Envisage Advisory (hereafter “Envisage”) was incorporated as Envisage GmbH. under Swiss law, in the Canton of Zürich, in 2006. Envisage is an advisory firm that mostly provides advisory services to financial institutions and small corporations. Envisage occasionally works with private individual clients who require high level advisory, wealth and financial planning and general advisory services. We provide clients with advisory, consulting, planning and family office services as well as life insurance, tax and estate planning services. Envisage estimates that approximately 80% of services provided and work performed have a U.S. connection in some way. Estate planning includes advice on inter-generational wealth transfer, dealing with succession issues and philanthropic planning advice. We work with a very extensive international network of subject matter experts and service providers in the various areas needed to deliver comprehensive wealth planning solutions. These specialists are located in a number of jurisdictions including Switzerland, the United Kingdom and the United States of America. Envisage generally takes a management and coordination role in managing delivery of a multitude of services from different providers to achieve a specific client objective. Envisage GmbH does not currently manage any financial or bankable assets nor does Envisage provide direct investment management services. Further, Envisage does not provide direct investment advice on assets beneficially owned by U.S. persons (managed segregated accounts). We are focused on advisory, consulting and the structuring of overall solutions. Particularly in the area of Private Placement Life Insurance solutions, where Envisage takes the role and function of the intermediary. The intermediary function being the entity between the end client (policyholder and ultimate beneficial owner) and the asset manager and/or insurance carrier. Envisage however, is not a registered insurance broker in Switzerland, the United States nor in any other jurisdiction. Private Placement Life Insurance structuring is often in combination with trusts, foundations and other structures. Envisage works with a wide network of lawyers, trust companies and other professionals. Although Envisage does not currently provide investment advice, Envisage does however reserve the right to start again offering and providing direct investment advisory services to both U.S. and non- U.S. persons in the future. Envisage GmbH. Zürich, 14 March 2024 Page 4 We can provide much the same services for non-U.S. persons. Ie., persons with no connection whatsoever to the United States. Notwithstanding, the niche Envisage has developed and built lies primarily in working with U.S. connected advisory and structuring. Advisory Services Envisage does not provide discretionary and/or non-discretionary portfolio management and/or direct investment advisory services on assets beneficially owned by U.S. persons or any other persons. Ie., direct managed accounts / separately managed accounts for U.S. persons. We currently also do not provide direct investment advisory services on any assets owned by non-U.S. persons. Ie., Envisage does not currently perform direct asset management services. Envisage does reserve the right to start offering and providing discretionary and non-discretionary portfolio management and direct investment advisory services to U.S. persons, i.e., direct managed accounts for U.S. persons, should it make sense to do so. Envisage provides general advisory and consulting services, including advice which we consider could be construed as investment advice under the Investment Advisors Act of 1940 act. In particular as such advice and services relate to Envisage' activities in Private Placement Life Insurance; our role as intermediary on life insurance policies (Deferred Variable Annuities, Variable Universal Life, etc.) In addition, advisory services are occasionally provided to private individuals, trusts, estates, charitable organizations, small corporations or other similar entities. We work with our clients to evaluate and establish their specific needs, goals and investment profiles. We place great importance on:
• proper wealth planning
• succession planning
• estate planning
• risk management
• tax planning, tax compliance and optimisation Envisage may advise clients on ways to enhance the benefits of their overall wealth management plan. Envisage may engage, use and manage the services of selected third party providers, subject matter experts and other specialists (tax accountants, tax attorneys, trustees, etc.) as needed. This is a key competency differentiating Envisage from other providers - in that we manage a network of third party providers toward providing integrated solutions for clients. Variable Annuities and Variable Life Insurance Products Envisage earns a substantial percentage of its revenue through acting as intermediary for variable universal life insurance and variable annuity products. Before making any recommendation or proposal involving a variable annuity or life insurance product, it is Envisage policy to:
• Inform the client of the general terms of the various features of the variable annuity or life insurance product
• Inform and explain to the client and if appropriate, the clients advisors, the benefits, advantages and disadvantages of variable annuities and life insurance
• Inform the client and if appropriate, the clients advisors, the total costs associated with variable annuities and life insurance
• Reasonably believe that the client will benefit from the features of the variable annuity or life insurance product
• Ensure that any contract riders, risk components and/or product enhancements, and the underlying subaccounts to which premium payments are allocated, are appropriate for the client Before

making a recommendation involving an exchange of a variable annuity or life insurance product or a change in the type, nature, structuring, policyholder(s), insured person(s) or beneficiary(s) of the policy, it is Envisage policy to:
• Consider whether: o the client would incur a surrender or other charge o be subject to the commencement of a new surrender period o any or what material changes could be to the terms and conditions of the policy o lose existing benefits Envisage GmbH. Zürich, 14 March 2024 Page 5 o be subject to increased fees
• Be satisfied that the client would benefit from product enhancements and improvements
• Factor in whether the client has had another variable annuity exchange within the preceding 36 months In the intermediation of life insurance products (Private Placement Life Insurance) for U.S. persons, Envisage fulfills the role of intermediary between:
• The issuing or maintaining insurance company and the client
• The responsible asset manager and the client Because variable life insurance and variable annuity products have investment product characteristics and the Deferred Variable Annuity (DVA) product in particular is regulated by the SEC, Envisage took the decision to register as an Investment Advisor under the act of 1940 and to maintain this registration. Thus subjecting Envisage to the regulatory oversight and jurisdiction of the United States. Discretionary Investment Services Should a client wish to receive discretionary investment advice and if this is agreed to by us, the client will sign a Discretionary Asset Management Mandate (hereafter ‘Discretionary Mandate’) with Envisage. Under the Discretionary Mandate, Envisage is authorized to manage the assets on a fully discretionary basis, according to the client’s investment needs, objectives and restrictions as set out in the Investment Policy Statement (IPS). Under the Discretionary Mandate, we will be responsible for determining the client’s asset allocation and for investing the client’s assets subject to pre-defined restrictions, if any. We will periodically review and may update the asset allocation and holdings, such as in response to economic, political or market conditions. Non-Discretionary Investment Services Should a client wish to receive non-discretionary investment advice and if this is agreed to by us, may sign a mandate for non-discretionary investment services (hereafter ‘Non-Discretionary Mandate’) with Envisage. Under the Non-Discretionary Mandate, we will provide investment advisory services and will respond within a reasonable time frame to the client’s correspondence and telephone calls requesting to discuss Envisage views and recommendations regarding economic events, advisable strategic and tactical asset allocation and investments (e.g., securities, securities markets, funds, currencies, market trends) and related investment options, strategies, and opportunities. Envisage will discuss economic events and investment possibilities with client at reasonable length. Envisage may also, but is not obligated to, contact the client from time to time (by phone, email, letter, or other means) with recommendations that we believe may be appropriate for the client based on the client’s investor profile. Envisage is not registered as a securities broker-dealer and, therefore does not provide brokerage services. As is standard practice in Switzerland, brokerage services are generally conducted by the custodian bank. Special arrangements can be made by the client to direct brokerage at the wish of the client. Envisage’s investment recommendations under any Agreement concluded may relate (but are not limited) to stocks and other equity securities, bonds and other debt securities, money market and other cash management instruments, derivatives and other investments. Under the Non-Discretionary Mandate, the client will be solely responsible for making all investment decisions and Envisage will not have any discretionary authority over the client’s account. As per the terms of the Non-Discretionary Mandate, Envisage will not monitor the client’s investment portfolio or other assets to determine whether changes should be made thereto. Finally, we will not monitor information that we previously provided or recommendations we previously made to the client to determine whether such information and recommendations require updating to reflect changed market conditions or changes to the client’s investment profile. Asset Manager Selection & Sub-Advisory Mandates Envisage may occasionally support clients in the evaluation and selection of non-affiliated third-party asset managers. Particularly where a client has special investment needs and/or objectives, we may in good faith refer the respective client to third-party asset managers. Envisage may have referral agreements with some third-party asset managers and may therefore be compensated for the referral. Envisage GmbH. Zürich, 14 March 2024 Page 6 The existence of the referral agreement and the amount to be paid under the agreement is always disclosed to the client as a matter of course. It is at the client’s discretion to decide whether such third- party asset managers are suitable or not. Envisage will generally have no further obligations after such a referral. In particular, Envisage will not accept any liabilities for the performance and quality of service provided by such third-party asset managers that the client chooses to work with. In general Envisage does not enter into sub-advisory mandates with other managers. Client Needs & Restrictions We tailor our Advisory Services to the individual needs and objectives of clients based on the information and personal specifications that clients provide to us. Since Envisage does not directly manage client assets, the question of investment restrictions allowable by clients is not relevant.