Upon providing necessary financial information, target investment objectives and answering a series of queries, customers are assigned a model portfolio that is aligned with their investing objectives and target goals. BGV currently offers the Model Portfolio Program in conjunction with BlackRock, based on different profile types, including: Short Duration, Income, Conservative, Moderate, Aggressive and Equity.The Models offered through this Program are as follows: ▪ Target Allocation UCITS All Accumulating Objective: Combines strategic long-term views with tactical shorter-term market opportunities. Asset Classes: Fixed Income, Equities and Non-Traditional Rebalances: 4-6 times a year Underlying universe: Up to 25 underlying ETFs ▪ Long Horizon UCITS All Accumulating Objective: Long term focus with Strategic Views Asset Classes: Fixed Income and Equities Rebalances: 1-2 times a year Underlying universe: Up to 10 underlying ETFs ➢ Other Non-Discretionary Advisory Services Adviser provides non-discretionary advisory services to all types of clients in accordance with a non- discretionary advisory agreement between Adviser and the client. Each agreement typically defines the P a g e| 6 services to be provided and if a fee is charged, the fees will also be agreed to in the advisory agreement. Adviser also provides recommendations and research regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs and such advice may be provided to accounts with assets maintained at various third parties. Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. BGV investment advisory agreements will not be assigned without client consent. Wrap Program BGV does not currently participate in any Wrap Fee Programs. Wrap Fee Programs are inclusive of most transaction costs and fees; therefore, the costs incurred will include brokerage costs and portfolio management whether on a discretionary or non-discretionary capacity. Assets Under Management As of February 29, 2024, BGV had regulatory assets under management (“RAUM”) of $112,131,802 managed on a discretonary basis.