A. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). FitzRoy is a private limited liability corporate entity that offers non-discretionary investment management services for separate accounts of high net-worth individuals and trusts (“Advisory Clients” or “Clients”). The Advisory Clients include both U.S. and non-U.S. persons. With respect to Advisory Clients, FitzRoy has responsibility for making investment recommendations, subject to the specific guidelines established for each such Advisory Client in accordance with the Advisory Client’s needs, long-term goals and risk profile. In particular, FitzRoy makes recommendations with respect to customized asset allocations for its Advisory Clients, including allocations to separately managed accounts (“Separately Managed Accounts”), mutual funds, exchange-traded funds (“ETFs”) and pooled investment vehicles, including hedge funds and private equity funds (“Investment Vehicles”), in each case, managed by unaffiliated professional investment managers (“Managers”). Jose A. Fernandez is the owner and managing member of FitzRoy. Mr. Fernandez is based in the United Kingdom and provides services to FitzRoy through an affiliate, FRIA Consulting Limited. FRIA Consulting Limited does not provide investment advisory services to clients and is not required to be registered as an investment adviser with the SEC. B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. FitzRoy is an investment advisor specializing in making recommendations to its Advisory Clients (on a non-discretionary basis) with respect to overall Asset Allocation as well as to investments in Investment Vehicles, Separately Managed Accounts managed by Managers as well as mutual funds and ETFs. The Managers selected by FitzRoy pursue a variety of investment strategies, focus on different geographic sectors and invest in a wide range of securities. In connection with making recommendations to Advisory Clients, FitzRoy generally creates a customized asset allocation program for each Advisory Client which reflects that Advisory Client’s individual risk tolerance, investment outlook and short-term and long-term goals. FitzRoy does not group its Advisory Clients into standardized allocation programs, but instead creates an individualized plan for each Advisory Client. Capital preservation is an important aspect of FitzRoy’s investment approach. FitzRoy generally does not provide investment advice to its Advisory Clients with respect to specific securities (other than with respect to mutual funds, ETFs and the securities

of pooled investment vehicles in the fund of funds context) but may refer an Advisory Client to a Manager or broker-dealer for such advice. Portfolios advised by FitzRoy for its Clients will usually, but not always, provide for diversification across investment strategies and Managers. Categories of investments typically include fixed income, equities and so-called ‘alternative investment vehicles’ such as hedge funds and private equity and real estate funds. FitzRoy may also advise Clients regarding tactical asset allocation in order to take advantage of perceived opportunistic investments in the marketplace as a result of short-term mispricing. FitzRoy uses a variety of tools, both qualitative and quantitative, to measure the potential risks of the various asset classes it recommends and to evaluate the Managers investing in those asset classes. FitzRoy schedules investment strategy and performance review calls and in some cases meets with existing Managers and potential new Managers on a regular basis and maintains statistical data, including historical returns, various measures of volatility and capital loss, peer group screening, gross and net exposures, geographic and sector exposures and liquidity. It also performs due diligence on the Managers (either directly or via the due diligence teams of the custodian firms through which the Clients invest), including periodical calls and site visits. C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. The advisory services provided by FitzRoy to its Advisory Clients are tailored to the investment objectives, investment strategy and investment restrictions set forth in the Advisory Client investment advisory agreements. Recommendations that are made for each Advisory Client stay within the confines of that Advisory Client’s stated risk tolerance, time horizon and strategy, and, if applicable, are subject to restrictions applicable to the account. D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. FitzRoy does not participate in “wrap fee arrangements,” whereby clients select FitzRoy to manage funds through an investment program presented to the clients by a third-party program sponsor. E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2023, FitzRoy managed $662,347,896 in client assets on a non-discretionary basis. FitzRoy does not manage any assets on a discretionary basis.