Firm Description Beck Asset Management AG (“Beck AM” or “the Firm”), a Swiss corporation based in Zurich, Switzerland, provides investment advisory services to clients resident in the United States (“US”). Beck AM also may serve non-US as well as non-US resident clients. Beck AM commenced operations in April 2012. Beck AM adheres to the ethical principles of Judaism, as well as to the SEC’s code of ethics, in the conduct of its business practices. Principal Owners The Principal Owner of Beck AM is Jakob Natan Beck. Services Beck AM provides discretionary asset management and nondiscretionary investment advisory services. Beck AM provides portfolio management consistent with the circumstances, preferences and objectives of each client. Investment advisory services are provided based on the individual needs and investment objectives of each client as communicated to Beck AM. Specifically, the structure for each client’s investment program is created in the context of certain considerations such as expected returns, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Each client’s assets are managed in a separate account (an “Account”) maintained at a third-party financial institution. Beck AM’s client portfolios may be diversified across a variety of asset classes, including cash, non-US dollar currencies, marketable securities. Accounts may include, without limitation: equity securities, fixed income securities, money-market 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. Whilst generally Beck AM makes investments with a longer time horizon, Beck AM may recommend changes to allocations in an attempt to take advantage of conditions in the current economic

environment being sensitive to transaction costs and taxes, as applicable. Such allocation changes may involve short-term underweight or overweight positions in various asset classes designed to capitalize on current economic conditions over the short-term. Beck AM’s advice is limited to the types of securities and transactions as set forth in Item 8. Discretionary Asset Management Beck AM offers discretionary asset management services whereby Beck AM has the authority to supervise and direct the investments of and for each client’s Account without prior consultation with the client. Beck AM determines the securities that are bought and sold for the client’s Account and the total amount of the purchases and sales. Beck AM’s authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the asset management agreement entered into between Beck AM and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Beck AM seeks to obtain a rate of return consistent with each client’s objectives, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Nondiscretionary Investment Advisory For clients who desire a nondiscretionary investment advisory service, Beck AM offers investment advice similar to its discretionary asset management service in a nondiscretionary mandate whereby prior consultation and client approval is required before Beck AM purchases or sells any security. Beck AM works with its nondiscretionary clients to define their investment objectives and consults with each client with investment suggestions in line with the defined objectives. Wrap Fee Programs Beck AM does not participate in wrap fee programs. 4 March 12, 2024 Beck Asset Management AG, CRD: 162969 Assets under Management Beck AM managed approximately $43’621’284 on a discretionary basis, as of December 2023.