FIRM DESCRIPTION Flameback Capital USA, Inc. (hereinafter referred to as “Flameback Capital USA,” “we,” “us,” or “our firm”) is a Delaware corporation with its principal office located Bengaluru, Karnataka, India and has been in business as a registered investment adviser since March of 2024. The principal owner of the firm is Flameback Capital Private Limited and Mr. Kishan Murjani Nair serves as Flameback Capital USA’s Director and Chief Compliance Officer. As a registered investment adviser, we are a fiduciary to you, our client, meaning we have a fundamental obligation to act and provide investment advice that is in your best interest. Should any material conflicts of interest exist that might affect the impartiality of our investment advice, they will be disclosed to you in this Brochure. We urge you to review this Brochure carefully and consider our qualifications, business practices and the nature of our advisory services before becoming our client. Flameback Capital USA is a newly established investment adviser with no assets under management. Clients may request more current information at any time by contacting our firm. ADVISORY PROGRAMS Flameback Capital USA is an investment advisory firm that provides limited investment management services to our clients exclusively through digital technology solutions. Our firm’s services are provided via Flameback Capital USA’s proprietary interactive website at https://us.flamebackcapital.com. We utilize an automated, algorithm-based investment strategy with respect to fractional shares, equities, debt/equity/ /index ETFs, and Equity Options. To tailor its investment decisions to each client’s specific needs and objectives, Flameback Capital USA collects information from each client through an “Investor Profile Questionnaire” on its website. Each client will fill out this questionnaire prior to signing up for Flameback Capital USA’s investment management services. Through interactive models, Flameback Capital USA will assist our client with determining their risk capacity and risk attitude and help them choose from three predefined risk levels. This is due to the fact that it is our duty to provide investment advice that considers each client objective individually, and if the majority of a client’s objectives weigh in favor of a certain risk level that the client did not request, we must notify such client of this outcome. The firm’s digital platform may even determine that our investment advice is not suitable for particular clients after reviewing client answers to the initial questionnaire. Clients can also override the algorithm’s recommendation, but the client must acknowledge in writing that they are not taking the firm’s advice if they decide to be placed in a different risk profile. Flameback Capital USA maintains its clients’ personal identification information in strict confidence subject to its Privacy Policy, which can be found on our website, https://us.flamebackcapital.com. Although Flameback Capital USA seeks to accommodate any reasonable investment restrictions or guidelines set by our clients, we may decline to accommodate certain investment restrictions that are incompatible with our firms’ investment philosophy or that may have an adverse effect on our ability to manage your account. Flameback Capital USA will have non-discretionary authority over Client accounts with respect to portfolio construction, asset allocation, and

other investment decisions, subject to the limitations described herein. Flameback Capital USA will have discretionary authority where the client grants us such authority over the client’s account. Flameback Capital USA enters into formal written agreements with our clients setting forth the terms and conditions under which we will provide our advisory services (the “Investment Management Agreement”). The Investment Management Agreement sets forth the scope of the services to be provided and the compensation we receive from the client for such services. The Investment Management Agreement may be terminated by either party in writing at any time by giving thirty (30) days signed written notice to the other party. Clients agree to accept electronic delivery of this agreement, disclosure documents, statements, and other materials. Once enrolled in our services, clients can update their investment profile or monitor their accounts’ allocation via the client account section of our website. Clients are able to view their account activity, and performance through their online, broker provided dashboard, or broker provided trading platform. Clients should periodically review their existing investment risk profile and update it when their goals, risk tolerance, or other aspects of their financial situation change. Our advisers offer the advisory services described below to our clients: Automated Investment Management. Flameback Capital USA provides automated investment management services in which clients grant our firm the ability to make automated investment recommendations: the client either grants our firm discretionary authority whereby Flameback will manage rhe client’s investment assets without consulting with the client in advance of trade execution, subject to the investment objectives, guidelines and restrictions set by the client, or the client grants our firm a limited form of discretionary authority, whereby the client must either accept or deny our recommendations prior to execution. Once a client approves of a recommendation, our firm will give instructions concerning these transactions to the qualified custodian with which the client’s account(s) are held. The firm requires Clients to electronically sign an Investment Management Agreement to receive non- discretionary or discretionary investment advisory services. Clients receive the firm’s Form ADV, including the Brochure, Brochure Supplements, Client Relationship Summary (“Form CRS”) and privacy policy through the website and/or other electronic communication. Access to Adviser. Flameback Capital USA serves as an “internet-only” investment adviser pursuant to Section 203A-2(e) of the Advisers Act. Under this registration the Adviser provides investment advice solely through its interactive website. The Adviser is not available to Clients for telephone conversations or communications through other means such as post mail, courier, or email (other than operational emails). The Adviser does not meet with clients at its offices. All advice, support, and inquiries are delivered through the Adviser’s website. Wrap Fee Programs. Flameback Capital USA does not participate in any wrap fee programs. Important Note: It is the client’s responsibility to ensure that Flameback Capital USA is promptly notified if there are ever any significant changes to their financial situation, goals, objectives or needs so we can review our previous recommendations and make any necessary adjustments.