Introduction In November 2012, Validus Growth Investors, LLC, doing business as Validus Investment Advisors, (“Validus”) with headquarters in San Diego, CA was established by Mark C. Scalzo, Managing Partner and Chief Investment Officer, to provide investment advisory services to a broad range of clients by implementing fundamental, bottom-up growth equity strategies with active market risk mitigation. Mr. Scalzo currently owns 76.1% of the voting rights of Validus. Principal Members Mark C. Scalzo As Managing Partner and Chief Investment Officer, Mark Scalzo is responsible for design, implementation, and enhancement of Validus’ investment philosophy and process, managing all of Validus’ investment strategies and overseeing day-to-day operations and research efforts. Advisory Services Offered Validus manages several model strategies which are used to manage portfolios across several types of relationships as described below. The Validus model strategies are composed of equities or a combination of equities and ETFs. Separate Account Management (“SAM”) Validus offers separate account investment management services to retail clients, institutional clients, including public and private pension plans, endowments and foundations, independent RIAs, and high net worth individuals. All separately managed client accounts are invested according to a specific Validus model strategy, consistent with each client’s risk profile. The client accounts using a particular model strategy are similarly managed, rebalanced to the dynamic model portfolio on a periodic basis, and subject to Validus’ trade allocation policy. All separate account clients can place reasonable client-specific restrictions regarding their accounts as agreed with Validus. Asset Allocation Services On a limited basis, Validus provides asset allocation portfolios to existing high net worth clients whose changing risk profiles require more conservative portfolios or income over capital appreciation. These portfolios are constructed utilizing portfolio optimization at the asset class level and implemented with individually scored mutual funds and/or ETFs. To the extent mutual funds are utilized, Validus does not charge a commission and seeks the lowest cost advisory share class available on its custody platform. Form ADV Part 2A 6 Model Portfolio Advisory Services Institutional Portfolio Advisor to Third Party Investment Advisers Validus also provides its model equity strategies to certain investment advisory firms and investment programs, including Unified Managed Account (UMA). For these relationships, Validus does not interact directly with the individual end-client, but interfaces with the third- party investment adviser. For most of these relationships, Validus provides regular management and maintenance of these model portfolio strategies, including continuous monitoring, and provides re- balancing trade instructions to the third-party investment adviser. The model equity strategies provided to third

party investment advisers are the same strategies used by Validus in managing portfolios for SAM clients and for the Destra Multi-Alternative Fund for which Validus serves as sub-adviser, as described in more detail below. Sub-Adviser to Investment Company Validus is engaged as the investment sub-adviser to the Destra Multi-Alternative Fund (the “Fund”), a closed-end registered investment company traded on the New York Stock Exchange under the symbol DMA. As a sub-adviser, we provide investment advice, and the Fund is an available investment option for our SAM clients. Therefore, investors in the Fund may also be SAM clients; however, the Fund will be open to any investor meeting the Fund’s minimum investment levels. Since Validus is the sub-adviser to the Fund and receives a management fee for its services, Validus has an incentive and inherent conflict of interest to favor the Fund when selecting investments for SAM clients. Increases in the value of the Fund will result in increases in the fund management fee paid to Validus. However, if a SAM client portfolio managed by Validus holds a position in the Fund, the Fund assets will be excluded from the investment advisory fee charged to the client. Please refer to Item 5 of this Brochure for a description of our fees. Validus may determine that the Fund is a suitable alternative investment vehicle for the separate account clients. When Validus utilizes the Fund on behalf of clients, Validus does not receive a commission and will seek to utilize the institutional share class for clients, with permission from the Fund. We maintain limited power of attorney to act on a discretionary basis when managing the Fund. We are responsible for investment selection, asset allocation, and asset management decisions regarding the Fund, which generally mirror those of the Validus equity strategies provided to third party investment advisers and SAM clients as noted above. When managing the Fund, we will select the following general types of investments:
• Public and Private Real Estate Investment Trusts (REITs)
• Public and Private Business Development Companies (BDCs)
• Limited Partnerships Form ADV Part 2A 7
• Private Investment Funds
• Common Stocks
• Debt Securities
• Exchange Traded Funds (ETFs), mutual funds, and closed-end funds
• Master Limited Partnerships (MLPs) Research Services Validus provides investment research services such as security analysis and asset association to clients, which include investment advisers, broker dealers, and financial institutions. Validus does not directly manage the assets under these relationships. Assets Under Management / Advisement As of December 31, 2023, Validus Growth Investors has $123,717,341 in discretionary assets under management and $124,935,425 in non-discretionary assets under management. Total assets under management are $248,652,766. Additionally, Validus has another $356,188,875 under advisement.