Firm Description ROVS – Reyl Overseas Ltd. (“ROVS” or “the Firm” or “we”), a Swiss corporation based in Zurich, Switzerland provides investment advice to clients resident in the United States (“US”). ROVS also serves US taxpayers or dual citizens living outside the US and in certain cases may work with clients who are not resident in the US or US taxpayers. ROVS commenced operations in 2011 in Zurich. Principal Owners Reyl & Cie S.A. (“Reyl & Cie”) wholly owns ROVS. Fideuram Intesa Sanpaolo Private Banking S.p.A. (“Fideuram”) owns 69% of Reyl & Cie. Fideuram is wholly owned by Intesa Sanpaolo S.p.A. Services ROVS provides wealth management solutions to high-net-worth individual clients as well as companies and it offers both discretionary asset management (management mandates) and non- discretionary investment advisory services (investment advisory mandates). Each client’s assets are managed in a separate account (an “account”) maintained at a third-party financial institution. ROVS’ client portfolios are diversified across a variety of asset classes, including cash, US dollar and non-US dollar currencies, defensive strategies in marketable securities, growth strategies in marketable securities, and, in certain cases, private investments. Accounts may include, without limitation: equity securities, fixed income securities, limited partnership interests, mutual funds, exchange traded funds, hedge funds, options, structured product investments and other alternative investments consistent with a client’s suitability, his or her overall investment strategy, and his or her risk tolerance. Generally, client investments are concentrated in non-US securities consistent with most clients’ objective of obtaining jurisdictional diversification from the US. Whilst generally ROVS makes investments with a longer time horizon, ROVS may recommend changes to allocations in an attempt to take advantage of conditions in the current economic environment whilst being sensitive to transaction costs and taxes, as applicable. Such allocation changes may involve short-term underweight or overweight positions to various asset classes designed to capitalize on current economic conditions over the short-term. ROVS’ advice is limited to the types of securities and transactions as set forth in Item 8.

ROVS does not render any Legal or Tax advice. Management Mandate ROVS offers discretionary asset management services whereby ROVS has the authority to supervise and direct the investments of and for each client’s account without prior consultation with the client. ROVS determines the securities that are bought and sold for the client’s account and the total amount of the purchases and sales. ROVS’ authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the investment management agreement entered into between ROVS and the client. For example, a client may restrict or prohibit transactions in certain types of securities. ROVS seeks to obtain a rate of return consistent with each client’s objectives, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Generally, ROVS manages each client’s portfolio in line with model portfolios constructed by the investment committee of the firm. However, these model portfolios serve only as a general guide and not every client’s portfolio will replicate the model portfolio as a result in differences in client risk tolerance, tax ramification, client specifications, liquidity and timing. Investment Advisory Mandates For clients who desire a non-discretionary investment advisory service, ROVS offers ROVS – Reyl Overseas Ltd, CRD: 152526 4/16 investment advice similar to its discretionary asset management service in a non-discretionary mandate whereby prior consultation and client approval is required before ROVS purchases or sells any security. ROVS works with its non- discretionary clients to define their investment objectives and consults with each client on a regular basis with investment suggestions in line with the defined objectives. If explicitly required by a non-discretionary client, ROVS may implement investment ideas which do not pertain to ROVS’ investment universe. ROVS will disclose to the client if an investment idea is not part of ROVS’ investment universe. Wrap Fee Programs ROVS does not participate in wrap fee programs. Assets under Management ROVS managed approximately USD 177.4 million on a discretionary basis and USD 144.9 million on a non-discretionary basis for a total of USD 322.3. million as of December 31, 2023.