Firm Description VENTIRA Private Wealth Management Ltd. (“VENTIRA” or “the Firm” or “we”), a Swiss corporation based in Zurich, provides dedicated investment advisory services to clients resident in the United States (“US”). We also serve US taxpayers or dual citizens living outside the US and clients who have no connection to the US. VENTIRA commenced operations in 2012. Principal Owners Beat Gloor and André Studer are the principal owners of VENTIRA Private Wealth Management Ltd. Services VENTIRA provides investment management solutions to individuals, high net worth and ultra- high net worth clients and it offers both discretionary asset management and non- discretionary investment advisory services. Each client’s assets are managed in a separate account (an “Account”) maintained at a third-party financial institution. VENTIRA’s client portfolios are globally diversified across multiple asset classes. Accounts may include, without limitation: equity securities, fixed income securities, limited partnership interests, mutual funds, exchange traded funds, hedge funds, structured product investments and other alternative investments consistent with a client’s objective, risk tolerance, reference currency, tax situation, investment time horizon and overall suitability. For the purpose of diversification, client accounts may hold non- dollar securities in markets outside the United States. Whilst generally VENTIRA makes investments with a longer time horizon, VENTIRA 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 changes may involve underweight or overweight positions designed to capitalize on current economic conditions over the short- term. VENTIRA’s advice is limited to the types of securities and transactions as set forth in Item 8. VENTIRA does not render any Legal or Tax advice. Discretionary Service VENTIRA offers a discretionary asset manage- ment service designed for investors who wish to have their assets fully managed by VENTIRA. This service provides asset allocation, investment selection and active portfolio management including portfolio rebalancing in accordance with a client’s stated objectives, investment time horizon, risk tolerance, and tax situation. VENTIRA purchases and sells securities for the client’s Account without prior consent of or notification to the client. VENTIRA determines the securities

that are bought and sold for the client’s Account and the total amount of the purchases and sales. VENTIRA’s authority may be subject to condi- tions imposed by individual clients as set forth an agreed upon in the investment management agreement entered into between VENTIRA and the client. For example, a client may restrict or prohibit transactions in certain types of secu- rities. Non-Discretionary Services VENTIRA offers two non-discretionary services: a portfolio advisory service and an investment advisory service. a. The Portfolio Advisory Service is similar to the discretionary portfolio management service in terms of the investment approach; however, VENTIRA requires client consent before effecting any securities transaction. VENTIRA provides portfolio advice and trading recommenda- tions but all decisions regarding the investment of the Account reside with the client. This ser- vice is designed for clients who desire holistic management of their Account but who want to retain involvement in every investment decision. As a result, clients under this service offering may not be invested in the same manner as those clients with the Discretionary Asset Management service. b. The Investment Advisory Service permits clients to consult with VENTIRA from time to time on the client’s specific investment questions per- taining to individual investment opportunities as identified by the client. VENTIRA provides its ad- VENTIRA Private Wealth Management Ltd. CRD 164792 - page 4 - vice concerning the merits of particular invest- ments (i.e., whether to purchase or sell a security). This service offering is designed for clients who wish to use VENTIRA as an advisory resource when making investment decisions but who desire to retain responsibility for determining the allocation of their investment portfolio. VENTIRA does not monitor the overall risk of the Accounts of clients selecting this service. Ultimate responsibility for the investment of the client’s Account rests solely with the client. If explicitly required by a non-discretionary client, VENTIRA may implement investment ideas which do not pertain to VENTIRA’s investment universe. VENTIRA will disclose to the client, if an investment idea is not part of its investment universe. Wrap Fee Programs VENTIRA does not participate in wrap fee pro- grams. Assets under Management and Advisement VENTIRA managed approximately $ 495 million on a discretionary basis and approximately $34 million on a non-discretionary basis as of De- cember 31, 2023.