Investire LLC: investment adviser

B. Description of Advisory Services Investire offers multiple types of advisory services designed to meet the unique needs of our clients. Below are descriptions of the primary advisory services we offer. A written agreement detailing the exact services we will provide to you and the fees you will be charged will be executed prior to the commencement of any services. Separately Managed Accounts Services Investire offers discretionary portfolio management services on a discretionary basis. We will have the ability to buy or sell securities on your behalf without your prior authorization. Nevertheless, you will have the ability to impose restrictions on the management of your account, including the ability to instruct us not to purchase certain securities. We will manage your account based on your financial situation, investment objectives, risk tolerance and in our understanding of what is in your best interest. Accordingly, we will need to obtain certain information from you to determine your financial situation, investment objectives, and risk tolerance. As part of this process, an investment adviser representative will assist you in completing a risk questionnaire and review the information you provide. You will be responsible for notifying us of any updates regarding your financial situation, investment objectives, or risk tolerance and whether you wish to impose or modify any existing investment restrictions. The financial situation, investment objectives, and risk tolerance for each client of Investire is unique. As a result, we may give advice to another client or take actions for them or for our personal accounts that is different from the advice we provide to you, or actions taken for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that the particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client s benefit. C. Investment Advisor Services process The separately managed advisory programs offered by Investire are based on the individual needs of our clients. We make a thorough assessment of our client s goals, objectives, investment horizon, and risk tolerance. Subject to any written guidelines which the Client may provide, the Firm may be granted discretion and authority to manage the account. Page 4 of 24

Investire is authorized to perform various functions, at the Client s expense, without further approval from the Client. Such functions include the determination of securities to be purchased/sold and the amount of securities to be purchased/sold. Prior to engaging Investire to provide any of the aforementioned investment advisory services, the Client will be required to enter into one or more written agreements with Investire setting forth the terms and conditions under which Investire shall render its services. At the beginning of the relationship, Investire meets with the new Client, gathers information, performs research and analysis as necessary and then prepares an investment plan for the Client. Once the Client portfolio is constructed, Investire will provide continuous supervision and re-balancing of the portfolio as changes in market conditions and as Client s circumstances may require. These objectives and other data are commonly revised or updated over time. In some instances, these changes are made in writing; in others, they are agreed to verbally and documented accordingly. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without Client consent. Clients are advised to promptly notify Investire in writing if there are any material changes in their financial situation, investment objectives, or in the event they wish to alter any restrictions upon investment management services.

D. Wrap Fee Programs Investire is not a sponsor of any Wrap Fee Program(s).

E. Client Assets Under Management To the date of this Brochure, Investire has Client Assets Under Management for USD 46,237,541.

A. Advisory Fees Discretionary Advisory Services Upon the Client s engagement of Investire to provide separately managed account services, Investire shall perform those services for an annual fee, charged based on a percentage of assets under management, billed in arrears (at the end of the billing period) on a monthly calendar basis and calculated based on the average daily balance of the account for the preceding calendar month. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account to be opened at any time other than the beginning of the billing period. Under the average daily balance method, each day s balance for the month is summed then divided by the number of days in the month, to compute the average daily balance. The average daily balance is then multiplied by the monthly portion of the annual fee to determine the monthly fee due. Page 5 of 24

The advisory fee you will pay will be exclusive of and in addition to brokerage commissions, transaction fees, borrowing costs, and any other costs or expenses incurred by the Client and payable to Client s broker. Investire will not receive any portion of these commissions, transaction fees, or other brokerage costs. Investire could charge a performance fee to certain qualified clients, as this term is defined by rule 205-3 of the Investment Adviser Act and the US Securities and Exchange Commission. Performance-based fees could be billed quarterly or annually. Investire could charge Flat Fees. Flat fees could be billed monthly, quarterly, or annually. Fees charged for our direct asset management services are negotiable by each of our investment adviser representatives based upon the type of client, the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. Based upon the above negotiability factors, each investment adviser representative is allowed to set Investire s investment management fee up to a maximum amount of 2.0% annually and, when agreed upon with certain qualified clients, a maximum performance fee of 20%. The actual annual fee charged by Investire will be specified in the client s agreement with Investire believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. Investment advisory fees will be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. You must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to Investire. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Management fees charged by Investire are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security s prospectus. Please be aware that the way we charge fees (i.e., based on assets that we manage for our clients) creates a conflict of interest as we have an incentive to increase the assets clients have in the accounts we manage so that we increase our revenues. However, bear in mind that we mitigate this conflict by only advising you to establish a relationship with Investire when we believe it is in your best interest. Similarly, we will only advise you on investment products and strategies that we believe are in your best interest. Compensation for Sale of Securities Investire investment adviser representatives are not affiliated with any broker-dealer.

B. Billing Procedures Discretionary Portfolio Management Services Separately Managed Account management fees are typically deducted daily. Fees are deducted from a designated Client account to facilitate payment collection. Clients must consent in advance, when engaging with Investire to provide separately managed account services, to direct debiting of their investment accounts. Investire collects Page 6 of 24

advisory fees from the Client s custodian on a daily basis, with the amount of the advisory fee to be deducted from the account, given the agreed conditions when celebrating the discretionary management agreement. Furthermore, the custodian sends Client s account statements at least quarterly showing the deduction of the management or advisory fee. The same logic applies for performance fees. These are typically deducted quarterly, in arrears, from Clients after the quarterly billing period has ended. Fees are deducted from a designated Client account to facilitate payment collection. As for management fees, the Clients must consent in advance, when engaging with Investire to provide separately managed account services, to direct debiting of their investment accounts. Performance fees will be collected in accordance with a high watermark hurdle. Flat fees are deducted monthly. Fees are deducted from a designated Client account to facilitate payment collection. As for management fees, the Clients must consent in advance, when engaging with Investire to provide separately managed account services, to direct debiting of their investment accounts. A Flat fee is set to replace other fees in an investment management agreement. Investire reserves the right to waive or reduce fees.

C. Other Fees & Expenses There may be additional fees or charges that result from the maintenance of our trading within your account. These fees are imposed by third parties in connection with investments made through your account. Any additional fees, charges or expenses resulting from maintenance of our trading within the account shall be the sole responsibility of the Client.

D. Refund Policy A Client may terminate the Investment Advisory Services Agreement for any reason at any time by notifying Investire in writing. Given that all payments will be made in arrears, no refund will be made. Investire may terminate any of the services at any time by notifying the Client in writing.

E. Other Compensation Investire does not receive or accept any other types of compensation in addition to the Management and Performance Fees.

F. Other Information The investment terms offered to different Clients pursuing similar investment objectives may differ. Advisory fees may be negotiable for Clients in certain circumstances and Investire may enter into individual agreements with particular Clients with respect to the method of payment and timing of charging any management fee or performance fee. Managed Accounts Clients may be invoiced for advisory fees, or they may self-remit payment for those fees. Please be aware that the way we get compensated creates a conflict of interest. This is because we charge based on assets that we manage on your behalf, and as such, we have an incentive in increasing the assets that we manage so that we can increase our fee revenue. We mitigate this conflict by only advising you to invest and design portfolios that are in your best interest. Execution of Client transactions typically requires payment of brokerage commissions by Clients. Investment activity may also involve other transaction fees and taxes payable by Clients, including but not limited to, sales charges, oddPage 7 of 24

lot differentials, transfer taxes, financial transaction taxes, wire transfer and electronic fund fees, overdraft fees and other fees and taxes on brokerage accounts and securities transactions. In addition, Clients may incur certain charges imposed by custodians, prime brokers, counterparties, banks, governmental authorities, third-party investment consultants, attorneys and other third parties, such as custodial fees, consulting fees, administrative fees, auditing fees, legal fees, and insurance fees.

Additionally, since performance fees reward for performance in accounts which are subject to such fees, Investire may have an incentive to favor these accounts over those that have only asset-based fees with respect to trading opportunities, trade allocation, and allocation of new investment opportunities. Generally, Investire addresses these conflicts by utilizing an investment allocation policy designed to treat all Clients fairly and equitably. Investire has defined an investment policy to address these issues, consisting of in: 1)

2)

Block Trading and Allocation: we will buy the securities for all the accounts in a single operation per security and then proceed to allocate them to the accounts that will have those securities in their portfolios. There will be no price variations between accounts, no matter if the account has a performance fee or not. Investire will offer a set of portfolios that are managed with independence of the accounts that subscribe to those portfolios. Risk profiles of the clients will be approached by setting different percentages of allocation in the different portfolios we offer. More risk averse clients will have a greater participation of low risk portfolios in their individual portfolio than less risk averse clients.

Please see below and Item 12 Brokerage Practices for more information.

Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Cyclical The Cyclical Method analyzes investments which are sensitive to business cycles and whose performance is strongly tied to the overall economy. For example, cyclical companies tend to make products or provide services that are in lower demand during downturns in the economy and in higher demand during upswings. Examples include the automobile, steel, and housing industries. The stock price of a cyclical company will often rise just before an economic upturn begins and fall just before a downturn begins. Investors in cyclical stocks try to make the largest gains by buying the stock at the bottom of a business cycle, just before a turnaround begins. While most economists and investors agree that there are cycles in the economy that need to be respected, the duration of such cycles is generally unknown. An investment decision to buy at the bottom of a business cycle may actually turn out to be a trade that occurs before or after the bottom of the cycle. If done before the bottom, then downside price action can result prior to any gains. If done after the bottom, then some upside price action may be missed. Similarly, a sell decision meant to occur at the top of a cycle may result in missed opportunity or unrealized losses. Algorithmic trading Algorithmic Trading refers to the use of computer-based algorithms that automatically generate trading signals or execute trades based on predefined criteria, mathematical models, or market data inputs. These algorithms are designed to process large volumes of information and respond to market movements at speeds and frequencies that are not possible through manual trading. In some cases, algorithmic trading may be used to identify short-term market opportunities, execute systematic strategies, or improve trade execution efficiency. The use of algorithmic trading involves unique risks and limitations. Algorithms rely heavily on historical data and programming logic, which may not accurately predict future market conditions or account for sudden changes in liquidity, volatility, or market structure. System errors, technology malfunctions, or disruptions in market data feeds may also result in unintended trades or losses. Additionally, algorithmic strategies may react similarly to those used by other market participants, potentially amplifying short-term price movements. Only selected client accounts may utilize algorithmic trading strategies, and participation in such programs will occur only with the client’s prior consent. Algorithmic trading is not a generalized practice within the firm and may not be suitable for all clients or investment objectives

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Fundamental The Fundamental Method evaluates a security by attempting to measure its intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. Technical The Technical Method evaluates securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. To conduct analysis, Investire gathers information from financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses and filings with the SEC, company press releases and other public information sources. There are risks involved with any method of analysis that may be used.

B. Investment Strategies Investire may employ the following investment strategies when managing client assets and/or providing investment advice: Value investing. A value investing strategy selects stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, resulting in stock price movements that do not correspond with Page 10 of 24

the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to-earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e., businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. Tactical asset allocation. A tactical asset allocation strategy allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. A strategic asset allocation strategy calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a buy and hold strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter.

C. Types of Securities Offered and Risk of Loss We do not primarily recommend one specific type of security to clients. There can be no assurance that the objectives associated with any strategies described above will be met. At any time, Investire may add, remove, or modify any of the strategies it employs, and this includes any of the strategies discussed above. These methods, strategies, and investments involve risk of loss to Clients and Clients must be prepared to bear the loss of their entire investment. There are many different events that can affect the value of a client s assets or portfolio(s) including, but not limited to, changes in financial status of companies, market fluctuations, changes in exchange rates, trading suspensions and delays, economic reports, and natural disasters. Some of the risks associated with Investire’ s investment strategies, and the securities and other assets utilized to implement those strategies, include, but are not limited to, those listed below: Accuracy of Public Information Risk: We select investments, in part, on the basis of information and data filed by issuers with various government regulators or made publicly available by the issuers or through publicly available sources other than the issuers. Although we evaluate this information and data, we are not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information may not be available. Borrowing and Embedded Leverage: Some Clients allow secured and unsecured borrowing to the maximum extent allowable under applicable credit regulations. Like other forms of leverage, the use of borrowing can enhance the risk of capital loss in the event of adverse changes in the level of market prices of the assets being financed with the borrowings. Leverage may also take the form of financial instruments, including OTC derivative instruments which are inherently leveraged, and products with embedded leverage such as options and short sales, in which an investor can lose more money than the initial cost of the investment. The use of leverage allows the Clients to increase their exposure to assets, such that total assets may be greater than capital invested. However, the use of leverage may also magnify the volatility or the likelihood of short-term changes in value of any portfolio. The effect of the use of leverage in a portfolio may result in losses to the portfolio that exceed losses to the portfolio if such portfolio did not utilize leverage. Page 11 of 24

Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Computer System Risks: Throughout its investment management process and business operations, Investire relies on a variety of computer hardware and software systems and platforms, some of which may be proprietary while others may be licensed from third parties (such systems and platforms, collectively, Computer Systems ). Incorrect data, including stale or missing data, hardware or software malfunctions, programming inaccuracies, and similar errors may impair the performance of Computer Systems, which may negatively affect investment performance. Concentration Risk: This is the risk that a portfolio concentrates investments in a limited number of issuers, or in issuers within the same economic sector, industry, or geographic location. The value of such concentrated portfolios may be particularly susceptible to adverse economic, business, or political developments compared to more diversified portfolios. Crowding/Convergence: There is significant competition among quantitatively focused managers. To the extent that Investire s models come to resemble those employed by other managers, the risk that a market disruption that broadly affects the models of quantitatively-focused managers (including competitors of Investire) may adversely affect a Client is increased, as such a disruption could accelerate reductions in liquidity or rapid repricing due to simultaneous trading across a number of funds in the marketplace. Currency Risk: Currency risk is the risk that changes in currency exchange rates will negatively affect securities denominated in, and/or receiving revenues in, foreign currencies. The liquidity and trading value of foreign currencies could be affected by global economic factors, such as inflation, interest rate levels, and trade balances among countries, as well as the actions of sovereign governments and central banks. Adverse changes in currency exchange rates (relative to the U.S. dollar) may erode or reverse any potential gains from investments in securities denominated in a foreign currency or may widen existing losses. Cybersecurity Risk: With the increased use of technologies such as the Internet to conduct business, the Adviser and its Clients are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through hacking or malicious software coding) for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyberattacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Cyber incidents affecting the Adviser and other service providers (including, but not limited to, accountants, law firms, custodians, transfer agents and financial intermediaries) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, impediments to trading, the inability of Clients and/or investors to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which a client invests, counterparties with which a client engages in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and other service providers for Clients) and other parties. In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future. While a client s service providers may have established business continuity plans in the event of, and risk management systems to prevent, such cyber incidents, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, the Adviser cannot control the cyber security plans and systems put in place by its service providers or any other third parties whose operations may affect a client. As a result, Clients could be negatively impacted. Page 12 of 24

Database Errors: Our strategies rely on proprietary databases and third-party data sources. As a result, any errors in the underlying data entry, database or the assumptions underlying the strategies may result in a portfolio acquiring or selling investments based on incorrect information. Additionally, data entry made by our internal team of financial analysts may contain errors, as may the database system used to store such data. When strategies and data prove to be incorrect, misleading, flawed, or incomplete, any decisions made in reliance thereon expose our clients to potential risks. For example, by relying on our strategies and data, we may be induced to buy certain investments at prices that are too high, to sell certain other investments at prices that are too low, or to miss favorable opportunities altogether. Similarly, any hedging based on faulty strategies and data may prove to be unsuccessful. As a result, the portfolio could incur losses on such investments before the errors are identified and corrected. We do not reimburse the portfolios or Clients for database errors. Options Risk: An investment in options may be illiquid, difficult to price, and subject to leverage, such that small changes in circumstances generate disproportionate losses to a portfolio. Because of the complexity of options, such investments may not perform as anticipated and returns/losses may be difficult to monitor. Emerging Markets Investments: Investing in the securities or other instruments of issuers located in nonU.S. countries may involve certain risks not typically associated with investing in established economies or securities markets. Such risks may include (i) the risk of nationalization or expropriation of assets and confiscatory or other taxation; (ii) social, economic and political instability, including war; (iii) dependence on exports; (iv) less liquidity of securities markets; (v) significant currency exchange rate devaluations, fluctuations, and declines against the U.S. dollar; (vi) potentially higher rates of inflation (including hyperinflation) and rapid fluctuations in inflation; (vii) controls on foreign investment and limitations on repatriation of invested capital and the Client s ability to exchange local currencies for U.S. dollars; (viii) a higher degree of governmental involvement in and control over the economies; (ix) government decisions to discontinue support for economic reform programs and imposition of centrally planned economies; (x) differences in auditing and financial reporting standards which may result in the unavailability of material information about economies and issuers; (xi) less extensive regulatory oversight of securities markets; (xii) longer settlement periods for securities transactions; (xiii) less stringent laws regarding the protection of investors; (xiv) certain consequences regarding the maintenance of a Client s portfolio securities and cash with sub-custodians and securities depositories in such countries; (xv) difficulty in enforcing contractual obligations; (xvi) inexperience of financial intermediaries, lack of modern technology, and the lack of a sufficient capital base to expand business operations; and (xvii) less available information than is generally the case in the United States. All of the foregoing factors lead to greater market volatility. Equity Securities: Equity securities fluctuate in value in response to many factors, including the activities, results of operations, and financial condition of individual companies; the business market in which individual companies compete; industry market conditions; interest rates; and general economic environments. In addition, events such as domestic and international political instability, terrorism and natural disasters may be unforeseeable and contribute to market volatility in ways that may adversely affect investments made by a client. Financial Risk: Excessive borrowing to finance a business operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Foreign Investments Risk: Foreign investments often involve special risks do not present in U.S. investments that can increase the chances that an investment will lose money. For example, a client may hold its foreign securities and cash in foreign banks and securities depositories, which may be recently organized or new to the foreign custody business and subject to only limited or no regulatory oversight. Changes in foreign currency exchange rates can affect the value of a portfolio. The economies of certain foreign markets may not compare favorably with the economy of the United States, and the governments of certain countries may prohibit or impose substantial restrictions on foreign investments in their capital markets or in certain Page 13 of 24

industries. Many foreign governments do not supervise and regulate stock exchanges, brokers, and the sale of securities to the same extent as does the United States and may not have laws to protect investors that are comparable to U.S. securities laws. Settlement and clearance procedures in certain foreign markets may result in delays in payment for or delivery of securities not typically associated with settlement and clearance of U.S. investments. Foreign (Non-U.S.) Risk: A portfolio s investments in securities of non-U.S. issuers may involve more risk than those of U.S. issuers. The prices of these securities may fluctuate more widely and may be less liquid due to adverse market, economic, political, regulatory, or other factors. General Risks of Options Use: Options trading is highly speculative. Price movements of options contracts are influenced by, among other things, changing supply and demand relationships, governmental agricultural and trade programs and policies, and national and international political and economic events. In addition, unless a portfolio is hedged against fluctuations in the exchange rate between the U.S. dollar and the currencies in which trading is done on some foreign exchanges, any profits that such a portfolio realizes in trading on such exchanges could be eliminated by adverse changes in the exchange rate, or such a portfolio could incur losses as a result of any such changes. Due to the low margin deposits normally required in options trading, an extremely high degree of leverage is typical of an options trading account. As a result, a relatively small price movement in an options contract price may result in substantial losses to a portfolio. Like other leveraged investments, any purchase or sale of an options contract may result in losses in excess of the amount invested. Accordingly, relatively small options positions have the potential to erode significantly or erase gains and compound losses in other investments held by a portfolio. Hedging: There can be no assurances that a particular hedge is appropriate or that certain risk is measured properly. Further, while Investire may enter into hedging transactions to seek to reduce risk, such transactions may result in poorer overall performance and increased (rather than reduced) risk for the Client portfolios than if Investire did not engage in any such hedging transactions. Inflation Risk: When any type of inflation is present, a dollar will be worth more today than a dollar next year, because purchasing power is eroding at the rate of inflation. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Investment Company and Exchange-Traded Fund ( ETF ) Risks: Investments in an investment company or ETF involve substantially similar risks to investments in the underlying securities of the company or ETF. Investment companies and ETFs may not achieve the intended investment objective, or may otherwise not execute the investment strategy effectively, which may adversely affect the value of a portfolio. ETFs include the added risk that they may no longer satisfy the listing standards of the exchange on which they are traded. Issuer Risk: The value of a security may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer s goods or services, as well as the historical and prospective earnings of the issuer and the value of its assets. Key Person Risk: Termination, disability, death, or departure of key personnel could adversely affect the underlying fund and its performance. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Market Drawdown Risk: Investire deploys risk management strategies that seek to minimize market drawdowns. When reduced equity exposure is indicated, Investire will short index futures to reduce market exposure; however, client assets will remain fully invested in the affiliated investment company strategies, regardless of market signal. The purpose of this practice is to enable clients to follow a risk management strategy without recognizing tax liabilities. The use of this strategy exposes clients to additional risks associated with options and short trades, which are discussed more fully below. Page 14 of 24

Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Model and Data Risk: Given the complexity of Investire s investments and strategies, the Adviser relies heavily on quantitative models (both proprietary models developed by the Adviser, and those supplied by third parties) and information and data supplied by third parties ( Models and Data ). Models and Data are used to construct sets of transactions and investments, to value investments or potential investments (whether for trading purposes, or for the purpose of determining the net asset value of a client), to provide risk management insights, and to assist in hedging the Clients investments, if applicable. When Models and Data prove to be incorrect or incomplete, any decisions made in reliance thereon expose Clients to potential risks. For example, by relying on Models and Data, the Adviser may be induced to buy certain investments at prices that are too low, or to miss favorable opportunities altogether. Similarly, any hedging based on faulty Models and Data may prove to be unsuccessful. Some of the models used by Investire are predictive in nature. The use of predictive models has inherent risks. For example, such models may incorrectly forecast future behavior, leading to potential losses on a cash flow and/or a mark-to-market basis. In addition, in unforeseen or certain low-probability scenarios (often involving a market disruption of some kind), such models may produce unexpected results, which can result in losses to a client s portfolio. Furthermore, because predictive models are usually constructed based on historical data supplied by third parties, the success of relying on such models may depend heavily on the accuracy and reliability of the supplied historical data. All models rely on correct market data inputs. If incorrect market data is entered into even a well-founded model, the resulting valuations will be incorrect. However, even if market data is input correctly, model prices will often differ substantially from market prices, especially for securities with complex characteristics, such as options contracts. Obsolescence Risk: Investire s strategies are unlikely to be successful unless the assumptions underlying the models used to implement those strategies are realistic and either remain realistic and relevant in the future or are adjusted to account for changes in the overall market environment. If such assumptions are inaccurate or become inaccurate and are not promptly adjusted, it is likely that profitable trading signals will not be generated. If and to the extent that the models do not reflect certain factors, and Investire does not successfully address such omission through its testing and evaluation and modify the models accordingly, major losses may result. Investire will continue to test, evaluate, and add new models, as a result of which the existing models may be modified or discontinued from time to time. There can be no assurance as to the effects (positive or negative) of any modification on a client s portfolio. Operational Risk: Investire has developed systems and procedures to manage operational risk. Operational risks arising from mistakes made in the confirmation or settlement of transactions, from transactions not being properly booked or accounted for, or other similar disruption in the Adviser s operations may cause the Adviser to suffer financial loss, the disruption of its business, liability to Clients or third parties, regulatory intervention, or reputational damage. Investire relies heavily on its portfolio management, trading, financial, accounting, and other data processing systems. The ability of its systems to accommodate an increasing volume of transactions could also constrain the Adviser s ability to properly manage a client s portfolio. Portfolio Turnover: Active and/or frequent trading of securities and financial instruments within a portfolio may produce increased transaction costs, including brokerage commissions, fees, transaction taxes, and other transaction costs. Likewise, such active and/or frequent trading may result in short-term capital gains tax treatment. Programming and Modeling Errors: Investire s research and modeling process is extremely complex and Page 15 of 24

involves financial, economic, econometric, and statistical theories, research, and modeling; the results of that process must then be translated into computer code. Although Investire seeks to hire individuals skilled in these functions and to provide appropriate levels of oversight, the complexity of the individual tasks, the difficulty of integrating such tasks, and the limited ability to perform real world testing of the end product raises the chances that the finished model may contain an error. One or more of such errors could adversely affect a client s portfolio and would generally not constitute a trade error subject to reimbursement under Investire s policies. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Risks from Purchasing Options: If a call or put option purchased by us is not sold when it has remaining value and if the market price of the underlying security, in the case of a call, remains less than or equal to the exercise price, or, in the case of a put, remains equal to or greater than the exercise price, you will lose its entire investment in the option. There is no assurance that a liquid or "fair" market will exist when we seek to close out an option position. Where a position in a purchased option hedges a related position, the price of the option may move more or less than the price of the related position. Risks from Selling Options: Selling or writing option contracts often results in a "short" position (see Short Selling Risk below). A short position can result in losses that substantially exceed your initial investment. There is no assurance that a liquid or "fair" market will exist when we seek to close out a short option position. This lack of marketability may result in further losses. In cases when we sell an option to hedge against price movements in a related underlying position, such as in connection with our risk management strategy described above, the price of the option may move more or less than the price of the related position and not fully hedge the position. Short Selling Risk: When an investor short sells a security, the investor s losses technically could be infinite. A short sale trade loses money when the price of the underlying security rises. Theoretically, a security price could rise by an unlimited amount. When the underlying securities prices go up, a short seller's losses get higher, and as sellers rush to buy the stock to cover their positions, the losses increase exponentially. This phenomenon is known as a short squeeze. Usually, news in the market will trigger a short squeeze, but sometimes traders who notice a large number of shorts in a stock will attempt to induce one. Timing is an additional complication. Even though a security is overvalued, it could conceivably take some time for the price to decline. In the meantime, the short investor is vulnerable to interest charges, margin calls, dividend payments if any and other adverse effects. Tax Risk: Tax laws and regulations applicable to an account are subject to change, and unanticipated tax liabilities could be incurred by investors as a result of such changes. Investors should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Trading Decisions Based on Quantitative and Other Analysis: Investire s portfolio management and trading decisions are based on quantitative models, signals, and other analyses. Any factor that would lessen the prospect of major trends occurring in the future (such as increased governmental control of, or participation in, the financial markets) may reduce the prospect that a particular trading method or strategy will be profitable in the future. In the past, there have been periods without discernible trends and, presumably, such periods will continue to occur in the future. Moreover, any factor that would make it more difficult to execute trades at desired prices in accordance with the signals of the trading method or strategy (such as a significant lessening of liquidity in a particular market) would also be detrimental to profitability. Further, many advisors investment models and trading methods utilize similar analyses in making trading decisions. Therefore, a bunching of buy and sell orders can occur, which makes it more difficult for a position to be taken or liquidated. No assurance can be given that the Adviser s strategies will be successful under all or any market conditions. While this information provides a synopsis of the events that may affect a client’ s investments, this listing is not exhaustive. There are inherent risks associated with investing and depending on the risk occurrence; and one may Page 16 of 24

suffer LOSS OF ALL OR PART OF THEIR PRINCIPAL INVESTMENT.

Investire will disclose material facts and potential conflicts of interest to clients. Investire seeks to conduct business in an honest, ethical, and fair manner and will take reasonable steps to avoid circumstances that might negatively affect our duty of loyalty to clients. This section is intended to provide clients with a summary of Investire s Code of Ethics. Clients may receive a complete copy of the Code of Ethics upon request.

B. Affiliate and Employee Personal Securities Transactions Disclosure Investire or associated people of the firm may buy or sell for their personal accounts investment products identical to those recommended to clients. This creates a potential conflict of interest. It is the express policy of Investire that all people associated in any manner with our firm must place clients interests ahead of their own when implementing personal investments. Investire and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. To mitigate potential conflicts of interest, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees, and their immediate family members (collectively, associated persons). Any associated person not observing our policies is subject to sanctions up to and including termination.

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The primary factor in suggesting a broker/dealer or custodian is that the services of the recommended firm are provided in a cost-effective manner. While quality of execution at the best price is an important determinant, best execution does not necessarily mean lowest price and it is not the sole consideration. The trading process of any broker/dealer and money manager suggested by Investire must be efficient, seamless, and straight-forward. Overall custodial support services, trade correction services, and statement preparation are some of the other factors determined when suggesting a broker/dealer. Unless specifically agreed upon, Investire will not be responsible for the best execution of transactions. Investire will rely on the client s broker/dealer best execution process. However, Investire will assess if the its clients are receiving best execution when directing transactions to the client s broker/dealer. On the instances where Investire is responsible for obtaining best execution, it will ensure that the client receives best execution for transactions. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, we may consider a number of factors other than prices and rates including, but not limited to: • • • • •

Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments) Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research, and analytic services) Financial strength, stability, and responsibility Reputation and integrity Ability to maintain confidentiality.

We exercise reasonable due diligence to make certain that the best execution is obtained for all clients when implementing any transaction by considering the back office services, technology and pricing of services offered.

B. Directed Brokerage Clients should understand that not all investment advisors require the use of a particular broker/dealer or custodian. Some investment advisors allow their clients to select whichever broker/dealer the client decides. By requiring clients to use a particular broker/dealer, Investire may not achieve the most favorable execution of client transactions and the practice requiring the use of specific broker/ dealers may cost clients more money than if the client used a different broker/dealer or custodian. However, for compliance and operational efficiencies, Investire has decided to require our clients to use broker/dealers and other qualified custodians determined by Investire.

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C. Soft Dollar Benefits An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser receives research or other products and services in exchange for client securities transactions or maintaining an account balance with the broker-dealer or custodian. Except as described above, Investire does not have a soft dollar agreement with any broker-dealer, custodian or other third party.

D. Block Trading Policy When aggregating and allocating securities transactions, our clients are treated in a fair and equitable manner. No account will be favored over any other accounts. All Clients participating in an aggregated order must be treated fairly. In the regular course of business, we may at times enter orders for multiple advisory accounts in order to obtain the best pricing averages and minimize trading costs for our clients. Accordingly, our policies and procedures mandate allocating the orders to the appropriate Client accounts as soon as possible thereafter and allocating transactions equitably. Investire will seek to allocate investment opportunities and trade fairly. Fair treatment does not mean identical treatment of all Clients. Rather, it means that Investire does not discriminate on an impermissible basis against one Client or group of Clients. When Investire transacts in securities or instruments for more than one Client, the investment opportunities and trades will be allocated in a manner consistent with Investire s fiduciary duties. Investire may not allocate trades in such a way that Investire s personal, proprietary, or affiliated accounts receive more favorable treatment than Clients accounts. Similarly, Investire may not allocate profitable trades at each day s end so as to disproportionately favor certain Clients without appropriate disclosure. In making investment decisions for the accounts, securities considered for investment by one Client may also be appropriate for another Client. On occasions when the purchase or sale of a security is deemed to be in the best interest of more than one Client, Investire may, but will not be obligated to, aggregate or batch orders for the purchase or sale of securities for all such accounts to the extent consistent with best execution and the terms of the relevant investment advisory agreements. Such combined or batched trades may be used to facilitate best execution, including negotiating more favorable prices, obtaining more timely or equitable execution, or reducing transaction charges. When Investire decides to purchase or sell the same securities for several Clients at approximately the same time, Investire is not required to aggregate such transactions, but will do so absent a determination by our Firm s Compliance Officer based on the best interests of Investire s Clients. Investire will aggregate and allocate orders only in a manner designed to ensure no Client or account is favored over others over time. Investire believes that aggregation is consistent with Investire s duty to seek best execution and best price for Clients and is consistent with Investire s investment advisory agreements with each Client for which trades are being aggregated. We will instruct our broker-dealer (custodian) to process our clients trades in the most cost-effective manner while securing quality of execution. The Compliance Officer will review transactions periodically to prevent and detect excessive costs related to non-compliance with order aggregation procedures.

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B. Intermittent Review Factors Although Investire reviews each Client s account on a regular basis, there are facts and circumstances which may prompt ad hoc reviews. Significant market events affecting the prices of one or more securities held by a client, changes in investment objectives or guidelines of a particular Client, or specific arrangements with particular Clients or investors may trigger more frequent reviews of a particular Client s account.

C. Statements and Reports Managed Account Clients receive regular written reports from their custodian and may receive operational reports from Investire upon request or as required in the investment management agreement. At a minimum, each Client will receive a quarterly report from their broker-dealer that will include a statement of account holdings, market value, broker commissions, and advisory fees charged for the period. Clients are encouraged to compare any reports or statements provided by Investire against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact our firm and the qualified custodian preparing the statement.

Item 1 - Cover Page Brochure Supplement (Part 2B of Form ADV) Av. del Libertador 8440, 3rd Floor, Apt 37 Buenos Aires, Argentina Phone: +54 911 55179633 www.investire.capital Firm Brochure Supplement Dated: January 1, 2026 Supervised Persons: Lucas Fernando Rodriguez Julian Ricardo Siri All Supervised Persons can be reached at the address and telephone number listed above. This Brochure Supplement provides information about the above listed Supervised Persons that supplements the Investire, LLC Brochure. You should have received a copy of that Brochure. Please contact Investire’s Chief Compliance Officer at carlos@cimafrc.com if you did not receive Investire’s Brochure or if you have any questions about the contents of this supplement. The information in this supplement has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about all Supervised Persons is available on the SEC’s website at www.adviserinfo.sec.gov.

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Lucas Fernando Rodriguez Born 1985 Item 2 - Educational Background and Business Experience Education: Education: MS, Finance, CEMA University, Buenos Aires, Argentina (03/2009– 12/2010) BS, Economics, CEMA University, Buenos Aires, Argentina (03/2003– 11/2006) Business Experience: CEO, INVESTIRE LLC (11/2018 – Present) Independent Economic and Financial Advisor (11/2014 – 11/2018) Head Trading Desk / Financial Administration Manager, IRSA Group, Argentina (09/2007 – 11/2014) Item 3 - Disciplinary Information Lucas Fernando Rodriguez has not been subject to any legal or disciplinary events. Item 4 - Other Business Activities Lucas Fernando Rodriguez is affiliated with Superavit Asset Management SAS, an investment management firm, where he serves as an Investment Advisor Representative. Item 5 - Additional Compensation Lucas Fernando Rodriguez does not currently receive any additional compensation. Item 6 - Supervision Lucas Fernando Rodriguez is currently under the supervision of Carlos Gonzalez-Stawinski, Chief Compliance Officer. Supervisory contact information: 954-727-3117

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Julián Ricardo Siri Born 1984 Item 2 - Educational Background and Business Experience Education: Education: MSc, Financial Engineering, Columbia University, New York, NY (2011– 2012) MS, Finance, CEMA University, Buenos Aires, Argentina (2007) BS, Economics, CEMA University, Buenos Aires, Argentina (2003– 2006) Business Experience: Chief Financial Officer, INVESTIRE LLC (12/2018 – Present) Quantitative Portfolio Manager, Superávit, Argentina (11/2014 – 11/2018) Independent Portfolio Manager, Argentina (2012 – 2014) Head of Research, Maxinver Inversiones, Argentina (2009 – 2011) Assistant Monetary and Financial development, Central Bank of Argentina, Argentina (2008 – 2009) Item 3 - Disciplinary Information Julián Ricardo Siri has not been subject to any legal or disciplinary events. Item 4 - Other Business Activities Julián Ricardo Siri is affiliated with Superavit Asset Management SAS, an investment management firm, where he serves as an Investment Advisor Representative. Item 5 - Additional Compensation Julián Ricardo Siri does not currently receive any additional compensation. Item 6 - Supervision Julián Ricardo Siri is currently under the supervision of Carlos Gonzalez-Stawinski, Chief Compliance Officer. Supervisory contact information: 954-727-3117

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