PATHSTONE FAMILY OFFICE, LLC

Pathstone Family Office, LLC (“Pathstone,” the “firm,” “we,” “our,” or “us”) is an integrated wealth management organization serving ultra-high-net-worth (“UHNW”) families, single family offices, endowments, foundations, and other clients. Pathstone provides a broad range of investment advisory and professional services to its clients. As a registered investment adviser, Pathstone primarily focuses on complex wealth management solutions for UHNW families and other clients providing investment advice, manager sourcing and selection, asset allocation, investment policy and portfolio construction or other types of investment consulting services on a discretionary and non-discretionary basis for the benefit of advisory clients and Pathstone’s unregistered pooled investment vehicles (“Affiliated Funds”). In addition to these services, the firm offers a wide range of non-investment wealth management services (“Professional Services”) designed to complement and support clients across multiple dimensions of their financial and personal lives. Specific services arrangements are agreed upon in written agreements with the applicable client depending on the client’s unique preferences. Pathstone was founded in 2010 and expanded organically and through strategic acquisitions as it evolved to meet the needs of our clients. Today we employ approximately 775 employees across 22 offices in the United States, including affiliates. Collectively, inclusive of acquired legacy organizations, we have provided advisory services to clients since 1986. Pathstone is privately owned with partner participation through equity ownership, which is the foundation of the firm’s culture and character. Additionally, the firm’s equity ownership includes investment vehicles controlled by Kelso & Company (“Kelso”) and Lovell Minnick Partners, LLC (“LMP”), and certain Pathstone clients, in each case through intermediate subsidiaries. Please see Item 10 for additional information regarding ownership. As of December 31, 2025, Pathstone managed $65,580,318,345 of discretionary assets and $44,715,555,393 of non-discretionary assets for a total of $110,295,873,738 regulatory assets under management (“RAUM”) as reflected in Form ADV, Part 1A, Item 5F (“Item 5F of Part 1A”). Observations Regarding Pathstone Client Asset Categories of Regulatory Assets Under Management, Assets Under Advisory and Assets Under Administration Pathstone may identify or refer to different client asset categories in various client deliverables, filings, agreements and other materials as “Regulatory Assets Under Management,” “Assets Under Advisory,” or “Assets Under Administration” (or

“Reporting-Only Assets”) for the purpose of reporting or describing these categories to clients or regulators. This is not a complete or exhaustive list, but rather a small sampling of the various descriptions that may be used to describe client asset categories within firm materials. Additionally, the firm utilizes different legacy reporting practices across certain offices resulting in unique client identifiers, names, or descriptions of advisory asset categories, in part due to the integration of multiple legacy organizations, portfolio accounting systems, client relationship management (“CRM”) software and client reporting preferences such that some client assets may be assigned to different categories depending upon the legacy practices of a particular office. Additionally, please note that the aggregate values reported on each category may be significantly different, such that one category may be much larger or smaller than another. Lastly, each category may be shown separately or together (e.g., aggregated) depending upon the facts and circumstances as well as the firm’s needs. Regulatory Assets Under Management (“RAUM”). For calculating the firm’s RAUM in Item 5F of Part 1A, Pathstone includes the securities portfolios for which we provide continuous and regular supervisory or management services. Generally, continuous and regular supervisory or management services apply to accounts over which Pathstone has discretionary authority or, in the case of non-discretionary authority, Pathstone has ongoing management responsibility to make recommendations to buy or sell securities in securities portfolios and subsequently arranges such purchase or sale activity. Furthermore, to the extent clients grant Pathstone discretion to hire and fire unaffiliated, third-party managers, these assets are included in our RAUM calculation. Typically, such authority is set forth in written agreements with each client. Additionally, accounts for which we provide continuous and regular supervisory or management services, but do not receive compensation, are included in RAUM. Assets Under Advisory (“AUA”). For calculating the firm’s AUA, Pathstone includes assets where we provide advice or consultation but do not otherwise provide continuous and regular supervisory or management services. Such services include, for example, financial planning, 401(k) allocation reviews, or other consulting services where the assets are used for informational purposes to gain a full perspective of a client’s financial situation, but Pathstone does not have direct trading activity or authority over the securities portfolios. It is important to note that Pathstone may include certain client assets in the AUA calculation where Pathstone provides holistic advice or oversees all or a portion of the securities portfolios’ positioning, sizing, or performance, but the firm may only be acting on a portion of the securities portfolios. For example, in a situation where Pathstone advises on the whole client relationship, but a portion of the securities portfolios is directly managed by an unaffiliated third-party investment adviser or consultant, Pathstone may include such client assets in its AUA calculation.

Assets Under Administration (Reporting-Only Assets). Subject to the terms of a client’s written agreement, Pathstone may track certain assets separately and apart from RAUM and AUA in a category referred to broadly herein as “Reporting-Only Assets.” These reporting-only situations may vary by office and involve the tracking of positions, size, performance and other securities portfolio information across the legacy organizations’ portfolio accounting systems and CRM software. The reports may be designed and tailored to a specific client’s reporting preferences. These reporting services are charged fees differently depending upon the scope and size of the tracking required and do not involve Pathstone providing continuous and regular supervisory or management services over such Reporting-Only Assets or involve situations where Pathstone has the authority or ability to effect changes in securities portfolios. Lastly, certain balance sheet assets may be tracked as Reporting-Only Assets and therefore are not included in RAUM or AUA. Observations Regarding the Methodology for Computing Number of Clients and Accounts Pathstone may describe or refer to advisory clients in various materials, deliverables, regulatory filings, and agreements as “client relationships,” “family relationships,” “client accounts,” or “client portfolios” depending upon the context and the reporting needs. This is not a complete or exhaustive list, but rather a small sampling of the various descriptions that may be used to describe advisory clients throughout firm materials. As noted above, the firm utilizes different legacy reporting practices across certain offices resulting in unique client identifiers, names, or descriptions of advisory clients, in part due to the integration of multiple legacy organizations, portfolio accounting systems, CRM software and client reporting preferences (e.g., flash estimates, monthly, quarterly, or other periodic reporting requirements of advisory clients). As a result, with respect to the number of clients listed in Item 5D of Pathstone’s Form ADV Part 1A (“Item 5D of Part 1A”), Pathstone includes each family relationship and each Affiliated Fund in the client count but excludes limited partners of these pooled investment vehicles that are not otherwise advisory clients of Pathstone. Additionally, for purposes of Item 5D of Part 1A, Pathstone generally does not separately count each sub-family relationship. Subfamily relationships are often grouped together using internal criteria such as the consolidation of related individuals and family entities covered under the same periodic reports, investment policies and/or agreements. A counting of each sub-family relationship, or alternatively each account, would result in a number much higher than the actual number of family relationships. With respect to the “Total Number of Accounts” in Item 5F of Part 1A, Pathstone generally counts each individual custody or prime broker account for each sub-family relationship, including individuals and familyrelated entities; where appropriate based on the nature of a legacy acquired advisory business and reporting practices, an account reported in Item 5F of Part 1A refers to a single client advisory relationship that may encompass a group of related individuals or

entities. One unintended outcome of this methodology is that dividing the total discretionary AUM by the number of accounts in Item 5F of Part 1A (or the number of clients listed in Item 5D of Part 1A) results in an arithmetic average of AUM for each family relationship much smaller than the actual numerical average. Pathstone Affiliates. Pathstone is affiliated by common control and ownership with the following companies whose services are offered to Pathstone clients. Willow Street Trust Company of Wyoming, LLC, a trust company, Willow Street Group, LLC, a fiduciary services firm, and Willow Street Trust Company (formerly known as Laurel Trust Company) (collectively, referred to herein as “Willow Street”) provide professional solutions for the administration, management, and stewardship of assets. Advisor Partners II, LLC doing business as Concentric or Concentric Innovation (CRD #321633) (“Concentric”) is a separately registered investment adviser providing discretionary subadvisory services through two distinct investment programs and model portfolio management services. Cambrian Capital Management, L.L.C. (CRD #324623) (“Cambrian”) is a separately registered investment adviser that sponsors anchor investments with highly qualified portfolio managers who are interested in starting their own private equity firms. Please see Concentric’s and Cambrian’s separate Form ADVs for additional details available on the SEC’s website at www.adviserinfo.sec.gov. Additionally, certain private funds sponsored by Pathstone or its affiliates, are considered Pathstone affiliates (“Affiliated Funds”). Furthermore, related affiliated entities that serve either as the general partner, portfolio manager, investment manager, investment adviser, sub-adviser, administrative manager, or in other similar types of investment, administrative or operational service roles on behalf of Pathstone’s Affiliated Funds program are treated as Pathstone affiliates. Please see Item 10 for additional details as well as Form ADV Part 1A under Item 7.A. Financial Industry Affiliations and Item 7.B. Private Fund Reporting for a complete list of Pathstone’s Affiliated Funds and affiliated entities related to such funds. Furthermore, Pathstone has entered into separate service agreements with its affiliates to provide better economies of scale and gain other efficiencies. Pathstone provides certain administrative and operational services to affiliates such as business support, information technology, human resources, vendor coordination, legal, compliance and trading support services solely for the internal benefit of its affiliates.. This is not an exhaustive or complete list, as the nature, scope, and amount of these services that are utilized differ between affiliates. Pathstone Unaffiliated, Third-Party Service Provider Relationships. Lastly, Pathstone has entered into certain service agreements with unaffiliated, third-party service providers (e.g., commonly referred to as “white label agreements” or other “service agreements”) in situations where Pathstone either provides or receives services from

these partners. Please see Item 10 for additional information regarding Pathstone’s affiliates and other third-party service provider arrangements. B. INVESTMENT SERVICES

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Broad Categories of Services*

Fee Arrangement Types**

INVESTMENT-RELATED SERVICES SUMMARY Investment Advisory

Asset-based fee with fixed or tiered percentage and/or breakpoints; fixed/flat fee; performance-based fee, etc.

Investment Reporting

Asset-based fee with fixed or tiered percentage and/or breakpoints; fixed/flat fee.

Investment Administration

Asset-based fee with fixed or tiered percentage and/or breakpoints; fixed/flat fee.

PROFESSIONAL SERVICES SUMMARY ACCOUNTING-RELATED SERVICES - PERSONAL CFO SERVICES Banking, Bill payment Services, Vendor Management, Payroll, Lifestyle Management, etc.

Fixed/flat fee.

TAX-RELATED SERVICES Tax Compliance, Audit Defense, Research, etc.

Time & materials based on fixed/flat rate or fixed/flat fee.

Family Office Structure and Financial Reporting

Fixed/flat fee.

WEALTH PLANNING RELATED SERVICES Financial, Tax & Estate Planning, Philanthropy, Insurance, etc.

Fixed/flat fee.

RISK MANAGEMENT RELATED SERVICES Insurance Related (Medical, Travel, Personal Security, Property & Causality)

Fixed/flat fee.

EXTENDED FAMILY OFFICE SERVICES Property Management, Debt Management, Financial Analysis, Family Office Administration, Aviation Advice, etc. PRIVATE FUND SPONSORSHIP OR SUB-ADVISORY RELATIONSHIP - AFFILIATED FUNDS

Fixed/flat fee. Asset-based fee with fixed or tiered percentage and/or breakpoints; fixed/flat fee; performance-based fee, revenue share, etc.

*Categories listed are illustrative samples - not all services are shown under each category. **Fee arrangements are negotiable depending upon the facts and circumstances of each engagement such as size, complexity and scope of the relationship contemplated. This may result in different clients paying less or different fee arrangements. Fee arrangements shown are provided for illustrative and informational purposes only.

Fee Arrangements typically begin to accrue as of the effective date of the fully executed agreement unless otherwise agreed to by the parties. To the extent that related parties (e.g., family members or related entities) are covered by the same agreement, the Fee Arrangements will generally be allocated among such parties on a pro rata basis (i.e., in proportion to the respective AUM of such related parties), equal-weighted basis, or as otherwise agreed to by the parties. With respect to billing arrangements, to the extent certain related parties wish to be treated differently for billing purposes, such differential treatment will typically be reflected in the relevant agreement or an addendum or amendment thereto. For example, a family member may elect to bear the Fee Arrangements for other family members or family-related entities. Therefore, invoicing and account debiting arrangements are customizable to suit each client’s preferences. Fee Arrangements are typically deducted automatically from specified client accounts; however, arrangements may be made to invoice clients directly. Observations Regarding Prospective Clients & the Time Period Before Client Onboarding Process Pathstone has developed an interactive learning experience for prospective clients (“prospects”) that typically begins with high-level introductory conversations about the firm and its services. These conversations may evolve into more detailed and comprehensive discussions that may ultimately lead to our client onboarding process (collectively referred to herein as the “PathForward”). If a prospect determines to move forward with a more detailed series of conversations, the prospect or its representatives will typically provide Pathstone enough information for the firm to prepare a detailed analysis (or similar workpaper) of the prospect’s needs. During PathForward, Pathstone generally provides an estimated pricing level of the overall engagement and/or an individual break-out of costs for each service once the prospect’s full financial picture and needs are assessed. The timing, presentation, and delivery of fee information to prospects may differ between offices. Additionally, due to the number and complexity of different legacy organizations’ fee schedules and services, Pathstone does not provide a percentage or dollar range of fees in its Form ADV. Ultimately, Pathstone’s PathForward is designed to assist and inform prospects about our firm, Pathstone Services, and pricing before client engagement. Pathstone may refine PathForward to suit the needs of a particular prospect before client onboarding. Affiliated Funds Pathstone is compensated for certain portfolio management, investment management, investment advisement, administrative management, or other similar types of investment, administrative or operational services that it provides as sponsor, manager or sub-adviser to the Affiliated Funds program. The nature, rate, method of calculation and manner of

payment of the fees charged for these services is disclosed in the offering or governing documents of each Affiliated Fund in which a client or other limited partner invests. Both clients and non-client limited partners in Affiliated Funds also generally bear their proportionate share of the Affiliated Funds’ organizational and operating expenses, which are set forth in the offering or governing documents of the applicable Affiliated Fund. Fees and expenses associated with an Affiliated Fund are typically deducted from the Affiliated Fund’s assets. The general partner of an Affiliated Fund may, in its sole discretion, agree to accept an alternative fee arrangement with respect to any fund investor or limited partner, to the extent permitted under the applicable governing documents. It is important to note that due to the unique nature, large number, and different types of terms and conditions set forth in each Affiliated Fund’s offering and governing documents, all information related to Pathstone’s Affiliated Funds program provided herein is qualified in its entirety by reference to each Affiliated Fund’s respective offering and governing documents and a prospect cannot exclusively rely on a summary or partial description of any fund related information contained herein, especially regarding each Affiliated Fund’s particular Asset or Incentive-Based Fees (defined below). From time to time, Pathstone negotiates fee discounts or other investor rights for its clients with underlying managers, which may be based on aggregate investments by firm clients and Affiliated Funds. Clients Who Invest in Affiliated Funds Pathstone will at times advise a client to invest in one or more Affiliated Funds. As a result, depending on the terms of the applicable offering or governing documents for each Affiliated Fund, a client may be subject to additional fees (e.g., a management fee, comprehensive fee, performance fee, revenue sharing arrangement, or some other similar type of asset or incentive-based fees) (collectively, referred herein as “Asset or IncentiveBased Fees”) that are charged at the Affiliate Fund level. These fees are separate and distinguishable from the investment advisory or other Professional Services fees that are charged on the Pathstone services selected by the client. In general, for investment advisory clients who invest in Affiliated Funds that charge Asset or Incentive-Based Fees, the client may be afforded a fee discount or fee break mechanism depending upon the terms and conditions of the offering and governing documents of such Affiliated Fund. As a result, the applicable Asset or Incentive-Based Fees may be waived, rebated or reduced in some instances. In certain instances, the fee discount or fee break consideration may be achieved by offering a “no-management fee” share class or category type within the fund, or in other circumstances, it may be identified as a “fee offset,” “fee rebate,” “fee credit,” “fee adjustment” or other similar type of fee consideration (collectively, “Fee Breaks”) as reflected in the workpapers, books or records of the Affiliated Fund. Alternatively, Fee Breaks may be identified outside the Affiliated Fund and reflected in

invoices, fee schedules or other client documents or agreements as part of the client’s broader Pathstone billing arrangements. As a result, Fee Arrangements with clients include different Fee Breaks, and in some cases do not involve Fee Breaks. So, for example, certain existing, long-term or other advisory relationships in legacy organizations may be subject to different legacy fee schedules and may not receive Fee Breaks pursuant to the relevant terms of each client’s agreement. In general, Fee Breaks are offered to clients who retain Pathstone to provide investment advisory services and apply during the term of the advisory relationship with the firm. If the client terminates its advisory relationship with the firm, it often cannot concurrently redeem or withdraw from the Affiliated Fund (e.g., in the case of an illiquid private fund), in which case the former client may be transferred into a fee-paying category, as applicable, and will pay only the Affiliated Fund fees and expenses (if any) or alternatively be invoiced outside the fund. Such billing arrangements outside the fund are typically handled at the time of client offboarding. Other Third-Party Expenses In addition to clients paying Pathstone’s Fee Arrangements and being subject to any applicable Asset or Incentive-Based Fees related to investments made through the Affiliated Funds program, clients are responsible for all unaffiliated, third-party expenses incurred directly or indirectly in connection with transactions effected on behalf of clients pursuant to their agreements. These expenses shall include, but are not limited to brokerage costs, transaction costs, custodian fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, investment expenses such as commissions, interest on margin accounts and other indebtedness, borrowing charges on securities sold short and other expenses reasonably related to the purchase, sale or transmittal of assets in clients’ securities portfolios or accounts (collectively, “Third-Party Expenses”). Other Third-Party Underlying Managers’ Fees In addition, to the extent that clients’ securities portfolios include products offered by unaffiliated, third-party sponsors or managers of public or private funds, separately managed accounts, exchange-traded funds, mutual funds or other similar types of investment or financial products or services offered by others, clients may be subject to, directly or indirectly, different types of third-party sponsor or manager fees such as management fees, portfolio fees, performance fees, incentive allocations, transaction fees, monitoring fees, accelerated monitoring fees, board/director’s fees, finder’s fees, solicitors fees, consulting fees, administrative fees, fees in connection with mergers & acquisitions activity (e.g., add-on acquisitions, refinancing, sales, and similar transactions) or other

similar types of fees and expenses depending upon the manager and fund investment chosen. This is not a complete or exhaustive list of underlying manager fee arrangements. As clients and Affiliated Funds invest with underlying managers, clients and investors in the Affiliated Funds will generally be subject to underlying manager fees pursuant to the terms of the offering and governing documents of each underlying fund. Generally, underlying managers charge a management fee that may be based on a client or Affiliated Fund’s net asset value, capital commitment, capital contribution, or some other measure of assets in the funds or separate accounts as applicable, as well as an incentive allocation or performance fee in many instances. From time to time, Pathstone negotiates fee discounts or other investor rights for its clients with underlying managers, which may be based on aggregate investments by firm clients and Affiliated Funds. Please see Item 12 below for Pathstone’s brokerage practices. An underlying manager may offer the same or similar investment strategies through different investment vehicles or share classes (such as an underlying fund and SMA managed by the same underlying manager). In such instances, the firm seeks to recommend the particular investment vehicle or private fund share class to each client believed by the firm to be appropriate and in the best interest of such client, which may not be the lowest fee-paying share class or investment vehicle offered by the underlying manager due to constraints around minimum investment size, account type, registration, liquidity provisions, or other factors that may influence appropriateness and access to investments. Fee Negotiations, Legacy Relationships, and Other Custom Arrangements Pathstone may enter different billing arrangements with clients at its discretion. In addition to the Fee Arrangements described above, Pathstone may assist clients in establishing custom mandates, such as the setup and investment of private placement life insurance policies, resulting in custom fees for such services, which may be in addition to the investment advisory fees charged to clients under the primary engagement. Additionally, Pathstone may manage portfolio accounts for which, in its discretion, it reduces or waives investment advisory fees. In addition, certain clients may be charged based on older existing fee schedules established prior to becoming Pathstone clients because of the integration of legacy organizations. As a result, depending upon the office location, certain legacy clients may be subject to unique fee arrangements. For example, certain clients may have elected to be subject to a performance-based fee arrangement. To the extent applicable, Pathstone complies with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which requires that a client who pays a performance fee be a “qualified client.”

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Pathstone recommends investments to build diversified portfolios customized to each client’s unique goals, circumstances, and risk tolerance. We work closely with clients to establish an understanding of these factors before bringing investment recommendations. Investment recommendations incorporate these considerations as well as Pathstone’s own philosophy and investment processes.

“Accredited investor” and “qualified purchaser” are defined in Rule 501 of Regulation D and Section 2(a)(51) of the Investment Company Act of 1940, respectively.

Pathstone primarily recommends investments with underlying managers (e.g., managers of various types of onshore and offshore private fund structures, Affiliated Funds, separate accounts, mutual funds, closed-end registered investment companies, or exchange-traded funds) across asset classes and geographies to build client portfolios. Investment Philosophy While each Pathstone client differs in their specific investment objectives, asset allocation, and portfolio construction, we generally adhere to the following core investment principles in our portfolios:    

 

Maintain a long-term investment horizon Be unconstrained but highly selective in where to invest Target underlying managers/direct investments who are flexible and opportunistic with potentially durable returns Incorporate diversification across drivers of value within fixed income, public equities, alternative assets (i.e., hedge funds and hybrid credit funds), private equity and venture capital funds, and/or real estate Concentrate portfolios in high conviction investments Focus on risk-adjusted returns. For most portfolios, we generally define risk as the possibility of permanent capital impairment, not volatility. Additionally, we seek to be sensitive to the volatility of portfolios in relation to distributions (to avoid unplanned realization of losses)

Investment Strategies, Process and Methods of Analysis. Pathstone specializes in developing asset allocation strategies, sourcing and selecting underlying managers, and in allocating capital across investment strategies and asset classes. Based on each client’s investment objectives, preferences, and liquidity requirements, our customized asset allocation approach generally begins with a strategic allocation to a diversified portfolio of different asset classes. The construction of the strategic allocation incorporates an analysis of historical risk, return, and correlation of various asset classes and, at times, tactical considerations, among other factors. Asset classes used by Pathstone include but are not limited to cash and fixed income; public equities (long and long/short); alternative assets; private equity and venture capital; and real estate. Pathstone employs investment research teams, led by the firm’s Co-Chief Investment Officers, dedicated to monitoring the capital markets and identifying potential investment opportunities and risks within such asset classes

(collectively, the “Research Team”). The Research Team is the primary pathway by which the firm recommends the underlying managers ultimately introduced to advisory clients and Affiliated Funds. Client Advisors have direct responsibility for overseeing client relationships and making portfolio recommendations to individual clients. Depending on a client’s financial needs, Pathstone may implement strategies that incorporate buying or selling securities directly rather than, or in addition to, allocating capital to underlying managers. These direct securities transactions may include the purchase of cash or cash equivalent instruments, equity and debt securities, as well as other types of publicly traded securities. They may also include strategies involving long-term purchases (held at least a year), short-term purchases (sold within a year), trading (sold within 30 days), short sales, margin transactions, option writing, including covered options, uncovered options or spreading strategies, structured products, and other securities or derivatives transactions. As noted above, certain client mandates may be invested through an investment program implemented by Concentric. The objective of such a strategy is generally to provide, within a single coordinated portfolio, the pre-tax return of a combination of asset managers or styles while seeking to limit total portfolio risk, costs and taxes. Pathstone selects the investment allocation and applicable benchmarks and/or funds, and Concentric executes the trades that best serve the overall portfolio’s needs. Such portfolios generally invest exclusively in equity securities, including mutual funds and ETFs. However, to the extent the customized strategy permits, it may also invest in nonequity securities. For certain client engagements the firm utilizes portfolio models of a third-party provider as appropriate for such clients’ asset base, investment objectives, and liquidity needs, among other factors. Exposure across asset classes (including private investments) within such portfolios will vary depending on the unique needs, preferences, and circumstances of the client. Clients may also direct Pathstone to make and/or report on certain investments that the firm has not or does not recommend. Although the firm may consider those investments in providing investment services to the client, it is not obligated to provide investment advice, including due diligence, on such non-recommended investments. Please see Item 4 explanation of “Assets Under Administration (Reporting-Only Assets)” and the descriptions of various asset categories for more details. Due Diligence & Monitoring Processes Pathstone conducts due diligence and monitoring in connection with its investment recommendations and advisory services. The firm’s approach recognizes that investments may require various levels and types of diligence depending on the

circumstances, as described below. Please note that the descriptions are designed only as broad explanations of the different depths of due diligence performed by either the Research Team, Operational Due Diligence Team (“ODD”) or Client Advisors and that such activities are naturally constrained by the availability, time, and allocation of resources each group can dedicate to due diligence and monitoring activities as described in the different categories. Depending upon the facts and circumstances of each instance, some activities may fall between or below the category shown. Category I: Enhanced Due Diligence. Investments that are underwritten by the Research Team through the firm’s formal processes, which includes review by the Investment Committee, are subjected to enhanced due diligence prior to recommendation for use in client portfolios and Affiliated Funds. In such situations, the Research Team is generally responsible for the initial due diligence on the underlying investments or managers used, or considered for use, in client portfolios and Affiliated Funds. The Research Team works with the ODD professionals who assist with conducting due diligence and monitoring activities in respect of underlying managers. Potential investments are vetted through a series of internal processes, including an Investment Committee, before being recommended for use in advisory client portfolios and Affiliated Funds. Through such reviews and processes, the corresponding firmrecommended investment opportunity will be vetted, discussed, and debated before the recommendation is finalized. The firm typically prepares an investment memorandum (or similar type of workpaper including e-mail documentation) for investments recommended in this manner, which are provided to applicable Client Advisors and clients. Following this initial recommendation and diligence process, Pathstone professionals, such as the ODD Team and/or Research Team, actively monitor the applicable underlying managers on an ongoing basis. Category II: Basic Due Diligence. Certain investments that are otherwise deemed appropriate for client portfolios, such as direct, follow-on, secondary and coinvestments (e.g., those sourced through previously recommended underlying managers) or certain widely held index funds, may be exempted from the fulsome enhanced due diligence and approval process described above. In such situations, the Research or ODD Teams will review and consider the applicable investment opportunity and may reasonably determine that it does not require additional reviews or approvals based on a variety of factors (e.g., that the applicable manager has previously been subjected to enhanced due diligence). Such review may also include an analysis of the applicable investment opportunity’s offering and governing documents and potential return underwriting. In these situations, the Research Team may provide Client Advisors or clients with their observations or recommendations regarding the investment opportunity, which may be in the form of a short memorandum (or similar type of workpaper).

Category III: Due Diligence Upon Client Request. From time to time, advisory clients may request that Pathstone provide a “second opinion,” “a quick review,” “a quick look” or other assistance relating to (i) investments sourced by a client or group of clients or (ii) a client’s expressed desire to obtain greater exposure to a specific type of opportunity. These unsolicited requests may require the Research Team or applicable Client Advisors to review underlying manager materials and conduct limited diligence to provide an informed opinion on the opportunity. Due to the limited nature of such reviews, there should be no expectation that the Research or ODD Teams will perform or conduct the enhanced due diligence activities described in Category I or II above. Any corresponding assessment or opinion provided by the firm should not typically be deemed to be a recommendation, endorsement, or approval of such client-directed strategy, investment, or manager. The firm may produce a brief assessment or memorandum (or similar workpaper) for the client describing the opportunity at such client’s request. To the extent a client decides to invest in any such opportunity, the firm may (but is not required to) conduct limited monitoring of the applicable manager as an accommodation, such as reviewing the applicable investor notices and letters, audited financial statements, investor capital statements, and participate in annual general meetings, manager calls or conferences, or other opportunities to speak directly with the underlying manager. Category IV: Client Advisor-Specific Diligence. In rare instances, a Client Advisor may independently recommend to one or more advisory clients under their supervision certain investments that have not been reviewed or approved by the Research Team or Investment Committee. This may occur where client portfolios are invested in certain index-tracking mutual funds or ETFs, or when a Client Advisor or advisory client has a pre-existing relationship with a private fund manager (“Legacy Manager Relationships”). For example, advisory clients that invest in Legacy Manager Relationships may do so based on their own independent experiences and evaluation or the Client Advisor’s experiences with and evaluations of legacy organizations. The Research or ODD Teams generally do not provide any comprehensive due diligence efforts related to such manager selection or the continuous and regular review of Legacy Manager Relationships’ activities. Please see “Underlying Funds and Manager Risk” in the following section for additional descriptions of limitations and risks related to the selection and due diligence of underlying managers and investments. It is important to note that an investment memo or similar workpaper will not be generated for every recommended manager or investment approved by the firm. Lastly, such work product will not be shared with clients or others if Pathstone determines in its sole discretion that such material contains material non-public information (“MNPI”), is subject to confidentiality or other obligations or may pose some other risk related to its disclosure.

B. MATERIAL RISKS OF INVESTMENT STRATEGIES AND METHODS OF ANALYSIS

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Pathstone Advisory Clients (“Advisory Clients” or “Clients”) As described in Item 4 of this Brochure, Pathstone provides a broad range of discretionary and non-discretionary investment advisory and other professional services to its clients pursuant to various written agreements. Pathstone primarily serves UHNW families, including individual family members and their family-related entities, such as trusts,

estates, private charitable organizations, and single-family offices. Pathstone also advises corporations and business entities, pooled investment vehicles, pension and profit-sharing plans, public non-profits, endowments, foundations, and other clients. Subject to the types of services selected, client portfolios generally begin with assets under management of $10 million or more for investment advisory related services. Clients in the Affiliated Funds meet the requirements of the Affiliated Fund and U.S. persons typically must qualify as “accredited investors,” “qualified clients” and “qualified purchasers. 2” Other suitability/eligibility criteria may apply. Pathstone is not precluded from advising other types of clients that are not listed above. Observations Regarding Treating Affiliated Funds as Advisory Clients Pathstone also provides advisory services to its Affiliated Funds pursuant to separate agreements and as a result, each Affiliated Fund is treated as an advisory client. Pathstone assists and advises with managing certain investment and business operations of the Affiliated Funds, in each case to the extent provided in the applicable governing agreement. Observations Regarding Certain Limited Partners of Pathstone Affiliated Funds Certain limited partners invested in the Affiliated Funds who have no other relationship with Pathstone (i.e., they are not receiving investment advisory services pursuant to a separate agreement), may be referred to as “Limited Partners,” “LPs,” “LP Only Investors,” “Non-client Limited Partner,” “Partnership Investors,” etc. depending on the reporting practices of each legacy organization. This is not a complete or exhaustive list, but rather a small sampling of the various descriptions that may be used to describe limited partners throughout firm materials. As a result, such limited partners are not counted as advisory clients for Item 5D of Part 1A.

Pathstone may enter performance-based fee arrangements with “qualified clients” based on a share of capital gains or capital appreciation of the client’s assets. Performance fee arrangements are negotiated with clients on a case-by-case basis. Certain Affiliated Funds managed by Pathstone also charge performance-based fee arrangements.

A. POTENTIAL CONFLICTS

Pathstone advises or manages client portfolios or Affiliated Funds that pay an assetbased fee side-by-side with other clients and Affiliated Funds that pay performancebased fees. Performance-based fees provide Pathstone the opportunity to receive more, or less, compensation compared to advisory fees based solely on assets under management. Performance-based fees can serve to align the interests of Pathstone with those of our clients but may also create conflicts of interest for Pathstone. For example, performance-based fees may create an incentive for an adviser to recommend risky or speculative investments to generate higher positive returns. Performance-based fees may also create an incentive to favor those accounts over other asset-based fee accounts in the allocation of investment opportunities. Pathstone seeks to mitigate these potential conflicts and others as generally described below. B. MITIGATION OF POTENTIAL OR ACTUAL CONFLICTS

Fair Allocation of Investment Opportunities. Please see the description of our Allocation Policy in Item 11.C. Review of Client Accounts. Please see Item 13. Fairness to Clients. The firm seeks to resolve known, potential or actual conflicts in a manner that is generally fair to all its clients. Best Interests of Clients. The firm recommends an investment to a client only if it is appropriate for the client and is in the client’s best interest. An investment may not be appropriate for all client accounts, and recommendations are made independent of the consideration of fees payable by an account. Investment Due Diligence, Decision-Making, and Monitoring. Please see Item 8 under “Methods of Analysis, Investment Strategies and Risk of Loss” for more details. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Please see Item 11.

Pathstone Key Affiliate

Description

Affiliate Services for the benefit of Advisory Clients

WILLOW STREET TRUST COMPANY OF WYOMING, LLC, WILLOW STREET GROUP, LLC, AND WILLOW STREET TRUST COMPANY

Willow Street Trust Company of Wyoming, LLC ("WSTC, LLC"), Willow Street Group, LLC ("WSG, LLC"), and Willow Street Trust Company ("WSTC") (collectively, "Willow Street") provide professional solutions for Corporate Trustee Services, Private Trust the administration, management, and stewardship of assets. Pathstone is affiliated Company (PTC) Services, Other Trust & Fiduciary Services by common control and ownership with Willow Street. Please note that WSTC, LLC is a Wyoming trust company, WSTC is a Nevada trust company, and WSG, LLC is a fiduciary services firm and not a trust company.

CONCENTRIC

Advisor Partners II, LLC (“Concentric”) is a registered investment adviser providing discretionary, sub-advisory, and model portfolio management services primarily to clients of registered investment advisers and other financial institutions. Pathstone is under common control and ownership with Concentric.

Concentric builds customized portfolios for clients through SMAs and UMAs. Concentric’s services may include any combination of the following: tax loss harvesting overlays; Environmental, Social, and Governance (ESG) overlays; factor tilts; implementation of client-driven asset allocations and custom index exposures; and additional portfolio constraints.

CAMBRIAN CAPITAL MANAGEMENT, LLC

Cambrian Capital Management, LLC ("Cambrian") is a registered investment adviser and private market investment platform. Pathstone is under common control and ownership with Cambrian.

Pathstone Private Equity Anchor Program

AFFILIATED FUNDS, GENERAL PARTNERS, INVESTMENT MANAGERS, AND OTHER FUND-RELATED AFFILIATED ENTITIES

Certain private funds sponsored by Pathstone or its affiliates are considered Pathstone affiliates. Additionally, related affiliated entities that serve either as the general partner, portfolio manager, investment manager, investment adviser, sub-adviser, administrative manager, or serve in other similar types of investment, administrative or operational service roles on behalf of Pathstone's Affiliated Funds program are treated as Pathstone affiliates.

Pathstone will at times advise a client to invest in one or more Affiliated Funds. Please see Item 10 for additional details as well as Form ADV Part 1A under Item 7.A. Financial Industry Affiliations and Item 7.B. Private Fund Reporting for a complete list of Pathstone's Affiliated Funds and affiliated entities related to such funds.

A. PROFESSIONAL SERVICES

Pathstone offers its clients a variety of Professional Services to assist them in addressing many of the complex opportunities and challenges that can arise in the stewardship of their wealth. These Professional Services are generally targeted towards the firm’s UHNW families and their family-related entities. However, they are also available and adapted as needed for other clients, such as investment limited partnerships, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and other business entities. Engagements are tailored to each client’s preferences or needs and based upon the services selected. Please see Item 4 for a general description of available Professional Services and Item 5 regarding Fee Arrangements. Available Professional Services and Fee Arrangements are subject to change. Pathstone Professional Services, LLC is an affiliated entity that was formed in April 2025. Although the entity is formed, it currently does not provide services to clients. Pathstone may utilize this entity in the future to support the delivery of certain non-investment professional services. B. AFFILIATED FUNDS, GENERAL PARTNERS, INVESTMENT MANAGERS AND OTHER FUNDRELATED AFFILIATED ENTITIES

Certain private funds sponsored by Pathstone or its affiliates are considered Pathstone affiliates. Additionally, related affiliated entities that serve either as the general partner, portfolio manager, investment manager, investment adviser, sub-adviser, administrative manager, or serve in other similar types of investment, administrative or operational service roles on behalf of Pathstone’s Affiliated Funds program are treated as Pathstone affiliates. Please see Item 10 for additional details as well as Form ADV Part 1A under Item 7.A. Financial Industry Affiliations and Item 7.B. Private Fund Reporting for a complete list of Pathstone’s Affiliated Funds and affiliated entities related to such funds. Pathstone will at times advise a client to invest in one or more Affiliated Funds. Making investments through sponsored private funds as opposed to making direct investments in an underlying fund may result in some advantageous benefits for clients such as investment diversification that may reduce risk, providing economies of scale to access underlying managers and negotiating more favorable terms (e.g., obtain fee breaks, meet higher fund minimum requirements, etc.) to name a few. However, this may also result in less favorable outcomes for clients such as additional fees and expenses related to the costs of operating an Affiliated Fund, unexpected tax implications and other restrictions on an investor’s ability to withdrawal from the fund or access liquidity and other unfavorable outcomes. Because the Affiliated Funds have limited or no liquidity, clients who terminate their relationship with Pathstone often cannot concurrently redeem or withdraw from Affiliated Funds. This creates a potential conflict of interest for Pathstone between its responsibility to advise on securities portfolios for the benefit of

clients and its interest in fees payable on the continued investments in Affiliated Funds by clients that terminate their advisory relationship with Pathstone. For these and other reasons, there are several inherent conflicts for advisers when recommending clients invest in their sponsored pools. Pathstone only recommends its Affiliated Funds where it believes the recommendation is appropriate for the client and is in the client’s best interest. Please see Item 5 for a description of Fee Arrangements and other information about Pathstone’s Affiliated Funds program. It is also important to carefully read the offering and governing documents of each Affiliated Fund that set forth the terms and conditions related to making a private fund investment. The risks & conflict of interests addressed herein are not exhaustive nor a complete description of the potential or actual risks or conflict of interests related to making an investment in an Affiliated Fund. A prospect or client must carefully review the offering and governing documents as well as other fundrelated materials with their professional advisors before making an investment. C. ANCHOR/SEED INVESTOR FUNDS AND RELATED REVENUE SHARE

An anchor or seed investor is typically the first or earlier investor to commit significant capital to a new manager or underlying fund. To the extent an Affiliated Fund determines to make a large capital commitment or investment to an emerging manager, the general partner may negotiate a revenue share arrangement for the benefit of its fund’s investors. Pathstone and its personnel have financial interests in some of the Affiliated Funds. For example, Pathstone, its affiliates, and certain principals, employees and members of the investment team of the firm (the “Pathstone Interested Parties”) engage in a broad array of activities, including financial advisory services, sponsoring, managing and advising other private investment funds and accounts (“Other Vehicles”) and other activities beyond providing services to the Affiliated Funds. In connection with such other activities, Pathstone may recommend to clients an Affiliated Fund that may invest in Other Vehicles managed by a third-party manager which has a revenue sharing arrangement with one or more Other Vehicles advised by the Pathstone Interested Parties. Under this revenue sharing arrangement, such Other Vehicles and the Pathstone Interested Parties will be entitled to receive a share of revenue (including both asset-based and incentive-based compensation) earned by the third-party manager of such underlying fund (the “Revenue Share” and such investment in the underlying fund, the “Transaction”). As a result of the Transaction, a portion of the management fees and carried interest charged to the Affiliated Fund by the underlying fund’s manager will accrue to the benefit of certain Pathstone Interested Parties participating in the Revenue Share. Furthermore, the Pathstone Interested Parties may be incentivized to increase the Affiliated Fund’s investment in the underlying fund considering the Revenue Share (as opposed to investing the Affiliated

Fund’s assets in third-party investment funds from which the Pathstone Interested Parties do not receive a Revenue Share). D. EMPLOYEE AND OTHERS’ PARTICIPATION IN PATHSTONE AFFILIATED FUNDS PROGRAM

Eligible Pathstone employees may be offered opportunities to invest alongside clients as part of Pathstone Affiliated Funds program subject to the Research and Legal & Compliance Teams’ approval as well as the terms of the offering and governing documents of each Affiliated Fund. This includes, but is not limited to, participating in other managers sponsored private funds, related vehicles, or other investment pools, direct investments, or similar types of investment opportunities. Additionally, in conducting the investment program of the Affiliated Funds, the applicable general partner thereof may, from time to time, be presented with opportunities to co-invest in an investment in an underlying fund or other vehicle. The general partner may allocate such co-investment opportunities among Affiliated Fund(s), Affiliated Fund limited partners and/or any third parties (including Pathstone clients, personnel, the investment manager, the general partner, or any of their respective affiliates) as the general partner may, in its sole discretion, determine. As the general partner may allow certain Pathstone employees and/or employees of affiliates to invest in co-investment opportunities and allow such allocations to employees, this activity may trigger related party transaction(s) considerations. E. AFFILIATED TRUST & FIDUCIARY SERVICES COMPANIES: WILLOW STREET

Pathstone is affiliated by common control and ownership to Willow Street (as defined in Item 4), which includes Wyoming- and Nevada-based trust and fiduciary services firms that provide long-term corporate trustee and fiduciary services to families, individuals, and private foundations, including assistance in the administration, management, and stewardship of assets. Pathstone may introduce clients to Willow Street, which may provide trustee or fiduciary services pursuant to a separate agreement for an additional fee. Additionally, Pathstone may provide clients of Willow Street with investment advisory services for which Pathstone will be separately compensated. As a result, a conflict of interest exists whenever Pathstone introduces clients to Willow Street, and conversely, when a client Willow Street uses Pathstone for investment advisory services. Separately, in certain cases, senior personnel of Pathstone may serve in an individual capacity as a trustee, general partner, or manager for entities affiliated with Pathstone clients and/or for non-Pathstone client entities. F. ADVISOR PARTNERS II, LLC D/B/A CONCENTRIC OR CONCENTRIC INNOVATION

Concentric (as defined in Item 4), a Pathstone affiliate, offers its services to Pathstone clients. Pathstone is under common control and ownership with Concentric, a registered investment adviser providing discretionary sub-advisory services through

two distinct investment programs: Separately Managed Accounts (“SMA”) and Unified Managed Accounts (“UMA”). Concentric primarily provides sub-advisory services for the benefit of other registered investment advisers (“RIAs”) and their underlying clients (collectively referred to as “Other RIA Underlying Client Accounts”). Concentric builds customized portfolios for clients through SMAs and UMAs. Concentric’s services may include any combination of the following: tax loss harvesting overlays; Environmental, Social, and Governance (ESG) overlays; factor tilts; implementation of client-driven asset allocations and custom index exposures; and additional portfolio constraints. For the equity strategy, Concentric invests in exchange-traded equity securities, exchange-traded funds (“ETFs”), mutual funds, and American Depository Receipts (“ADRs”). Concentric may also invest in other types of securities including, but not limited to, fixed income (e.g., Treasuries, Agencies, Municipals, Corporates etc.) and fixed income ETFs, foreign securities, multicurrency/foreign exchange, ordinaries and real estate investment trusts (“REITs”). Depending on the type of product selected, Concentric generally tailors its advisory services to the individual needs of the RIA. There are different types of products and investment structures Concentric can implement for the RIA which can be offered to their Other RIA Underlying Client Accounts. For example, SMAs are generally highly customized based upon individual investment goals and objectives which are mutually agreed upon by Concentric, the RIA, and the Other RIA Underlying Client Accounts. The underlying RIA client can impose reasonable restrictions on investing in certain securities or types of securities. Concentric typically charges a fee for its services in addition to the investment advisory fees payable to Pathstone. This creates a potential conflict of interest for Pathstone between its responsibility to advise on clients’ securities portfolios and its indirect interest in fees payable to Concentric. G. SALTBOX II, LLC

Read the rest in the brochure

Pursuant to SEC Rule 204A-1, Pathstone has adopted a Code of Ethics for all supervised persons of the firm describing its standard of business conduct and fiduciary duty to its clients under the Advisers Act. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, the maintenance of a Restricted List in specific securities, requirements with respect to personal trading intended to avoid actual or mitigate potential conflicts with any client’s interests, limitations with respect to gifts and business entertainment, among other requirements. Employees at Pathstone must comply with and acknowledge the terms of the Code of Ethics annually, or as materially amended. The Code of Ethics also includes requirements related to confidential treatment of certain information. The Code of Ethics is an exhibit to the firm’s Compliance Manual. Pathstone reviews the Code of Ethics and other compliance policies and procedures in its onboarding of new employees and provides annual training on compliance topics to employees. Annually, personnel are required to certify in writing that they have received a copy of and complied with the provisions of the Compliance Manual, including the

Code of Ethics and any amendments, and submit other compliance-related certifications. The Pathstone Compliance Group (“PCG”) actively monitors compliance with the Compliance Manual and the Code of Ethics and recommends sanctions deemed appropriate for violations. Additionally, through separate service agreements, PCG also provides compliance personnel and other resources on behalf of and for the benefit of certain affiliates such as Concentric and Cambrian. Clients or prospective clients may request a copy of the Code of Ethics by contacting PCG via email at compliance@pathstone.com. B. POTENTIAL OR ACTUAL CONFLICTS

The firm may give advice and act with respect to any of its clients that differs from advice given or the timing or nature of action recommended with respect to any other client. The firm is not obliged to acquire for any client account securities or investments that the firm or its personnel may acquire for its or their own accounts or for the account of any other client if, in the absolute discretion of the firm, it is not practical or desirable to acquire a position in such security for that account. Pathstone and its personnel may buy or sell securities (including private funds or private company interests or shares) for their own accounts based on personal investment considerations, subject always to their compliance with the personal trading requirements within the Code of Ethics. It is also likely that such investment opportunities may not be suitable or appropriate for Affiliated Funds or other clients. Pathstone and its personnel or affiliates are, from time to time, presented with opportunities to invest in securities of the same classes as are purchased for clients and may purchase, hold, and/or sell securities of issuers in which clients are invested. These securities include the Affiliated Funds, private funds managed by managers other than Pathstone, mutual funds, exchange-traded funds, direct investments in operating companies, and other opportunities. If Pathstone and its personnel invest personally in securities that Pathstone invests in or recommends for its clients, they may do so at different times and different values. Moreover, Pathstone and its personnel may determine to sell or redeem these securities at different times than Pathstone advises its clients to do so, which may result in Pathstone or its personnel obtaining better value. The firm has adopted policies and procedures within its Code of Ethics to address conflicts of interest associated with personal investment activities by Pathstone personnel. Pathstone personnel that invest (i) in pooled investment vehicles that invest in certain of the Affiliated Funds or (ii) directly in an Affiliated Fund generally are not charged a management fee by such entities. See also the description of employee participation in Affiliated Funds in Items 5 and 10.

In certain instances, a client of Pathstone buys or sells an investment directly from or to another client and Pathstone facilitates the transaction without exposing it to the market (“Cross Trades”). In general, Cross Trades can create conflicts of interest because, by not exposing such transactions to market forces, a client may not receive the best price otherwise possible and Pathstone could favor one client over another. However, Pathstone engages in Cross Trades only where it believes the trade is in the best interest of clients on both sides of the trade. Pathstone does not act as a brokerdealer or otherwise directly or indirectly receive any commission or other transactionbased compensation for facilitating any Cross Trade. The firm sometimes enters confidentiality or “standstill agreements” when assessing investment opportunities and/or monitoring investments, and firm personnel sometimes acquire confidential or MNPI affecting certain issuers. In addition, from time to time, senior Pathstone personnel serve on advisory boards of underlying funds in which clients or Affiliated Funds are or may invest, as well as on the board of directors of one or more companies that results in them having MNPI. It is the policy and practice of the firm to add issuers for which the firm or personnel has MNPI to its “Restricted List.” The Restricted List may constrain the firm and its personnel from implementing investment decisions with respect to issuers on the Restricted List. Please see Item 10 above for certain scenarios in which Pathstone allocates client capital to underlying funds and other investments managed by underlying managers in which it or a related person has a direct or indirect financial interest (for example, the scenarios described under the following Item 10 headings: “B. Affiliated Funds,” “C. Anchor/Seed Investor Funds and Related Revenue Share,” “F. Advisor Partners II, LLC,” “I. Pathstone Owners and Other Business Relationships,” “J. Prime Group,” and “K. Mitigation of Actual or Potential Conflicts”). There may be conflicts of interest or other constraints over the time devoted to any client relationship or account of the firm and its affiliates as well as the allocation of investment opportunities among such accounts. Pathstone has adopted policies and procedures to address such conflicts. C. MITIGATION OF POTENTIAL OR ACTUAL CONFLICTS

The firm mitigates potential or actual conflicts, including in the following ways. See also Item 10. Fairness to Clients. The firm seeks to resolve all potential or actual conflicts in a manner that is generally fair to all its clients. Best Interests of Clients. The firm recommends an investment to a client only if the firm believes the recommendation is appropriate for the client and is in the client’s best interest.

Fair Allocation of Investment Opportunities. The firm seeks to allocate investment opportunities fairly over time to its clients in a manner consistent with the firm’s fiduciary duties as an investment adviser, taking into consideration each client’s investment objectives, restrictions, or policies. Allocations of capacity constrained trades follow written procedures that are reasonably designed to allocate such opportunities fairly over time. The type or size of a client, and the type or amount of fee paid by a client, is not considered in determining the allocation of investment opportunities. Compensation Policies. Pathstone personnel are compensated on a set salary basis, and a bonus based on overall firm performance and individual contributions. Personnel do not receive commissions. Personnel compensation is not based on the value of client assets, fee structure or specific investment recommendations. Trading by Pathstone Personnel. Pathstone maintains personal trading policies and procedures intended to avoid or mitigate actual and potential conflicts of interest. Employee trading is reviewed under the Code of Ethics, which has been reasonably designed to prevent conflicts of interest between Pathstone and its clients. The firm’s monitoring and review of personal trading is, in certain instances, individually tailored to one or more legacy acquired organizations in consideration of historically distinct business practices, compliance monitoring systems, and other compliance considerations.

Registered Investment Advisers (“RIAs”) such as Pathstone typically do not execute trades themselves, but instead, they send or “route” their clients' trade orders to a broker-dealer for execution (“Trade Order Routing”). The broker receives the order from the RIA and then routes it to the appropriate exchange or market center for execution. Pathstone, as a fiduciary, has a duty to act in their clients’ best interests, which includes diligently researching and selecting brokers and venues that provide "best execution" for their clients' orders – that means having Trade Order Routing policies and procedures in place to ensure client orders are routed to venues that execute efficiently and competitive prices. Trade Order Routing activity is coordinated through trading and operational groups within certain Pathstone offices (e.g., primarily through Capital Markets Group and its Regional Trading Operational Teams (defined below)). Depending on the office, such Trade Order Routing activity typically includes, but is not limited to, the routing of purchase or sale of cash or cash equivalent instruments, equity and debt securities, exchange traded funds, mutual funds, options as well as other types of publicly traded securities. For example, the Capital Markets Group coordinates the Trade Order Routing activity of the regional offices through its operational group designees (collectively, referred to herein as the “Regional

Trading Operational Teams”) to the extent it effectuates trade routing on behalf of clients through broker dealers, banks or other mutual fund departments. Certain Trade Order Routing activity, such as ETFs or mutual fund purchases (or other investments), may be implemented directly by the Regional Trading Operational Teams (e.g., SF/NYC, Boulder/Denver, or Rhode Island). Ultimately those operational group designees or team members report through and directly to the Capital Markets Group any material trade errors, trade breaks, or other material trading issues, etc. requiring the attention of the Capital Markets Group. The Capital Markets Group coordinates and resolves these issues, or if necessary, elevates them to the Legal & Compliance Group and/or Pathstone’s Executive Leadership Team on a case-by-case basis until resolved. Capital Markets Group - Trade Order Routing Activity Depending on each client’s circumstances, the Capital Markets Group generally will recommend the brokerage and clearing services of Pershing Investment Manager Services (“Pershing”), Fidelity Brokerage Services, LLC (“Fidelity”) or the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”) for investment management accounts. Although Pathstone may recommend these or other brokerage or custodial arrangements to advisory clients, it is ultimately the client’s decision where to custody their assets and to determine the custodial services and fee arrangements selected. In certain situations, custodial services and fee arrangements at our preferred brokerage and custodial relationships are negotiated by Pathstone on behalf of our clients to gain better efficiency and economies of scale, asset size fee breaks or other discounts, or for other reasons. For non-Pathstone recommended brokerage or custodial relationships, those fees and services are separately negotiated and determined by the client. The brokerage commissions and/or transaction fees charged by brokers-dealers are separate and apart from Pathstone’s Fee Arrangements and any applicable Asset or Incentive-Based Fees related to investments made through the Affiliated Funds program. Capital Markets receives, tracks, and routes securities orders in a working queue. Trade orders are routed once received and reviewed for accuracy by Capital Markets team members. The Capital Markets Group primarily routes the purchase or sale of cash or cash equivalent instruments, equity and debt securities, exchange traded funds, mutual funds, options as well as other types of publicly traded securities directly with the trading desk of the client’s custodian relationship. The firm does not negotiate “execution only” commission rates. In selecting a broker, Capital Markets Group may consider, among other things, the broker’s commission rate, execution capabilities, actual experience, efficiency, promptness, financial stability, reputation, confidentiality, operational and administrative expertise and support, and research services provided by the broker.

A client may, in its sole discretion, elect a different broker-dealer to execute securities transactions. Clients may direct Pathstone to use a specific broker, and some clients have relationships with brokers that predate their relationship with Pathstone. In these directed brokerage situations, the firm has not negotiated the terms and conditions (including, but not limited to, commission rates) and does not have any responsibility for obtaining best execution. Clients who direct Pathstone to use a specific broker may pay higher commission rates or receive less favorable execution transactions than non-directing clients. For example, in directed brokerage accounts, clients may pay higher brokerage commissions than the firm has negotiated with Pershing, Fidelity and Schwab. Pathstone may direct a client account to pay a brokerage commission exceeding that which another broker might charge for effecting the same transaction, in recognition of the value of the execution capabilities. Pathstone does not receive research or other products or services from any broker-dealer or third party explicitly in connection with client securities transactions (“soft dollar benefits”). In selecting or recommending broker-dealers, Pathstone does not consider whether it or a related person receives client referrals from a broker-dealer or third party. Capital Markets Group receives research from brokers through which the firm and/or its clients affect transactions as well as possibly other brokers. Research services furnished by brokers may be used in servicing all Pathstone’s accounts. Not all these services may be used by Pathstone in connection with accounts that paid commissions to the brokers providing such services. Research received from brokers is generally developed by the brokerage firm, rather than by third parties. When Pathstone obtains research from brokers, it receives a benefit because it does not have to produce or pay for the research. The firm may have an incentive to select or recommend a broker based on the firm’s interest in receiving research or other products or services, rather than on a client’s interest in receiving most favorable execution. Philadelphia Metro Trading Group (PHL Metro Trading) – Trade Order Management Philadelphia Metro Trading Group is one of the Regional Trading Operational Teams that ultimately report up through and directly to the Capital Markets Group any material trade errors, trade breaks, or other material trading issues, etc. that will require Capital Markets Group’s attention. As a legacy organization it currently utilizes a different trade order management system (referred to internally as “Transaction Processing System” or TPS”) to handle the trade order management flow as well as trade execution platforms. Additionally, PHL Metro Trading has some unique trading activities and capabilities utilizing different people, processes and systems than those used in the Capital Markets Group or Regional Trading Operational Teams and therefore is described separately herein. PHL Metro Trading builds customized cash management, fixed income securities (e.g., customized bond portfolios), and index strategies for client securities portfolios.

A client may, in its sole discretion, elect a different broker-dealer to execute securities transactions. Clients may direct Pathstone to use a specific broker, and some clients have relationships with brokers that predate their relationship with Pathstone. In these directed brokerage situations, the firm has not negotiated the terms and conditions (including, but not limited to, commission rates) and does not have any responsibility for obtaining best execution. Clients who direct Pathstone to use a specific broker may pay higher commission rates or receive less favorable execution transactions than non-directing clients. For best execution, PHL Metro Trading uses the following factors, among others, to evaluate its brokerage arrangements and total execution quality of client trades: competitiveness of price spreads; minimal market impact; timeliness of execution and reporting; liquidity of the securities traded; frequency and correction of trading errors; business reputation of broker/dealer; back office and trade settlement capabilities; responsiveness to PHL Metro Trading’s orders; availability of accurate information and research; and overall responsiveness to the desk’s needs. If multiple clients execute trades in the same security on the same day, PHL Metro Trading may use average pricing in the execution price of trades that occur around the same time and with the same objective. Client accounts (as well as any employee’s trades) participating in an aggregated order will receive the average price for the security. In some instances, average pricing may result in higher or lower execution prices than otherwise obtainable by a single client account. Pathstone uses this procedure to avoid any preferential treatment among client accounts or to employees. Additionally, pursuant to the Shared Services Agreement with Concentric, certain human resources and trading support services related to fixed income securities and tax managed accounts of certain Pathstone advisory clients are managed by Pathstone employees allocated too Concentric. As a result, these individuals will be dual registered under Concentric and Pathstone and the regulatory assets under management (“RAUM”) associated with these individuals will be reflected in both firms’ Form ADVs. See Concentric’s Form ADV Part 2A Brochure for more details.

Pathstone may compensate unaffiliated promoters (i.e., an independent third party) to solicit clients on behalf of Pathstone. These third-party promoters have an economic incentive to recommend the advisory services of Pathstone. Each promoter referring advisory clients is typically paid a portion of the fees (e.g., investment management, consulting, or other similar types of fees charged) Pathstone receives from each client. These or other similar types of fees sharing arrangements are set forth in separate written agreement with each promoter. These arrangements do not result in a higher advisory fee than would customarily be charged to clients. Pathstone employees may also be eligible to receive additional compensation if they introduce new clients to the firm. Employees who receive such additional compensation must comply with the requirements of the Advisers Act and any corresponding state securities law requirements. The employee compensation arrangements for referrals do not impact on the amount that Pathstone charges a client.

From time to time, Pathstone may enter into arrangements with employers, professional firms or other organizations under which such third parties pay or subsidize a portion of the advisory fees on behalf of certain eligible individuals as a benefit. Pathstone does not compensate such third parties for referrals in connection with these arrangements. These arrangements may create a conflict of interest to the extent that the subsidized fees incentivize such individuals to engage Pathstone’s services. Clients remain responsible for all fees under their advisory agreement, subject to any such payments or credits applied. Pathstone has negotiated various strategic partnerships with non-financial business entities to provide additional family office lifestyle management services to its clients. On occasion, employees of Pathstone may participate in or utilize these services at the comparable fee level charged Pathstone’s clients. Please see Item 10 above for a description of Pathstone’s affiliates and certain revenuesharing arrangements. Potential Conflicts Regarding the Relationships of Pathstone and its Owners Pathstone’s owners, including their respective affiliates, operate independently of Pathstone, and engage in a broad array of activities, including financial advisory services, asset management, and lending activities, and have wide-ranging relationships, including relationships unknown to Pathstone. In some instances, Pathstone may be prohibited by law, regulation or contract, from receiving the full details of any commercial relationship. As a result, it may be difficult for Pathstone to anticipate or manage potential conflicts.

Pathstone and its management persons have no disciplinary history reportable under Item 9.

[Intentionally left blank – please see Pathstone’s Key Affiliates Below]

Pathstone generally reviews all client accounts approximately quarterly and provides clients with detailed quarterly reports about their accounts. It is important to note that the manner, scope, and frequency of account reviews depend upon the office and any legacy organization’s unique historic review processes and procedures that are still in effect and in use by that office.

A. ACCOUNT REVIEWS

Clients. For those clients to whom Pathstone provides investment advisory services, Pathstone generally conducts periodic account reviews on an “as needed” basis, which may be in conjunction with the preparation of client’s quarterly reports. This informal review may include assessing client goals and objectives, monitoring the portfolios and addressing the need to rebalance. Accounts are reviewed in the context of the client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client’s individual circumstances, market conditions, or the political or economic environment. We maintain policies and procedures that address client account reviews. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with Pathstone and to keep Pathstone informed of any changes thereto. Pathstone expects to contact investment advisory clients at least annually to review its previous services and/or recommendations and to discuss any changes in the client’s financial situation and/or investment objectives. Additional reviews that Pathstone may periodically perform on behalf of clients include tax-planning, cash-flow needs, as well as charitable giving, insurance, and estate planning. Financial plans we prepare are not necessarily reviewed periodically; however, we attempt to meet at least annually with those clients and offer the opportunity to review all the financial matters a client may wish to discuss or more frequently upon client request. Affiliated Funds. Personnel responsible for overseeing the Affiliated Funds meet quarterly or more frequently to review performance and address other subjects relating to the Affiliated Funds. B. CLIENT REPORTS

Unless otherwise agreed upon, clients receive account statements directly from the broker-dealer, custodian, or underlying manager for their accounts. Investment advisory clients of Pathstone also receive a customized report from Pathstone of account and/or market-related information such as an inventory of account holdings and account performance. The design, type, scope, and number of details provided in such reports are subject to the agreement of the parties at the time of the client onboarding including any subsequent adjustments made to such reports or timing periods anytime thereafter. Most of the trading activity related to advisory client accounts is in marketable securities with a readily available market price pulled from subscription-based, independent data pricing services. The next largest segment of a client portfolio is private investments such as hedge funds, private equity funds, real estate funds, etc. that are fair valued by third parties. Typically, there are two types, namely, unaffiliated

funds of underlying managers or Affiliated Funds. These investment managers provide investors capital statements, audited financial statements, investor letters, notices, and other types of valuation information and methodologies with a price for the fair valued investments that is entered into Pathstone’s client portfolio accounting systems. There are also certain fair valued investments that are specific or unique to certain advisory clients. For example, a privately held family business, interfamily loans, artwork, etc. Such investments are valued by the client’s team of advisors such as family office staff, controllers, accountants, or financial services personnel (collectively, “Client Service Providers”). Typically, Pathstone is provided with the most recent valuations for these private investments by the Client Service Providers. These fair valued investments may be tracked in a customized quarterly report as an appraisal or separate schedule at the client’s direction. Those clients to whom Pathstone provides financial planning and/or consulting services will receive reports as requested by the client or otherwise agreed to in writing by Pathstone. Affiliated Fund Investor Reports. Investors in the Affiliated Funds generally receive quarterly capital statements, and investors in certain Affiliated Funds also receive periodic performance statements and/or investor letters. Investors in Affiliated Funds will receive annual audited financial statements within 120 or 180 days of their fiscal year-end. It is important to note that client reporting processes and procedures may vary by office from the general description above depending upon any legacy organization’s unique historic reporting capabilities that are still in effect and in use by that office.

Pathstone Investment-Related Services. As part of Pathstone’s investment advisory services, Pathstone does not have physical custody of any client assets or securities and does not act as the custodian for client assets. Client assets are held at a third-party custodian generally of the client’s choosing. The custodian will maintain the underlying records for the assets in a client’s account, and each client will be solely responsible for paying all fees and charges of the custodian as stated in a separate agreement between the client and the custodian. Clients will receive quarterly or more frequent account statements directly from a qualified custodian of their choosing, such as a broker-dealer or bank. Clients should carefully review such account statements. In addition, Pathstone urges clients to compare the statements received from qualified custodians to the reports of accounts received from Pathstone. Nevertheless, due to certain activities, Pathstone is deemed, under the federal securities laws, to have custody of client assets. As a result, it engaged the services of an independent accounting firm to conduct a surprise examination of these accounts to ensure Pathstone’s compliance with the custody rules.

Additionally, as the result of Pathstone sponsoring Affiliated Funds, the applicable affiliated general partners of these private funds are deemed, under the federal securities laws, to have custody of client assets. The general partners do not have actual physical custody of any client’s assets or securities invested in by the funds. All such assets are held in the name of each fund by an independent, unaffiliated qualified custodian. The Affiliated Fund’s financial statements are prepared in accordance with U.S. generally accepted accounting principles (“GAAP”) and each Affiliated Fund is audited at least annually by an independent public accountant that is registered with, and subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules. The audited financial statements are made available to all investors in the Affiliated Funds within 180 days of their fiscal year end (or 120 days if applicable). Upon liquidation of an Affiliated Fund, Pathstone distributes the final audited financial statement to all investors in the Affiliated Fund promptly after the completion of such an audit. Pathstone urges its clients to carefully review the annual audited financial statements. Pathstone Professional Services. Separate and apart from its investment advisory related services, Pathstone offers a wide range of non-investment wealth management services and solutions, including, without limitation, expense and cash management, financial reporting, lifestyle management services, philanthropic management, and tax compliance/tax return preparation. In some instances where Willow Street is engaged to serve as a client trustee, Willow Street also acts as a qualified custodian and obtains an internal control report. Specific services arrangements are agreed to by the client depending on such client’s unique preferences. These services are performed by separate groups other than Client Advisors. Pathstone may coordinate with clients’ legal and tax advisors in connection with these services. Clients are encouraged to consult their independent legal and tax advisors with respect to their specific circumstances.

The firm provides investment services on either a non-discretionary or discretionary basis, as reflected in the firm’s agreement with a client. For both types of relationships, the firm coordinates the construction of investment portfolios, conducts initial and ongoing investment and operational due diligence, and generally receives statements and other communications directly from underlying managers. Unless otherwise instructed or directed by a discretionary client, Pathstone generally has the authority to: (i) determine the securities to be purchased and sold for the account (subject to any restrictions set forth in the advisory agreement and any written investment guidelines); (ii) determine the amount of securities to be purchased or sold for the account; and (iii) determine the broker used to effect the client’s securities transactions, if none has been directed by the client. The firm charges the same fees, as described in Item 5 above, for non-discretionary and discretionary client relationships. Fee arrangements are negotiable depending upon the

facts and circumstances of each engagement such as size, complexity and scope of the relationship contemplated. This may result in different clients paying less or different fee arrangements. The firm and/or its affiliates are general partners or underlying managers of the Affiliated Funds, and in those roles, exercise discretionary investment authority over the Affiliated Funds.

Generally, the types of investments recommended by Pathstone do not solicit proxy votes from shareholders, and Pathstone is typically not responsible for voting proxies on behalf of its clients. However, there are limited situations where the firm has the responsibility to vote proxies, such as for securities held by the Mutual Fund or Affiliated Funds in instances where proxy voting authority has not been delegated to a sub-adviser. In addition, Pathstone may be required to vote proxies for a retirement benefit arrangement subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) in any case in which such authority has been delegated to Pathstone in the client’s agreement. The firm has adopted proxy voting procedures and guidelines for those limited instances where the firm may have responsibility to vote proxies. Clients may obtain copies of these proxy voting policies and guidelines by contacting the Pathstone Compliance Group via email at compliance@pathstone.com. In addition, if Pathstone has proxy voting responsibility for a client, upon request, it will provide a record of how the client’s shares were voted. Pathstone annually reports how it voted on proposals relating to executive compensation (“say-on-pay”) matters on Form N-PX no later than August 31 of each year for the most recent 12-month period ended June 30, as required by Rule 14Ad-1. A copy of Form N-PX may be obtained, without charge, in the manner noted above or on the Securities and Exchange Commission’s website at http://www.sec.gov. Class Actions, Bankruptcies and Other Legal Proceedings Other than for our Affiliated Funds, Pathstone will neither advise nor act on behalf of a client in legal proceedings involving securities held in clients’ accounts. Clients are generally responsible for handling such claims involving securities held, or previously held, in the client’s accounts, including, but not limited to, the filing of “Proof of Claim” in class action settlements. Pathstone may, in its discretion, engage an independent third-party provider to assist in such matters or facilitate the direct engagement of such a third-party provider by its clients.

Pathstone does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.