The Firm and Related Companies Galapagos Advisory, LLC (“Galapagos Advisory”, the “Adviser”, or the “Firm”) is a Delaware limited liability company that was organized in May 2022. Galapagos International LLC (“Galapagos Holdings”) is the managing member and owner of Galapagos Advisory. Galapagos Holdings is a Delaware limited liability company that is owned 75% owned by Galapagos Capital Control Participações SA and 25% by Galapagos Capital Partnership Participações S.A. (the “Parent Companies”), which have their principal places of business in São Paulo, Brazil. The Parent Companies and their affiliates have operated as a privately held Brazilian investment management group that offers asset management, wealth management, and debt capital markets to Brazilian and international investors since 2019. Galapagos Holdings also owns and serves as the managing member of Galapagos Global Capital Management LLC (“Galapagos Investment Management”), a Delaware limited liability company organized in February 2023 that is also registered as an investment adviser. Bruno de A. Carvalho currently serves as the Manager and a Managing Director of both the Adviser and Galapagos Investment Management. Galapagos Investment Management currently offers “Macro” and “Real Estate” investment strategies, principally through investments by private funds that it or a partner manages. The Firm expects to recommend or direct investments by its clients in strategies and funds (collectively, “Galapagos Funds”) managed by Galapagos Investment Management or other Parent Company affiliates (collectively, the “Galapagos Group”), with appropriate disclosures to the client. See also “Investments in Securities Issued / Marketed by Affiliates” and Items 10 and 14 below. The Firm and Galapagos Investment Management share offices and have their principal place of business in Miami, Florida. Advisory Services Offered Galapagos Advisory provides investment advisory services primarily to high-net- worth individuals, corporations, trusts, and institutional clients. Its client base primarily consists of domestic and international clients with a focus on the Brazilian market. Galapagos Advisory’s investment management services include the design, structure, and implementation of investment strategies for advisory accounts managed on a discretionary or non-discretionary basis, as well as customized services that may include both or either of discretionary or non- discretionary management with respect to specified client accounts and advice and reporting with respect to client-directed assets. An Investment Advisory Agreement (each, a “Client Agreement”) executed with each client sets forth the terms and conditions of the engagement and other important disclosures and defines the services to be provided and advisory fees to be paid by the client. A Client Agreement will be effective upon acceptance by the client and Galapagos Advisory. Accounts are managed in accordance with each client’s investment objectives and risk profile. Clients will generally select one or more of the portfolio strategies listed below. A detailed description of each of the strategies is included under Item 8 of this Brochure. 1. Conservative 2. Income 3. Bond 4. Balanced 5. Growth Client portfolios will typically include, as appropriate, a wide range of assets and securities in a variety of markets including stocks, bonds, time deposits, Exchange Traded Funds (“ETFs”), mutual funds, hedge funds, private equity funds and other alternative investments, commodities, and currencies. For certain clients the Firm will offer portfolios with a concentration in alternative investments and structured products. The Firm may also initiate forward foreign exchange transactions, provided they serve to hedge an existing investment and as long as this does not subject the Firm to having to register with the National Futures Association under the Commodity Exchange Act as a Commodity Trading Adviser. Tailored Relationships The Firm offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon each client’s investment objectives and risk tolerance as set forth in the client’s Client Agreement or other documents. Clients may impose reasonable restrictions or guidelines on the types of investments in their account. However, if the restrictions prevent the Firm from properly servicing the client account, or if the restrictions would require the Firm to deviate from its standard suite of services, the Firm reserves the right to end the relationship. Use of Subadvisors / Third Party Managers The Firm may select affiliated or unaffiliated third-party managers to serve as subadvisors and assist in actively managing all or a portion of a client’s portfolios and may recommend or direct investments by its clients in Galapagos Funds or other private funds. The specific advisory services under which a client or the Firm (acting on behalf of a client) engages a subadvisor will be set forth in a separate written agreement with and the designated subadvisor, and private fund investments will be made pursuant to a client’s subscription agreement or other written direction by a client. Fees charged to the Firm’s clients by the subadvisors or borne by a client as an investor in a private fund are in addition to the Firm’s management fees depend on several factors, including the size and type of the investment, trading strategy, and degree of risk, except as described below in “Investments in Securities Issued / Marketed by Affiliates” with respect to Galapagos Funds. Subadvisors may charge performance fees on realized or unrealized gains in their portfolio. The Firm does not receive any portion of fees, commissions, or other charges from subadvisors, brokers, or other service providers. The Firm does not receive fees or commissions for recommending any security, investment, or subadvisor. Clients will be provided with the subadvisor’s Brochure and/or other written disclosure documents and fee schedule. Please refer to the subadvisor’s Form ADV or disclosure documents for additional information regarding fees and other important information. The Firm evaluates a variety of information about subadvisors and private funds it recommends. The Firm analyzes subadvisors and private fund managers based upon their investment strategies, experience, performance track records, reputations, and fees. To the extent possible, the Firm seeks to assess each subadvisor’s and private fund manager’s investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. The Firm also takes into consideration the subadvisor’s or private fund manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. On an ongoing basis, the Firm monitors the performance of those private funds and the accounts being managed by subadvisors. The Firm seeks to ensure the subadvisor and private fund strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Galapagos Advisory’s due diligence of subadvisors and private funds also includes a review of subadvisors and private fund manager publicly available disclosure documents, materials supplied by the subadvisors and private fund managers themselves and other third-party analyses from sources the Firm believes to be reliable. The Firm also offers sub-advisory services to our affiliates as well as to independent investment advisors and/or family offices in Brazil. Investments in Securities Issued / Marketed by Affiliates The Firm expects to recommend or invest client assets in securities or other investment products (including Galapagos Funds) that Galapagos Group members issue, promote, underwrite, manage, or serve as a general partner, and in which Galapagos Group members have a material financial interest. Recommending securities or other investment products described above creates an inherent conflict of interest between the interests of the Firm’s clients and those of Galapagos Group members including the Firm. Galapagos Advisory has a fiduciary duty to act in its client’s best interests and manage this conflict of interest and has in place policies and procedures to ensure that investment selection and recommendations are made based on what is suitable and in the best interests of its clients with disclosures that allow clients to make informed decisions. Clients are under no obligation to accept recommendations to engage the services of affiliated companies or invest in products issued by the Firm’s affiliates. See Items 10, 12 and 14 below for additional information regarding the Galapagos Group and the Firm’s brokerage practices. Wrap Fee Programs We do not sponsor or manage a Wrap Fee Program. We will, where appropriate, use a third-party sponsored wrap account to manage a client’s portfolio. Portfolio Consolidation Services Galapagos also provides portfolio consolidation services designed for clients using multiple custodians and / or asset managers. This service provides an overview of the client’s consolidated portfolio and several analytical tools to help optimize asset allocation, risk, performance, and cost. Reporting is customized to the client’s needs and requirements. The portfolio consolidation offered by Galapagos is part of its services and is a non-investment advisory product or service. Also see Item 13 Consolidated Reports. Consulting, Financial Planning, Reporting, and Special

Projects Clients may engage the Firm for consulting, financial planning, reporting, and special projects. These services may include family office-type services, including consolidated reporting. Consolidated reporting is customized to the client’s needs and requirements. The scope of such services, terms and conditions, and fees will be set forth in a written agreement. Transferring Assets Clients may fund their accounts with cash or securities. The Firm will typically liquidate securities transferred in and invest the proceeds in accordance with the investment mandate selected by the client. Depending on the types of securities involved, length of time held in the client’s portfolio, and other factors, liquidations could result in redemption fees and tax consequences. Clients should carefully review the impact of such fees and potential tax consequences before transferring assets. Additionally, certain investments, such as Private Placements, hedge funds, limited partnerships, insurance contracts or commodities, may not be transferred or held in the account. Clients should consult with their Galapagos Advisory Representative prior to instructing the transfer or liquidation of assets. Regulatory Assets Under Management As of December 31, 2023, Galapagos Advisory had USD$106,667,465 in assets under management, of which USD$54,318,352 were managed on a discretionary basis and USD$52,249,465 are non-discretionary assets. Fees The Firm typically charges a management fee on a per annum basis of the client’s net assets under management by the Firm and other Galapagos Group members, including amounts invested in Galapagos Funds, as per the agreed schedule. The management fee is calculated quarterly based on the average of month-end values and cash balances of the previous three months, as adjusted on a pro-rated basis for contributions and withdrawals during the quarter and charged in arrears during the month following the end of the quarter. Account valuations are determined by the custodian or other independent third party. The Firm, in its discretion, may impose a minimum fee for managing smaller accounts. Fees generally range from 0.5% to 1.5% but may be negotiated at our discretion and may vary from client to client based on the assets managed, related accounts, and other services provided as set out in the Client Agreement. The Firm has also agreed with other members of the Galapagos Group that manage Galapagos Funds that the management fees charged to the Firm’s clients who invest in those funds will typically be reduced by 0.5% (subject to negotiated adjustments) per annum to mitigate the layering of fees resulting from such an investment. The fees paid to the Firm may also be reduced for employee and family member accounts. On a case-by-case involving large, sophisticated, qualified clients (as defined under the Advisers Act), the Firm will agree to charge a negotiated performance-based fee instead of a management fee based on assets under management. See also discussion of Performance Fees in Item 6 below. Clients should be aware that the same or similar investment services may be available from other investment advisors for a lower or higher fee, and any qualified clients. The Client Agreement provides us with written authorization to deduct advisory fees from a client’s custodian account. The fees will be reflected in the client’s custodian account statements. We request that clients carefully review their custodian statements and inform us of any discrepancies. An asset-based fee may cost more than a transaction-based fee, but clients may prefer an asset- based fee if they want continuing advice or for someone to make investment decisions on their behalf. Although the Firm believes the charges and fees offered are competitive with other investment advisors and/or investment sources, we make no guarantee that the aggregate cost of a particular program will be lower than that which may be available elsewhere. When appropriate, the Firm may recommend the use of margin and/or option transactions. As these investment strategies involve a certain degree of additional risk, they are only recommended when consistent with the client objectives and risk tolerance. The use of margin also results in interest charges in addition to all other fees and expenses associated with the management of the account. Although account statements for margined accounts may reflect a negative amount, our advisory fee is based on the account’s absolute market value. This poses a conflict of interest because the Firm benefits by receiving a higher fee based on the account’s absolute market value. Minimum Fees/Flat Fees For certain small discretionary and non-discretionary accounts, Galapagos may impose a minimum fee threshold of $785 per quarter or negotiate a flat fee. Both minimum fees and flat fees are payable quarterly in arrears. Payment of Special Services Fees The Firm does not charge “set up” or termination fees. If applicable, any such fees would be charged by the client’s custodian. Clients that terminate their relationship with the Firm will only be charged a prorated amount for any unbilled management fees. Fees for consulting, financial planning, reporting, and special projects are charged on a flat fee, per project, hourly or as negotiated with the client based on a minimum hourly fee ranging from USD$500-$800. Galapagos Advisory’s fee will be based upon various factors including but not limited to the services requested by the client, the size of the portfolio, the type of holdings in the portfolio and any pre-existing relationship with the client. Since these are customized services and separate from the other services we provide to clients, the fees will vary by client and by project. Fees for consulting, financial planning, and other services fees will be invoiced to the client upon completion of the project. Portfolio Consolidation Fees Pricing for the Galapagos portfolio consolidation service is a fixed dollar amount per year based on the number of custodians, the number of investment positions and the ease of access to the data (varying from electronic data interface to manual input from printed statements). Pricing ranges from $1,000 to $10,000 per quarter, a basis points base fee can be implemented. At our discretion, we may discount the fee and/or offset all or a portion of the fee against fees paid for investment management services. Client Responsibility for Third Party Fees Clients will generally incur certain charges imposed by custodians, brokers, and other third parties such as fund managers. These include third-party manager fees, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other fees and taxes on brokerage account and securities transactions. Clients are responsible for the payment of all third-party fees. Such fees are separate and distinct from the fees and expenses charged by the Firm. See Item 12 for additional information. In addition to the Firm’s advisory fee, each mutual fund or ETF in which a client's assets may be invested, also charges its own management fees. Specific fees and expenses are described in the respective fund’s prospectus. Depending on the fund, a client may be able to invest directly in the shares issued by a mutual fund with or without incurring any sales or advisory fees. Mutual fund companies generally offer multiple share classes of the same fund. Share classes are described in the mutual fund's prospectus. Each share class charges different fees and expenses and depending on the share class selected, fees and internal expenses charges may be higher or lower. Certain funds do not charge a transaction fee but have higher internal expenses. Selecting funds that charge higher fees and expenses may adversely impact an account’s long-term performance. Galapagos Advisory’s policy is to recommend that clients invest in the lowest cost share class available based on the client’s individual situation. The Firm generally recommends Advisor or Institutional share classes that typically have the lowest expense ratios and the Firm believes are more beneficial than other share classes. Advisor or Institutional share classes are generally available to investors in qualified fee-based advisor programs, or accounts that meet certain minimum investment requirements. When deemed appropriate, we may recommend that a client that transfers in mutual fund holdings liquidate their existing holdings. This could result in tax consequences, contingent deferred sales charges, or other redemption fees to the client. Clients are encouraged to review the fees charged by the funds and our advisory fees to fully understand the total amount of fees to be paid. Please refer to the mutual fund's prospectus for additional information regarding a particular fund’s fees and expenses. Prepayment of Fees The Firm collects its fees in arrears. It does not collect fees in advance. Outside Compensation for the Sale of Securities to Clients Neither the Firm nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Termination Clients may terminate their Client Agreement without penalty within five business days of signing the contract. Thereafter, clients may terminate the Client Agreement by providing 30 days' written notice prior to termination. Fees for accounts terminated during a calendar quarter will be charged on a prorated basis.