Stelac Advisory Services LLC (“Stelac”) is an SEC-registered investment adviser with its principal place of business located in New York. Stelac began conducting business in 2007 to provide primarily international (non-US) clients with a comprehensive multi-family office solution. We act as independent and unbiased intermediaries between our clients and their financial institutions. Our primary role is to consolidate all of our client’s banking relationships into one platform and advise clients on asset allocation, estate planning, family governance, and philanthropic endeavors. Our clients include trusts or other entities which individuals may use to control their liquid assets. Listed below are the firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Integer LLC *
• CVC Holdings LLC
• Carlos E. Padula * CVC Holdings and Carlos E. Padula are the sole owners of Integer LLC, the sole owner of Stelac Advisory Services LLC. Stelac offers the following specific advisory services to our clients: INVESTMENT SUPERVISORY SERVICES (“ISS”) INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary and/or non-discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, capital preservation, or growth and income). As of December 31, 2023, we managed approximately $2,180,448,123 regulatory assets on a discretionary basis and $1,760,698,625 assets on a non-discretionary basis. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or custodian, and will generally include advice regarding the following types of securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• United States government securities
• Interests in partnerships, whether private equity and/or hedge funds
• Other liquid or illiquid securities the client may desire, such as structured products, currency forward contracts, third-party managers, etc. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. INVESTMENT SUPERVISORY SERVICES MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. The following are the three primary model portfolios we use with our clients, although other model portfolios or strategies may be utilized. In some cases, depending on the client’s needs, we may blend two model portfolios into one.
• “Loss-Aversion” Portfolio - designed for income-oriented investors who cannot tolerate significant losses. Contains substantial cash and fixed-income investments to mitigate risk and seeks to assure positive returns in 95% of the investment environments with minimal drawdowns otherwise.
• “Moderate Risk” Portfolio - created for high-net-worth investors who are prepared to take more downside risk in exchange for higher long-term returns. This is essentially the mid-point between the Loss-Aversion Portfolio and the Fully Invested Portfolio (no cash) and blends the characteristics (returns and risks) of the two extremes.
• “Fully Invested” Portfolio - Appropriate for more aggressive investors with a perpetual horizon (such as institutions). This portfolio minimizes cash exposure to the extent possible and is expected to deliver the highest long-term return, but also will exhibit substantial losses on occasion. The portfolio is benchmarked to a 75%/25% global stock and bond allocation. We manage these advisory accounts on a non-discretionary basis in the vast majority of cases. Some clients may grant limited powers of attorney on certain specific custodial accounts for convenience and logistical purposes. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, capital preservation, or growth and income). Through personal discussions with the client in which the client’s goals and objectives are established, we determine which model portfolio is suitable to the client’s circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio’s

goal, rather than on each client’s individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their accounts. Clients retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or custodian, and will generally include advice regarding the following types of securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• United States governmental securities
• Interests in partnerships, whether private equity and/or hedge funds
• Other liquid or illiquid securities the client may desire, such as structured products, currency forward contracts, third-party managers, etc. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity, and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client’s financial circumstances, we will: 1. At least quarterly, send reports outlining a client’s portfolio, including but not limited to existing asset allocation, currency denomination, custodial relationships, inflows, outflows, fees, performance, and transactions executed during the period; 2. At least quarterly, provide the client with a more detailed analysis of their portfolio and suggest a rebalancing strategy to meet the client’s investment objectives, and whether the client wishes to make any other changes to the portfolio or its investment objectives; 3. Be reasonably available to consult with the client; 4. Maintain client suitability information in each client’s file; and 5. During certain periods of extreme movement or volatility in the financial markets, client accounts are reviewed to determine an appropriate course of action, if needed. MANAGER OF MANAGERS PROGRAM Stelac advises a segregated portfolio company called Stelac SPC (“SPC”), a Cayman Island based entity. The primary purpose of SPC is to provide clients, and potentially to select third party high net worth individuals and/or families, with access to private equity funds and other private investment vehicles. SPC was launched with its first investment in April 2016. SPC serves as a product solution available to clients to diversify their equity allocation within the Stelac asset allocation. The mission of SPC is to provide investors with a transparent structure that has the potential to deliver superior equity returns to applicable foreign and domestic markets, at a minimum cost. Manager selection is based on the track record of the manager(s), investment strategy, and how Stelac views the applicable foreign and domestic macro and market environments at the time. SPC is only available to non-US investors and subscriptions to SPC require the approval of Stelac’s Chief Financial Officer and SPC’s independent administrator. Target investments of SPC are third-party private equity managers who have no relationship with Stelac or any of its employees, officers, or owners. Stelac has no financial interest in any of the private equity funds or vehicles in which SPC invests. No employees are currently invested in SPC. Clients should refer to the SPC offering memorandum for additional information. In addition, Stelac is the manager of SAS Paladin Cyber Fund II LLC (“Paladin”), a Delaware limited liability company. The primary purpose of Paladin is to directly invest in and own securities of Paladin Cyber Fund II, L.P., a Delaware limited partnership. Clients should refer to the Paladin offering documents for additional information. In certain cases, we may identify third-party asset managers that could fit well within a client’s portfolio strategy and investment objectives. If so identified, we may recommend on a non- discretionary basis a particular asset manager for the client to consider for their investment portfolio. If a manager is selected by the client, on an ongoing basis, we monitor the performance of the asset manager(s). If we determine that a particular asset manager is not providing management services to the client which are consistent with the level of service provided by other similarly situated asset managers or is not managing the client’s portfolio in a manner consistent with that client’s investment objectives, then we may recommend the client move the client’s portfolio to a different asset manager, program sponsor or investment vehicle. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on isolated area(s) of concern such as estate planning, trusts, philanthropic endeavors, family governance, retirement planning, or any other specific topic. We may also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or custodial bank. All recommendations are of a generic nature.