A. Description of the Advisory Firm Turn8 Private Wealth Inc. is a corporation organized in Canada. The firm was formed in March of 2012, and the principal owner is the CSM Trust, which is controlled by Craig Stuart McFadzean. B. Types of Advisory Services Turn8 Private Wealth Inc. (hereinafter “Turn8”) offers the following services to advisory clients: Investment Supervisory Services Turn8 offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Turn8 creates an Investment Policy Statement (IPS) for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Turn8 believes in a written investment policy as the only way to demonstrate a thoughtful process and make well-informed, prudent investment decisions. The firm will help clients develop their overall investment policy approach, create their IPS which outlines the investment selection and monitoring process, and provide unbiased advice on the most appropriate options for their plan. Turn8’s investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Turn8 evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Turn8 will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Turn8 may also provide educational seminars/workshops or publication of newsletters free of charge as part of its portfolio management services. Services Limited to Specific Types of Investments Turn8 generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, hedge funds, REITs, commodities, options, private placements, and government securities. Turn8 may use other securities as well to help diversify a portfolio when applicable. Subadvisor Services Turn8 acts as a subadvisor to advisors unaffiliated with Turn8. These third-party advisors outsource portfolio management services to Turn8. This relationship is memorialized in each contract between TURN8 and the third-party advisor and is disclosed to the respective client. Retirement Rollovers A client leaving an employer typically has four options (and may engage in a combination of these options): I. Leave the money in their former employer’s plan, if permitted, II. Roll over the assets to their new employer’s plan, if one is available and rollovers are permitted, III. Rollover to an IRA, or IV. Cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Turn8 may recommend an investor roll over retirement plan assets to an Individual Retirement Account (IRA) managed by Turn8. As a result, Turn8 may earn an asset-based fee on those assets. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Specifically, if Turn8 recommends a client roll over its retirement assets to a Turn8 managed account, such a recommendation creates a conflict of interest if Turn8 will earn new (or increase its current) compensation as a result of the rollover. Depending on the options available to the individual, rolling over assets to a Turn8 managed account could incur higher fees than leaving it in a current plan or moving to another employer-sponsored plan. In contrast, a recommendation that a client or prospective

client leave their plan assets with their old employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to Turn8. Turn8 has an economic incentive to encourage an investor to roll plan assets into an IRA that Turn8 will manage. There are various factors that Turn8 may consider before recommending a rollover, including but not limited to: I. The investment options available in the plan versus the investment options available in an IRA, II. Fees and expenses in the plan versus the fees and expenses in an IRA, III. The services and responsiveness of the plan’s investment professionals versus Turn8’s, IV. Protection of assets from creditors and legal judgments, V. Required minimum distributions and age considerations, VI. Employer stock tax consequences, if any, VII. Plan’s withdrawal options or limitations, before and/or after retirement No client is under any obligation to rollover retirement plan assets to an account managed by Turn8. C. Client Tailored Services and Client Imposed Restrictions Turn8 offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. PORTFOLIO CONSTRUCTION Turn8 views the world of investing using the fundamentals of Modern Portfolio Theory and the advanced teachings of the CFA program. The basic concept is to maximize a portfolio’s expected return for a given amount of risk, or equivalently minimize risk for a given level of expected return. This is obtained by carefully choosing the mix and allocation of various assets to establish an efficient portfolio using a Core and Satellite approach. In the Core and Satellite approach we divide our portfolios into two categories; Core strategies that tactically provide broad exposure and Satellite strategies that have the potential to deliver higher returns given market conditions. To anchor our Core portfolio allocations, we begin with an understanding of the “Big Picture” Global Macro trends. This process helps Turn8 identify the best risk/reward opportunities across all asset classes spanning the global financial spectrum (economic forecasts, inflation levels, geopolitical risk, fiscal constraints and monetary policy). The results of our Global Macro research is an identification of key asset classes and sectors that represent our strategic asset allocation mix. The most efficient way to gain the exposure needed is the use of country, sector and style ETFs that provide a greater degree of diversification without exposing our clients to single name risk. This approach allows us to manage volatility and achieve diversification while participating in the market intelligently and in a controlled manner. The Satellite allocation of Turn8’s portfolios gives our clients the opportunity to pursue independent or market-driven investment ideas. Satellite investments are typically individual companies, but could also include structured products, commodities, or hedge funds among other assets. Turn8, along with their global research, allocates the satellite investments and the time horizon to ensure our clients obtain the maximum benefit of each holding. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Turn8 from properly servicing the client account, or if the restrictions would require Turn8 to deviate from its standard suite of services, Turn8 reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Turn8 does not participate in any wrap fee programs. E. Assets Under Management Turn8 has the following assets under management: Discretionary Assets: Non-Discretionary Assets: Date Calculated: $259,726,080 0 March 31, 2024