A. History of our firm; ownership of our firm Ballentine Partners’ mission is to help the families we serve make smart decisions about their wealth, giving them the freedom to focus on their lives as they want to. Many of the decisions we made about how to structure our practice and how to address conflicts of interest are based on the experiences of our founder, Roy Ballentine, with his own family’s situation during the early 1980s – before Roy knew anything about wealth management. Roy’s parents had a sophisticated estate plan that included multiple trusts, partnerships, and corporations. But, when his father died in 1984, he learned the hard way about the challenges of managing wealth, balancing family needs, and the wishes of individual family members. After the estate was settled, Roy chose to change careers. He began to search for a better way to address the demanding requirements of family wealth management. What Roy’s family desperately needed and did not get was comprehensive, integrated, objective advice that addressed the issues and problems that later became difficult to address. They had no advisor to provide guidance about a strategic plan for their family’s wealth. There was no team leader who could help them to realize the benefits of collaboration among specialty advisors. In 1984, Roy founded Ballentine & Company, Inc., a wealth advisory firm, resolving to help other families achieve much better results than his family experienced. In 1997, the firm became Ballentine, Finn & Company, Inc. On January 25, 2010, the shareholders of Ballentine, Finn established Ballentine Partners, LLC (“the Company”) and transferred the entire business to that entity. As part of the company’s succession plan, in January of 2016, Drew McMorrow was appointed Chief Executive Officer of Ballentine Partners, LLC. Drew has been a member of the team since 2002. The ownership of Ballentine Partners, LLC is detailed on the Form ADV 1, which can be accessed through the SEC’s website: https://www.adviserinfo.sec.gov/. As of December 31, 2023, Ballentine Partners, LLC was 74% owned and controlled by its current or retired senior employees or trusts created by those employees, either through direct ownership or indirect ownership through Ballentine & Company, LLC, and 26% owned by clients of the firm. Our goal is to have Ballentine Partners remain under the ownership and control of its senior team members so it will remain independent and properly positioned to deliver objective advice to families we serve. B. Types of services we offer 1. Overview. Ballentine Partners’ goals are to help you to:  Protect, preserve, and grow your wealth so you can meet your financial goals;  Feel in control of your wealth, rather than to experience wealth as a burden; and  Prepare the next generation to be financially self-sufficient and to be good stewards of the family’s resources. We serve families with investment assets of $4 million or more. Our largest clients have family net worth of more than $1 billion. We specialize in managing privately-owned wealth. We have structured our firm to minimize conflicts of interest between ourselves and you. We do not sell any insurance or investment products. We have only one source of income – fees paid to us by our clients. Each client fee agreement is simple, and the costs are fully disclosed to each client. Our Wealth Management clients – generally families with assets of $30 million or more – receive extensive financial planning advice and investment management services on an on-going basis. This advice includes analysis of cash flows, balance sheet, estate plan, insurance coverage, debt, income tax planning, etc. Most Wealth Management clients receive quarterly financial statements covering all major aspects of each client’s situation. Wealth Management clients have access to both public and private investment vehicles. For clients who wish to participate in private investments, we make those investments on both a discretionary and non- discretionary basis, based on each client’s wishes. Our clients with assets between $4 million and $30 million typically require our advice for investment management and financial planning. Those clients are served by a dedicated team using the same investment research we apply to larger relationships, using mostly liquid investment vehicles that are better suited to those clients’ investment needs. We also provide investment advice to charitable foundations and other tax-exempt organizations. Many of the charitable organizations we serve were created by our private clients. Our primary business is providing families with objective advice about a wide array of financial strategies and, for our Wealth Management clients, providing an alternative to the cost and complexity of setting up a single-family office. Families who prefer to maintain a family office rely upon us to provide advice and implementation services beyond what their own staff is able to deliver. The range of services we offer each family depends upon the family’s needs, desires, and the complexity of their financial situation. Our advisory capabilities include:  Investment strategy and implementation – we manage accounts on both a discretionary and non-discretionary basis;  Traditional investments – both actively managed investments and index investments;  Alternative asset classes (real estate, private equity, venture capital, etc.);  Alternative investment styles (hedge funds, commodity trading advisors, etc.);  Asset protection planning;  Advice about the impact of wealth on marital and family relationships;  Estate planning advice;  Income tax planning and forecasting;  Property, casualty, and liability insurance;  Life, disability, medical, and long-term care insurance;  Closely held business interests – tax planning for owners, succession planning, preparing the next generation of family owners, preparing for sale, estate planning, financial risk management;  Cash flow planning and forecasting;  Bill payment and cash management systems;  Balance sheet management;  Charitable giving, administration, and management of family charitable foundations;  Lifetime gifts to family members;  Trust accounting and administration;  Family partnerships, LLCs, and other family business entities;  Family office administration; and  Lifestyle management (aircraft, yachts, vacation homes, household staff, etc.). A distinguishing feature of our firm is that we put an experienced wealth manager, not a salesperson, in charge of every client relationship. These experienced advisors are the primary link with our clients, and they get to know the families they serve very well. This means every time you want advice about a significant issue, you will be working with an advisor who has deep technical skills and detailed knowledge about your situation to help you seize opportunities and identify potential problems. When it comes time to implement a recommendation, we are prepared to manage whatever work needs to be done. Our goal is to make wealth management as simple as possible for you. Many of our family relationships are multi-generational. We often work with younger members of the family to help them acquire necessary financial skills. We can also provide direction and coordination for our clients’ other advisors, so our clients are relieved of day-to- day concerns about the management of their financial affairs. We have extensive experience with family office planning and administration. We have helped families establish family offices or reorganize family offices that were already in existence when we began working with them. We have experience managing family office relationships that involve multiple foreign jurisdictions. 2. Investment supervisory services. We serve as your family’s Chief Investment Officer. We manage accounts on both a discretionary and non-discretionary basis. We help you design and implement investment strategies for all of the investment assets on your family’s balance sheet, no matter how those assets are held (directly owned, held in trusts, held in privately owned companies, or held in private foundations), and regardless of which investment firm is making the day-to-day investment decisions. The strategies we use are described in Item 8, which begins on page 17. Most of our clients are individual investors who are required to pay taxes. Our investment advice is customized for you and is guided by four key tenets that are reflected in the following questions:  What is the optimal strategy or choice for your family? We try to put ourselves in your shoes, applying all of the information we have collected about your situation, and applying all of our technical skills.  What strategy is consistent with your risk management goals? Risk analysis requires that we gather detailed information about your risk exposures, tolerance for various types of risk, and what you have already done to mitigate risks. Risk tolerance cannot be measured with a simple questionnaire.  What is the expected net return, after all trading costs, management fees, market impact1 and taxes? For investors who must pay taxes, the net return is the only return that matters.  What other factors need to be taken into account? Most investment recommendations have implications for your cash flow, tax situation, estate plan, and charitable gift planning. We provide advice about a wide range of investment possibilities, including advice about investment products offered by other firms and, upon request, advice about direct investments in 1 Market impact – this term refers to the risk that a transaction to purchase or sell a security may actually cause the price of the security to change in a way that is disadvantageous for the investor. For example, if an investor owns some bonds that are seldom traded, the investor’s attempted sale of some of thier holdings may depress the market price of the bond, thereby adversely affecting the value of the bonds that the investor continues to hold. private companies and real estate. We seek to provide you with access to the best investment products and managers that the marketplace has to offer. A substantial portion of the assets we oversee is managed by other firms we have recommended. We search for the most attractive investment products. Our investment research includes coverage of real estate funds, hedge funds, private equity funds, venture capital funds, and natural resource funds. These are the areas where active management is most likely to add value in excess of its costs. Many of our clients make investments in closely held companies. Upon request, we will help you to find the right resources to analyze a private investment opportunity. 3. Discretionary vs. non-discretionary accounts. We manage investments on both a discretionary and non-discretionary basis. “Discretionary” means that you authorize us to buy and sell securities in your accounts without seeking your prior approval for each transaction. “Non-discretionary” means that we must obtain your approval before making any changes to an investment account. If you engage us to provide investment advice on a non-discretionary basis, we will not be able to make any changes to your account until you respond to an approval request. Any delay in responding may be to your disadvantage. If you have directed brokerage to a particular firm, you may also pay brokerage costs that are higher than necessary. Please refer to, “Directed brokerage,” Item 12.A.4. 4. Portfolio activity. We have a fiduciary duty to provide services consistent with your best interests. We attempt to minimize the portion of your investment returns lost to taxes. We also aim to guide you to an asset allocation policy that is consistent with your long-term goals and that you will feel comfortable holding through thick and thin. This means there may be long periods when we do little or no trading in your accounts. We will review your accounts on an ongoing basis to determine if any changes are necessary based upon various factors including, but not limited to, changes in your financial condition, changes in market conditions, investment performance, or a change in your investment objectives. There may be extended periods of time when we determine that changes are neither necessary nor to your advantage. Our advisory fee remains payable during periods of account inactivity. There is no assurance our investment decisions will be profitable. C. Customized services We customize both our wealth planning services and our investment services to fit your needs. Our wealth planning services are highly customized because every client has a very unique situation that requires a different combination of the services outlined above. Investment portfolios are tailored to fit each client’s circumstances. For instance,

some clients have large real estate holdings while others have concentrated equity positions in either public or private companies. Some clients have excluded almost all U.S. dollar denominated securities from their portfolios. This kind of customization is routine in our practice. 1. Our consulting & implementation services. As a regular and substantial part of our business, we provide financial planning and related consulting services regarding matters other than investments. (Please refer to the list in services for at least a year. The level of intensity of work and the scope of services we provide may vary over the course of a year. We do not adjust our fee in response to those changes because for a variety of reasons it is both inappropriate and impractical to do so. If you request a service that is outside the scope of services you negotiated and which represents significant additional work for us, we may request a fee discussion with you. We do not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as such. We do not prepare estate planning documents, tax returns, or sell insurance products. Upon request, we may recommend other professionals to provide legal, tax, accounting, insurance, or other services. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from us. We do not assume any liability for the performance of unaffiliated professionals. 2. Retirement account rollovers; potential for conflict of interest. If you own any type of IRA account, or if you have a qualified plan with your employer and you terminate your employment, you may have up to four options with respect to your retirement accounts: (1) leave the money where it is, (2) roll the money over to a new employer’s plan, (3) roll the money into an Individual Retirement Account (“IRA”), or (4) withdraw the money and pay taxes on it (and penalties, if applicable). Approximately one-half of our clients have negotiated flat fee arrangements for all services we provide, and the other half have fees based on assets managed or overseen by us. If your fee is based on assets under management and we recommend that you roll your retirement money into an account managed by us, we will be subject to a conflict of interest because the account will generate additional fee income for us. We operate under a fiduciary standard when giving you advice of any kind. You are not under any obligation to rollover retirement plan assets to an account managed by us. 3. Use of mutual funds and Exchange Traded Funds (“ETFs”). Mutual funds and exchange traded funds similar to those we use in clients’ portfolios are available directly to the public. You can purchase those investments without engaging us as your investment advisor. All investors pay brokerage costs and management fees that are embedded in mutual funds and ETFs. If you engage us, you will also incur our fee. 4. Private investment funds. If you wish to invest in private investments, we can assist you on either a discretionary or non-discretionary basis. Some private investments may be over-subscribed. If an investment is over-subscribed, decisions about the allocation of that opportunity among clients are made by the Investment Allocation Committee, which is comprised of a few senior members of our firm. If an opportunity is over-subscribed, we favor our clients over our employees; our employees are not allowed to invest. If an investment is not over-subscribed, our employees are allowed to invest on exactly the same terms as our clients. The value of private funds may be included in the calculation of our advisory fee. You are under no obligation to make an investment in a private fund. Private funds generally involve many risk factors including, but not limited to: the potential for complete loss of your capital, lack of liquidity, lack of transparency, lack of marketability, and the fund sponsor’s conflicts of interest. We sponsor a number of private investment funds for the benefit of our clients. We manage those funds through our affiliate, Ballentine Funds, G.P., LLC, which serves as the general partner of each fund. Neither Ballentine Partners nor Ballentine Funds, G.P., LLC has any ownership stake in the private funds we manage, thereby reducing or eliminating most conflicts of interest between ourselves and those funds. As a private fund nears the end of its investment cycle, it may reach a point where it will be in the best interests of the investors if we terminate the fund. There are three ways we can terminate a fund: (1) sell its remaining investments on the secondary market and distribute the cash proceeds to the investors, (2) distribute the remaining investments “in kind” to the investors, or (3) sell the remaining investments to another Ballentine fund and distribute the cash proceeds to the investors. Each of the three options carries with it potential advantages and disadvantages for the buyers and sellers involved. Which of the above options we select will depend upon the facts and circumstances at the time the issue arises. If we elect option 1 or 3, we will obtain a valuation opinion from an independent qualified appraiser. We will take reasonable and prudent steps to structure a transaction in which buyer and seller are both treated fairly. We will not receive anything of economic value as a result of the transaction. The terms and conditions found in the offering documents of each private investment will govern your rights and obligations with respect to those investments. Those terms and conditions of the offering documents will continue to apply so long as you are a participant in the private investment. Terms and conditions may include, without limitation, your obligation to fund capital calls, tax obligations and restrictions on your right to transfer your ownership. Please refer to the relevant offering documents to determine the terms and conditions applicable to each investment. It may not be possible for you to withdraw from a private investment until such time as the underlying activity has ended and the legal entity holding the investment activity has been dissolved. 5. Direct investments. A direct investment is an investment in a private company or real estate. For example, some of our clients have made direct investments in private companies and income-producing real estate. If you are interested in direct investments, we will assist you on a non-discretionary basis. Our analysis will be based upon the documentation and other information provided to us by you or the sponsor of the investment, and upon our general knowledge of investments. We do not claim to have expertise in investment banking, or any industry-specific expertise. Your Client Agreement2 will state whether or not the value of direct investments is included in the calculation of our advisory fee. You are under no obligation to make any direct investments. 6. Investments in digital asset and blockchain technology. We provide advice about investments in digital asset and blockchain technology. We also provide advice about custody agents for such investments. Clients wishing to invest in digital assets in their personal accounts do so on a non-discretionary basis, and they select a custody agent. Upon request, we will agree to make trades in clients’ digital asset accounts. We also invest in digital assets and blockchain technology on a discretionary basis through some of our Affiliated Funds (please refer to Item 10.C on page 31). Each client’s decision to invest in an Affiliated Fund is made on a non-discretionary basis, except when a client has explicitly granted us discretion to make private investments. 7. Specialty investment managers; our sub-advisory relationships. After discussion with you about your investment choices, we may allocate a portion of your investment assets among unaffiliated specialty managers with whom we have sub-advisory agreements (‘sub-advisors”). For example, we have relationships with equity managers and bond managers to whom we delegate investment authority. Those specialty managers have day- to-day responsibility for discretionary management of the allocated assets. We select sub- advisors based on a variety of factors including, but not limited to, reputation, integrity, financial strength, corporate culture, fit with your investment objectives, investment performance net of fees and taxes, reporting, and client service. Investment fees of sub-advisors are separate from and in addition to our fee. We have negotiated fees with those managers on behalf of all of our clients, so that all clients are subject to the same fee schedule. We do not participate in any portion of those fees. Our goal is to minimize the fees our clients pay to subadvisors, consistent with receiving a high level of service. The shareholders of some sub-advisors are individual clients of Ballentine Partners, which creates a conflict of interest for us because our decision to refer assets to a manager may increase the wealth of one or more of our clients who are owners of that firm. You are under no 2 We have several forms of client service agreements, all of which are referred to in this document as “Client Agreement.” obligation to use any sub-advisor. We encourage you to inquire about conflicts of interest between us and any investment manager we may recommend. 8. Qualified retirement plans. Trustee-directed plans: If you are a trustee of a qualified retirement plan (a “Plan”) and you engage us to provide investment advice to the Plan in your capacity as trustee, we will serve as an investment fiduciary as that term is defined under the Employee Retirement Income Security Act of 1974 (“ERISA”). If the Plan is participant-directed, we will assist you with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by us), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Advice about your qualified plan investments: Upon request, we may agree to provide you with advice about how to invest your retirement assets held in a qualified plan. Generally, you will be responsible for implementing our recommendations. Our fee for advisory services must be charged to one of your personal accounts; we cannot receive any fee compensation from your qualified retirement account or the Plan’s sponsor. You are responsible for notifying us of any changes to the Plan and its associated investment menu. Please refer to the discussion of conflicts of interest in Item 4.C.2 on page 8, which is also applicable to our advice about qualified plans. 9. Your obligation to notify us of changes in your situation. It is your obligation to keep us informed of information about your situation that may be relevant to our advisory relationship, and we shall be entitled to rely upon the accuracy of information you provide without making any attempt to independently verify that information. D. Our relationships with other investment managers; wrap fee programs We have no fee-sharing arrangements with other investment managers. We do not participate in any wrap fee programs.3 3 A wrap fee program is an investment arrangement under which a client opens an investment account with advisor “A”, who then parcels out the money to be managed by a number of separate investment management firms, “B”, “C” and “D”. The client is charged a single fee by advisor A, who then shares that fee with managers B, C and D. We maintain relationships with many investment managers who offer specialized products and investment strategies that are of interest to our clients. Our recommendations are governed solely by our assessment of the quality of the manager’s offering and how well that offering fits the needs of our clients. We decline all offers by outside managers to participate in fee-splitting arrangements and other forms of compensation. We use the collective purchasing power of our clients to negotiate favorable fee arrangements. All fee discounts are passed through to our clients. This is a direct benefit to you, and it eliminates another key area of conflicts of interest between us and you. E. Client assets under our advice4 Table 1 shows the approximate amount of client assets under our advice. Table 1: Assets under our advice as of December 31, 2023 Description Amount Client assets managed on a discretionary basis5 by Ballentine Partners $8,410,792,838 Client assets overseen by us6 but managed by other investment firms $2,357,816,929 Other client assets under our advice7 $12,427,497,855 Total client assets under our advice $23,196,107,622