Rothschild & Co Wealth Management UK Ltd

Principal Ownership Rothschild & Co Wealth Management UK Limited (“WM UK”) was formed in 2002 and is a provider of discretionary investment management, non-discretionary investment management and wealth management services to private clients and their connected structures, based in the United Kingdom. We are authorized and regulated by the UK Financial Conduct Authority and registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser under the U.S. Investment Advisers Act of 1940 (“Advisers Act”). We are directly owned by Rothschild & Co Wealth & Asset Management SAS and remain ultimately owned by Rothschild & Co SCA. The Rothschild & Co Group (“R&Co Group”) is a global financial advisory group which is family-controlled and independent. It has been at the center of the world’s financial markets for more than 200 years. This Brochure discusses the services that we offer to our U.S. resident clients (“U.S. Clients” or “U.S. Persons”). Advisory Services For clients that have agreed to the WM UK’s Terms and Conditions (US), we provide investment advisory services on a discretionary basis to individuals, their connected structures and private funds. Each client’s assets are managed in a separately held account. We do not accept orders from U.S. Persons to buy or sell securities. Customization We require each client to execute an investment management agreement (“IMA”) that details the nature of the discretionary investment advisory authority given to us, and that documents the client’s investment objectives, restrictions, guidelines, base currency, and risk profile (“Profile”). Customization is based upon the client’s individual preferences, personal circumstances and/or tax-management requirements as provided by the client and/or the client’s tax adviser, as applicable, and forms part of the Profile. Each Profile is managed according to the client’s specific restrictions, with reference to a centralized investment model portfolio, as discussed in Item 8. Investment Types For the equity allocation of client accounts, we invest in common stocks, collective investment schemes or exchange-traded funds (“ETFs”). Investments in the fixed income allocation of client accounts can include global, government, agency and corporate bonds, collective investment schemes or ETFs. We invest mainly in investment grade bonds and primarily in securities whose underlying issuer rating from at least one major rating agency is “BBB” or better. Currency exposures within client accounts are managed, when appropriate, by using FX forwards. We may also use put warrants. We do not do this in such a manner to be deemed a commodity trading adviser, and we are an exempt Commodity Trading Adviser under the U.S. Commodity Exchange Act. Assets under Management As at 31 December 2025, we had approximately US $28,474,632,132 of assets under management.

Our fees are charged as a percentage of assets under management. The standard management fee is 1% per annum (plus VAT, if applicable). We negotiate fees and may adjust this fee upwards or downwards at our discretion, depending on individual client situations. Foreign exchange transactions may be subject to currency commission. We may affect these transactions with Rothschild & Co Bank AG (“R&Co Bank AG”), a related person. Under MiFID II requirements, we may only use these arrangements where we consider that we would achieve at least as good results for our client as we would from another broker or venue, mitigating this potential conflict. The management fee is inclusive of investment services, investment reporting, and custody fees. Custody services are provided by an external third party. Our management fees are exclusive of brokerage commissions, transaction fees and other related market or third-party costs and expenses that are incurred by the client. Item 12 describes the factors that we consider in selecting brokers or counterparties for transactions and determining their commissions and fees. These fees are billed quarterly in arrears based on the previous three month-end account values in the agreed reference currency. Clients are not required to pay fees in advance. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee. All fees are agreed in advance with our clients and clearly stated in the IMA.

Investment strategies: Investment/portfolio strategies are agreed with each client from the range of portfolio strategies that we operate set forth below, taking into consideration each client’s investment objectives and Profile as well as other factors (i.e. investment purpose, investment time horizon, financial and personal circumstances, and / or tax-management requirements as provided by the client and / or the client’s tax adviser, as applicable). We offer the following strategies and risk profiles: low risk, cautious, balanced, equity risk, return-assets only and conviction equity. Clients select one of the following account currencies: GBP, EUR or USD. Each strategy and risk profile has a specified investment return objective (e.g., inflation + x%).

We implement each strategy and risk profile with reference to a centralized investment model portfolio (“Portfolio”). No guarantee, assurance or representation is made that any Profile will achieve its investment objective. Methods of analysis: Our investment philosophy is focused on the preservation of capital and the achievement of real returns over the economic cycle. We do not seek to follow or replicate any benchmark or index in managing portfolios. We do not have a fixed allocation, nor any mandatory or target allocation to any specific asset class. The appropriate combination of assets is determined by each Portfolio’s specific investment return objective and risk profile. We build Portfolios from the bottom-up, focusing on fundamental analysis. We believe there is value in using historic data to help guide future investment decisions. However, past performance is no guarantee of future results. Accordingly, our investment analysis process considers historic data in view of the current market environment, taking into consideration several factors, including where we are in the investment cycle and potential future investment themes. This allows us to adjust and focus the proposed asset allocation in areas that we expect to generate the strongest returns in the long term. Risk of loss All investments present a risk of loss of capital. Supply and demand for securities and other financial instruments change rapidly and are affected by a variety of factors. Such factors include investmentspecific price fluctuations as well as macro-economic, market and industry-specific conditions, including, but not limited to, national and international economic conditions, domestic and international financial policies and performance, conditions affecting particular investments (such as the results of operations, financial condition, sales and product lines of corporate issuers), national and international politics, governmental events and changes in interest rates and income tax laws. In addition, events such as political instability, terrorism, natural disasters, and regional and global health epidemics (including viral outbreaks such as COVID-19) may occur. WM UK may have only limited ability to vary its investment portfolio in response to changing economic, financial, investment and other conditions. No guarantee or representation can be made that our investment program will be successful. The market price of securities and other financial instruments owned by clients may go up or down, sometimes unpredictably, and investment results may vary substantially.

We offer asset management services primarily to high-net-worth individuals, trusts, companies, charities, and pensions. The minimum client relationship size is $10,000,000, although we may accept smaller investments at our discretion. In order to establish and maintain a relationship with us, each client must provide all necessary documents to demonstrate compliance with the relevant regulatory and tax authority requirements (including the UK, the U.S. and other jurisdictions, as applicable). A list of all required documentation will be provided as a basis of the establishment of the new client relationship.

We do not offer performance-based or side-by-side asset management fees. We do not charge performance-based fees.

We are ultimately owned by Rothschild & Co SCA. The R&Co Group is a global and family-controlled group with three main business units: Global Advisory, Wealth and Asset Management and Merchant Banking. R&Co Bank AG, an affiliate, calculates the valuations of clients’ portfolios for client reporting purposes. Our fees are calculated as a percentage of the value of clients’ portfolios. To mitigate any potential conflict, we require an independent review of the valuation methodology and results (a part of that company’s annual audit). We use information barriers designed to restrict the flow of information between internal departments and from other R&Co Group entities. The operation of the information barrier involves a range of practices including the segregation of data and computer systems, as well as physical separation of

certain businesses (and Supervised Persons) so that they are unable to access the same part of the office. Neither we, nor any representative of ours, are registered (active nor pending) as a futures commission merchant, commodity pool operator, or commodity trading advisor.

The R&Co Group has adopted a Code of Ethics (“Code”) that applies to our Supervised Persons. The Code describes the standard of business conduct and fiduciary duty we owe to our clients. The Code includes provisions relating to preventing the misuse of confidential client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, personal account dealing requirements for access persons, procedures to seek clearance to engage in outside business activities or financial interests and reporting Code violations. The pay-to-play rule regarding political contributions applies to us, but we do not offer our services to U.S. institutional, pension or governmental institutional clients. All Supervised Persons are provided a copy of the Code and must acknowledge the terms of the Code annually, or as amended. The Code requires Supervised Persons to comply with applicable federal securities laws. We provide training annually to all Supervised Persons reminding them of the Code’s requirements. Further, Supervised Persons are required to promptly bring violations of the Code to the attention of our Chief Compliance Officer.

Generally, and as described in Item 16, we are retained on a discretionary basis and are authorized to determine and direct execution of transactions within the client’s profile. As a fiduciary, we have a duty to act in the best interests of our clients. We do not act as principal (trade for our own account) or trade with clients. We do not solicit or take U.S. Client orders to buy or sell securities. We do not affect cross-trades for our U.S. Clients. Brokerage Relationships and Selection Criteria for Brokers and Counterparties WM UK has adopted policies and procedures regarding the best execution of trades for client accounts. We place client orders in listed and over-the-counter securities by routing such orders to the institutional desks of selected brokers and counterparties. We maintain a list of approved counterparties with whom orders are typically placed. We do not permit U.S. Clients to select brokers or counterparties for transaction execution. Broker and counterparty selection are at the sole discretion of WM UK . When placing trades for securities in client accounts, we may select as trading counterparty R&Co Global Market Solutions (“GMS”), an institutional brokerage firm located in London, England. When placing trades for foreign exchange or foreign exchange derivatives for client accounts, we may select as trading counterparty R&Co Bank AG, a bank based in Zürich, Switzerland. Additionally, GMS provides investment research to us, and we pay for all research obtained from GMS. GMS and R&Co Bank AG are both affiliates of R&Co Group. WM UK will only place trades through affiliates subject to best execution, as described below. Our objective in selecting brokers and counterparties, and in placing trades, is to seek to obtain a total consideration (price plus costs) for each transaction that is the most favorable for the client under the circumstances. The best net price, giving effect to brokerage commissions, spreads, and other costs (as applicable) is an important factor in this decision, but certain factors are considered as they are

deemed relevant under the circumstances. We have procedures in place to periodically review our choice of brokers and counterparties to determine that, taking into account all the factors specified above, the broker or counterparty is providing the best results for our client orders on a consistent basis. In making this determination we will have regard to:   

prices offered for the particular type of instrument over time; average costs per trade charged for the type of trade over time; the order execution policy of, and any other guidance issued by, the relevant broker or dealer from time to time.

WM UK will periodically obtain information as to the general level of commission rates being charged by the brokerage community and evaluate the overall reasonableness of commissions, spreads, markups, and mark-downs paid on client transactions by reference to such data. To the extent our clients have been paying higher commission rates for their transactions, we will determine if the quality of execution and the services provided by the broker / dealer justify these higher commissions. We may remove a broker or dealer from our list of approved counterparties. Order Aggregation (“Batching”) and Allocation We may purchase or sell the same securities for a number of client accounts simultaneously. Orders for the same security are aggregated or “batched” as one order when possible, and when it is in the best interests of all participating clients. It may not be possible to execute an order in a single transaction, due to size, timing issues or market fluctuations. The prices obtained on two or more transactions within a single day may vary, possibly substantially. We generally use an “averaging” procedure, pursuant to which: two or more purchases or sales of a particular security will at times be undertaken at different times over the day and confirmed at an average price. In such cases, the price shown on the confirmation of the client’s purchase or sale will be the average execution price of all purchases and sales that are aggregated for this purpose. For orders that are partially filled, shares will generally be allocated pro-rata among participating accounts that day, based on their pre-trade allocation pro-rata share of the order. Pre-trade allocations reflect factors such as cash considerations, the use of round lots, restrictions or reducing unnecessary custodial costs. Additionally, if we are unable to determine whether it would be impractical to allocate a small number of securities among one or more accounts, we may allocate such securities in a manner it determines in good faith to be a fair allocation. Research We generate our own internal research via our in-house research team. We visit companies and their management, and visit reports are monitored by management and Compliance. We also purchase research from third parties, but we pay for this out of our own funds under MiFID II. There are no softdollar arrangements in place. Trade Errors We have trade error policies that provide for the resolution of transactional errors. Once discovered, errors are required to be reported internally as soon as possible. It is WM UK’s policy to resolve any error identified in a client account in a manner that avoids harm to the client account. Clients receive gains, we bear losses and we do not net gains against losses.

Neither we nor any of our related persons, Supervised Persons or representatives receive economic benefit from any parties, other than the fee we receive to manage portfolios. We do not compensate any third-party person for referrals of U.S. Clients, nor do we receive compensation from any person for U.S. Client referrals. We or our related persons may compensate third parties for client referrals in connection with non-U.S. advisory activities conducted outside of the United States.

There are no legal, regulatory, or disciplinary events to disclose.

We review client accounts and Portfolios at least weekly, and more frequently in the case of relevant market events and other occurrences that may result in investment opportunities or investment risks. Individual securities are reviewed on an ongoing basis to ensure appropriate Portfolio construction and to implement investment decisions. Portfolio managers consider performance, portfolio risk, security selection, and portfolio allocation. Our Investment Controls team also undertake periodic reviews with the members of the Portfolio Management team, to review client accounts which are managed outside of standard Portfolio parameters.

Custodians provide account statements to clients monthly, or quarterly, at a minimum. Apart from this, we provide a quarterly summary of account activity. These include portfolio appraisal reports exhibiting securities positions, cost, market value and estimated income and asset value.

We do not have custody as this term is defined and applied in the Advisers Act.

We receive discretionary authority at the outset of the advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account.

We do not vote proxies for U.S. Clients, and do not provide advice to clients about how to vote proxies. We do not give advice to, or take any action on behalf of, clients with respect to any legal proceedings, including bankruptcies, class actions and shareholder litigation.

We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients and have not been the subject of bankruptcy proceedings.