Adviser’s Advisory Business Boreal Capital Management, LLC (“Boreal” or the “Adviser”)1 is an investment manager that provides discretionary and non-discretionary investment management services to Corporations, Private Investment Companies, Individuals and other Investors. Adviser is wholly owned by Boreal Capital Holdings UA, LLC which is wholly owned by MORA BANC GRUP, SA. Adviser is a subsidiary of Morabanc, S.A. an Andorran private banking and Investment management firm. www.morabanc.ad Types of Advisory Services Adviser Offers Adviser provides investment advisory services to Adviser’s clients through various types of discretionary and non-discretionary accounts in accordance with each client’s investment objectives. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that is intended to fit within the client’s objectives, strategies and risk profile as described by each client. Customized Discretionary Portfolios Adviser offers a discretionary management account that is customized to each client. 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 8. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. General: Investment Policy Statement & Definition; Asset Allocation Strategy; Investment Strategy & Manager Review. Investments: Review of Current Portfolios & Proposals; Determine Modifications, Create Timeline and Implement; Suggest Reasonable Fees for Products and Services; Provide Consolidated Reporting and Analysis; Ongoing Monitoring and Re-evaluation; Define or Affirm Wealth Transfer Desires; Succession Illustration and Definition. Third-Party Managers Based upon the stated investment objectives of the client, the Adviser may recommend to certain clients that they authorize the active discretionary management of a portion of their assets by certain investment managers that are not affiliated with Adviser. Prior to selecting a third-party manager for a client, Adviser may conduct due diligence about the 1 Boreal Capital Management, LLC was known as Mora Wealth Management, LLC until September 30, 2019. B o r e a l C a p i t a l M a n a g e m e n t , L L C P a g e | 5 manager through an independent third-party institution. Adviser shall continue to render services to the client and, in addition, monitor and review the performance of the third- party manager and the performance of the client’s accounts that are being managed. From time to time, Adviser may also recommend affiliated investment managers to certain clients based on their investment objectives, guidelines and risk profiles Portfolio Management Services Adviser provides investment advisory services to Adviser’s clients through the management of investment portfolios in accordance with the objectives and guidelines of the private investment companies as stated in each private placing memorandum or in accordance with the risk profiles of individual clients. The investment objectives, risk tolerance and financial circumstances of any funds in which clients may invest are generally described in their private placement memoranda other clients provide such information to Adviser at or before the time they enter into an advisory agreement with Adviser. Clients but not investors may impose reasonable restrictions on the management of their accounts, including by restricting particular securities or types of investments. Clients should be aware that performance of restricted accounts may differ from performance of accounts without such impediments, possibly producing lower overall results. Sub-Advisory Services Boreal may from time-to-time act as a sub-adviser or engage the services of sub-advisers to assist or manage client portfolios and related funds. Such activities include, but are not limited to the selection and monitoring of client portfolios, as well as asset

allocation and continued analysis related to the Adviser’s portfolio management services. Sub- advisors’ services are contracted by the Adviser. Boreal may engage its affiliates (i.e. Morabanc) or other related parties to act as a sub-adviser. In the event such activity exits Boreal notes a potential conflict of interest may exist, as well as related fees may be shared with the sub-adviser pursuant to the terms of a formalized agreement. Adviser offers a discretionary program that utilizes Lockwood Advisors Inc.’s (“Lockwood”) and their Wealth Management Programs. Lockwood is an unaffiliated investment advisory firm registered with the Securities and Exchange Commission. Lockwood provides access to individual portfolio managers (“Portfolio Managers”) and investment advisory and discretionary services to financial planners, certified public accountants, broker-dealers, registered investment advisers, and other financial advisors (“Firms” or “Firm” in the singular) which, in turn, provide investment advice and consulting services to their high net worth clients and institutional clients as described in Lockwood’s Form ADV Part 2. Lockwood also provides separately managed accounts (“SMAs”) in which each account has a Portfolio Manager responsible for the day-to-day investment decisions. Assets in the Programs are managed, in most cases, by independent Portfolio Managers from Lockwood or its affiliates. In addition, because Lockwood also functions as a Portfolio Manager in certain programs, Lockwood, itself, may be the underlying Portfolio Manager B o r e a l C a p i t a l M a n a g e m e n t , L L C P a g e | 6 on some Client accounts. Lockwood is the sponsor of the wrap fee program Managed Account Advisor (“MAA” or the “MAA Program”). In the MAA Program, your Firm provides brokerage services to you, directly selecting mutual funds and/or ETFs. The overall strategy and asset allocation for the Programs are customized to each client. Clients who participate in the Programs pay a fee, which is described in Item 5 below, to both Lockwood and to Adviser. Assets invested in the Programs are custodied with Pershing, which also provides brokerage services to the Programs. Brokerage fees for transactions in the Programs are not separately charged to clients, and third-party investment managers in the Program do not receive additional fees from Adviser’s clients. Adviser does not accept a portion of any wrap fees paid to the third-party managers. Adviser’s clients that wish to participate in the Programs receive a copy of Lockwood’s Brochure before or at the time they contract for such services. Please contact your Investment Adviser Representative or Adviser’s compliance officer for a copy of Lockwood’s Brochure and further details about the program. 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 would define the 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 at Adviser’s affiliated broker-dealer or accounts custody with third parties. Wrap Fee Programs Adviser does not act as a primary sponsor for any wrap fee programs. Investment Restrictions As described above, Adviser offers an array of services and clients can select among the services that the client and the Adviser feel are suited for the client. Clients may impose reasonable restrictions on the management of their accounts, including by restricting particular securities or types of investments. Clients should be aware that performance of restricted accounts may differ from performance of accounts without such impediments, possibly producing lower overall results. Regulatory Assets Under Management As of December 31, 2023, Adviser managed approximately $417,986,841 in assets on a discretionary basis and $959,870,316 on a non-discretionary basis. B o r e a l C a p i t a l M a n a g e m e n t , L L C P a g e | 7