Dragus is an independent Registered Investment Advisory firm focused on providing investment management services to high-net-worth individuals, families, companies and institutions. By consolidating resources Dragus strives to provide a discreet and stable service based on strategies designed to protect and grow the liquid assets of our clients. Dragus’ sole mission is the management of its clients’ liquid assets. The firm’s objective is the preservation of capital and the long-term growth of the assets under its management. Dragus seeks to achieve this through intelligent solutions focused on the specific needs of our individual clients. Dragus considers its clients’ goals and risk tolerance before reaching a mutual decision with the client on how best to seek to build and preserve their wealth. Dragus follows a disciplined approach to leverage high-quality investment products and providers in order to create a diversified portfolio aimed at meeting its clients’ objectives. Prior to engaging Dragus to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Dragus setting forth the terms and conditions under which Dragus renders its services (collectively the “Agreement”). Dragus is a Florida Limited Liability Company organized on March 13, 2011 and has been an SEC registered investment adviser since June 24, 2011. The owners of Dragus are Antonio J. Polegre, Sr., Jorge Sanchez, Javier Madariaga, and Alhambra Limited which is owned by The Alhambra Trust. As of December 31, 2023, Dragus had approximately $209,584,781 in assets under management, of which $159,771,953 was managed on a discretionary basis and $49,812,828 was managed on a non- discretionary basis. This Disclosure Brochure describes the business of Dragus. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Dragus’ officers, partners, directors, or employees or any other person who provides investment advice on Dragus’ behalf and are subject to Dragus’ supervision or control. Investment Management Services Clients engage Dragus to manage all or a portion of their assets either on a discretionary or non- discretionary basis. Dragus primarily allocates clients’ investment management assets among mutual funds, exchange- traded funds (“ETFs”), and individual equity and debt securities (i.e., stocks and bonds) in accordance with the clients’ investment objectives. Dragus’ investment policy does not permit recommendations of

private placements of securities, which may include debt, equity, and/or pooled investment vehicles, even to clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. Notwithstanding the types of investments that Dragus recommends to its clients, Dragus will provide advice about any type of investment held in its clients' portfolios. Dragus tailors its advisory services to the individual needs of its clients. To do so, Dragus consults with clients initially and on an ongoing basis to determine their risk tolerance, time horizon and other factors that may impact the clients’ investment needs. On an ongoing basis, Dragus ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify Dragus if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Dragus’ management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in Dragus’ sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Wealth Planning Services Dragus provides Wealth Planning Services primarily to clients who are non-U.S. persons. These services include establishing an ownership structure that assists clients with wealth preservation when assets are passed to next generations, planning how their assets will be distributed to their descendants when they pass away, protecting the beneficiaries of the assets during their lifetime, and to optimizing U.S. estate taxes for assets in the U.S. To accomplish these goals, Dragus normally recommends two types of ownership structures: Trusts and/or Offshore Companies. Providers recommended by Dragus for this type of service include:
• Forbes Hare Trust Company
• Zedra Trust Company
• Morning Star Holdings Services
• Integritas Trust
• Alemán, Cordero, Galindo & Lee (Alcogal) Consulting Services Occasionally, Dragus may offer consulting services to clients on an hourly basis that do not involve investment management. These services include, but are not limited to, assisting with the purchase of real estate; assisting with the purchase of businesses or making business decisions; assisting; dealing with accountants and other professionals; and assisting with trust structures changes.