A. Firm Information Elm Partners Management LLC (“Elm Partners” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Wyoming. Elm Partners was founded in March 2012 and is owned by Cygnet Capital LLC and operated by Victor J. Haghani (Chief Investment Officer) and James White (Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Elm Partners. B. Advisory Services Offered Elm Partners offers investment advisory services to pooled investment vehicles, individuals, high net worth individuals, trusts, estates, charitable organizations and businesses and corporations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Elm Partner’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Private Fund Services The Advisor provides advisory and sub-advisory services to pooled investment vehicles including hedge funds (each a “Fund” and collectively the “Funds”). These services are detailed in the offering documents for each Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor manages each Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. Certain Clients may be solicited to invest in the Funds. The recommendation to invest in the Funds poses a conflict of interest between the interests of the Advisor and the interests of the Client, as the Advisor is incentivized to increase the amount of assets in the Funds in order to increase the revenue generated for the Advisor and/or affiliated entities. This conflict is mitigated as Clients will pay fees in accordance with the offering documents and fees will either be reduced or waived by the Advisor for its investment management services on assets invested in the Funds. Clients of the Advisor are under no obligation to invest in the Funds. Investors should refer to the offering documents of the Funds for complete information on the investment objectives, policies, and guidelines of the Funds. Managed Account Investment Program The Advisor provides portfolio management services to individuals and high net worth individuals (collectively “Managed Clients”). Managed Clients may engage with the Elm Partners to participate in the investment management program designed by Elm Partners (“Managed Account Investment Program”) as described below. The Advisor and the Managed Client will agree on their investment objectives for the account[s] and will also have the opportunity to impose any restrictions on the account[s]. The Advisor will attempt to achieve the long- term objective of outperforming a Benchmark Portfolio through a combination of cost efficiency, diversification, responsiveness to changes

in asset valuation, responsiveness to momentum in asset prices, and managing Managed Client Assets in a tax aware (but not tax-optimized) fashion. The starting point of the investment process is a “Baseline Portfolio”, which currently consists of fifteen different asset categories, although this is subject to change by the Manager. The Baseline Portfolio will be communicated to Clients via periodic communication. The Baseline Portfolio is constructed to have roughly similar risk to the Benchmark Portfolio described above. The Baseline Portfolio is, by design, not a strictly market capitalization Page 5 weighted portfolio. From time to time (but at least annually), the Baseline Portfolio will be reviewed, and may be revised for a variety of reasons (e.g., as new, liquid and low-cost vehicles permit additional asset classes to be included in the Baseline Portfolio and enable a greater effective diversification or due to other relevant reasons). Roughly every seven (7) days, each asset class will be evaluated from both a valuation and momentum perspective, and desired deviations from the Baseline Portfolio will be calculated to provide raw desired allocation weights. If the sum of the raw desired allocation weights (ignoring cash) is less than 100%, then these weights form the basis of the desired portfolio. If the sum of the raw desired allocation weights is greater than 100%, each asset class will be proportionally scaled down so that the modified weights add up to 100% (and cash is given a weight of 0%). The desired allocation of an individual asset class can be at most doubled relative to the baseline weights (subject to the no-leverage constraint) or set at zero, depending on the attractiveness of each asset category based on the valuation and momentum measures. Based upon this evaluation process, the portfolio is then rebalanced using low-cost mutual funds, ETFs, ETNs or similar instruments and cash equivalents to try to match the desired allocation weights as closely as possible, which is subject to considerations described below. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging Elm Partners to provide investment advisory services, each Client in the Managed Account Investment Program will enter into an investment management agreement. Each investor in one of the Funds managed by Elm Partners will receive a Private Placement Memorandum and execute a subscription agreement that defines the terms, conditions, authority and responsibilities of the Advisor, the Fund and the Investor. D. Wrap Fee Programs Elm Partners does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2023, Elm Partners manages $1,503,909,966 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.