Zest: investment adviser

Description of Advisory Services Zest provides portfolio management financial advice and financial planning services to individuals, institutions and corporations. Zest’s investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in Zest’s investment advisory agreement. The Adviser’s discretionary and non-discretionary investment management services include the design, structure, and implementation of various personalized investment strategies for managed Accounts. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies, and risk profile as described by each client. The Adviser also provides personalized confidential financial planning services. Advice is provided through consultation with the client and may include determination and identification of financial objectives, cash flow management, insurance review, investment management, education funding, retirement planning, and educational services. The overall advisory services offered by Zest fall within the following categories: Customized Discretionary Portfolios Adviser offers discretionary separately managed Accounts that are customized to each client. Managed Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in Item No. 8 or customized for each client based upon varying factors. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. Zest tailors the investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation. Client profiles are created that reflect the stated goals and objective. Zest’s clients are allowed to impose restrictions

on the investments in their account. All limitations and restrictions placed on accounts must be presented to Zest in writing.

Other Non-Discretionary Advisory Services

Adviser provides non-discretionary advisory services to all types of clients in accordance with a non- discretionary advisory agreement between Adviser and the client. Each agreement typically defines the services to be provided and if a fee is charged, the fees will also be agreed to in the advisory agreement. Adviser also provides recommendations and research regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs, and such advice may be provided to accounts with assets maintained at various third parties. Investment Funds Adviser provides investment advice to non–U.S. funds (“Investment Funds” or “pooled investment vehicles”). The specific terms, fees, and arrangements for these services are fully disclosed in each Investment Fund's prospectus or offering documents, in accordance with applicable disclosure requirements. Investor funds are deposited in either a brokerage firm or a bank custodian account. Zest Capital Peru SAC, an affiliate Investment Adviser located in Peru, serves as Administrator, Distributor and/or Fund Manager of the Investment Funds and also serves as subadvisor. The Adviser directs the investment and re-investment of the securities, cash, and other assets, in accordance with the information provided by the pooled investment vehicles (“Investment Funds”), which is also managed by Zest Capital Peru SAC, sharing the same responsibilities. All terms are generally established at the time of a pool’s formation and investors may not restrict the investments except as indicated in the fund documents. The Investment Funds authorize the Adviser and Zest Capital Peru SAC to exercise complete and total discretion in the investment of the assets in such Funds. In this connection, the Investment Funds authorize Zest Capital Peru SAC and the Adviser, as agents, to buy, sell, and trade assets in the Funds, in accordance with the terms and conditions of the fund documents and pertaining agreement. Prospective investors in the pooled investment vehicles should be aware of additional risks, restrictions on withdrawals and redemptions and other important information associated with the pooled investment vehicles. Only qualified clients are permitted to participate in the Investment Funds offered by the Adviser.

Other Services

Adviser may provide additional services for clients from time to time as agreed between the client and the Adviser.

Additional General Information

Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. Zest investment advisory agreements may not be assigned without client consent. Zest does not currently participate in any Wrap Fee Programs.

Assets Under Management

As of December 31, 2025, Zest manages a total of $90,613,565 in Regulatory Assets Under Management (“RAUM”), of which $81,023,472 are managed on a discretionary basis and $9,590,092.77 are managed on a non-discretionary basis. The Adviser tailors its advisory services to the individual needs of each client, taking into consideration each client’s financial situation, investment objectives, and risk tolerance.

The fee can range from 0.50% to 2.50% for an Investment Fund value of up to $9,999,999. Calculation and Deduction of Advisory Fees Clients are generally required to authorize Adviser to directly debit management fees from client accounts on a quarterly or monthly basis, depending on the arrangement with the client or Investment Fund. A client may pay more or less fees than similar clients depending on the particular circumstances of the client, size, additional or differing levels of servicing or as otherwise agreed with specific clients. Clients that negotiate fees, including a flat fee, may end up paying a higher fee than that set forth above as a result of fluctuations in the client’s assets under management and account performance.

Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Additional Fee Information Clients may authorize the Adviser to directly debit management fees from client accounts on a quarterly basis. In such instances, management fees are prorated for each capital contribution and withdrawal made during the applicable calendar quarter. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Adviser’s fees for individual discretionary or non-discretionary accounts are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred directly by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by fund managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on brokerage account and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. It is the Adviser’s policy not to accept “kick-backs” or retrocession fees from any third non-affiliated party providing services to the Adviser’s clients. Advisory fees for Investment Funds includes all fees and charges for the services, as applicable, of the Adviser and Zest Capital Peru SAC (“Zest Peru”), and all applicable brokerage charges, but is exclusive of transaction charges and costs, postage and handling charges and direct out-ofpocket costs incurred by the Adviser and Zest Peru as a result of its providing the services contemplated under the Agreement, and separate third party charges for the Investment Fund, including transfer fees set forth in the respective Prospectus, and certain transaction and settlement costs incurred by the Adviser and Zest Peru for the Investment Fund, or separate fees, costs and expenses resulting from the agreement(s) executed between the Investment Fund and Custodian. Termination of the Agreement Although an agreement between Zest and its clients is ongoing and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an agreement by written notice to the other party with a (30) thirty – day advance notice or as agreed upon otherwise between the client and the Adviser. If an agreement is terminated during a period in which the client has already paid Zest its advisory fees in advance, then the Adviser will reimburse, on a pro-rated basis, the remaining advisory fees collected for any service not rendered; these fees will be sent to the client’s address of record, unless otherwise directed by the client, within (30) days of termination of the agreement.

Adviser has procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. The Adviser may have clients with similar investment objectives. The Adviser is permitted to make an investment decision on behalf of clients that differs from decisions made for, or advice given to, such other accounts and clients even though the investment objectives may be the same or similar, provided that the Adviser acts in good faith and follows a policy of allocating, over a period of time, investment opportunities on a basis intended to be fair and equitable, taking into consideration the investment policies and investment restrictions to which such accounts and clients are subject.

providers do not have access to or knowledge of information concerning the specific investment decisions and recommendations made to Adviser’s clients. Through Adviser’s strategy, Adviser seeks asset preservation and capital appreciation of clients’ portfolios by customizing asset allocations and selecting investment vehicles that it believes will align clients’ risk / return expectations with long term and short-term investment needs and goals. The asset class allocations forecasts and expectations are analyzed and invested in various financial instruments, typically include equity, fixed income, options and alternative investments. Adviser will select and monitor the investment vehicles for each asset class in the portfolios based on their history and prospective risk and return characteristics, and determine suitability for each client’s needs, as well as, estimated fees and expense. Material Risks for Significant Investment Strategies While it is the intention of Adviser to implement strategies which are designed to minimize potential losses suffered by its client, there can be no assurance that such strategies will be successful. It is possible that a client may lose a substantial proportion or all of its assets in connection with investment decisions made by Adviser. The following is a discussion of typical risks for Adviser’s clients, but it does not purport to be a complete explanation of the risks involved with Adviser’s investment strategies. There is no guarantee that in any time period, particularly in the short term, a client’s portfolio will achieve appreciation in terms of capital growth or that a client’s investment objective will be met by Adviser. The value of the securities in which Adviser invests on behalf of its clients may be volatile. Price movements may result from factors affecting individual companies, sectors or industries that may influence certain strategies or the securities market as a whole. Furthermore, a client will be subject to the risk that inflation, economic recession, changes in the general level of interest rates or other market conditions over which Adviser will have no control may adversely affect investment results. Adviser notes that while Adviser’s management of accounts may not involve direct leveraging, or other risk factors discussed below, the underlying funds and other investments that comprise client accounts may engage in practices that can materially impact the performance of such fund or investment, which in turn may materially impact the value of Adviser’s clients’ portfolios. Hedging transactions may increase risks of capital losses Adviser utilizes hedging strategies primarily to protect and preserve capital as well as yield enhancement. Investment products in which Adviser invests clients’ accounts may utilize a variety of financial instruments, such as options, for risk management purposes. While hedging transactions may seek to reduce risk, such transactions may result in a worse overall performance. Certain risks cannot be hedged, such as credit risk, relating both to particular securities and

counterparties. Adviser will not always invest in funds or other investment vehicles that utilize hedging strategies. Leverage Adviser may utilize and employ leverage under its current strategies. Such strategies may include the borrowing and short selling of securities, bonds, foreign exchange and the acquisition and disposal of certain types of derivative securities and instruments, such as swaps, futures and options. While leveraging creates an opportunity for greater total returns, it also exposes a client to a greater risk of loss arising from adverse price changes. Where leverage is indirect (e.g., used by a fund manager for a fund in which Adviser’s client is invested) a sharp decrease in the value of the investment can have a significant impact on a client’s portfolio. Liquidity of investment portfolio The market for some securities in which Adviser invests indirectly on behalf of its clients may be relatively illiquid. Liquidity relates to the ability to sell an investment in a timely manner. The market for relatively illiquid securities tends to be more volatile than the market for more liquid securities. Investments in relatively illiquid securities may restrict the ability of a fund or portfolio manager to dispose of investments at a price and time that it wishes to do so. The risk of illiquidity also arises in the case of over-the-counter transactions. There is no regulated market in such contracts and the bid and offer prices will be established solely by dealers in these contracts. Client accounts that are invested in funds or other instruments that contain illiquid investments may be subject to these risks. Foreign currency markets Adviser’s investment strategies may cause a client to be exposed to fluctuations in currency exchange rates where it invests directly or indirectly in securities denominated in currencies other than U.S. dollars. Adviser does not engage in direct foreign currency trading. However, the underlying funds and other investment vehicles may engage in direct foreign currency trading. The markets in which foreign exchange transactions are effected are highly volatile, highly specialized and highly technical. Significant changes, including changes in liquidity and prices, can occur in such markets within very short periods of time, often within minutes. Foreign exchange trading risks include, but are not limited to, exchange rate risk, interest rate risk and potential interference by foreign governments through regulation of local exchange markets, foreign investment, or particular transactions in foreign currency. Derivatives Adviser’s investment strategy may cause a client to be exposed to derivatives including instruments and contracts the value of which is linked to one or more underlying securities, financial benchmarks or indices. Derivatives allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark, index, currency or interest rate at a fraction of the cost of investing in the underlying asset. The value of a derivative depends largely

upon price movements in the underlying asset. Therefore, many of the risks applicable to trading the underlying asset are also applicable to derivatives trading. However, there are a number of other risks associated with derivatives trading. For example, because many derivatives provide significantly more market exposure than the money paid or deposited when the transaction is entered into, a relatively small adverse market movement can result not only in the loss of the entire investment but may also expose a client to the possibility of a loss exceeding the original amount invested. Settlement risks Adviser’s investment strategies may expose a client to the credit risk of parties with whom Adviser, on behalf of the client or the underlying funds, trades and to the risk of settlement default. Market practices in the emerging markets in relation to the settlement of securities transactions and custody of assets will provide increased risk. Although the emerging markets have grown rapidly over the last few years, the clearing, settlement and registration systems available to effect trades on such markets are significantly less developed than those in more mature world markets which can result in delays and other material difficulties in settling trades and in registering transfers of securities. Problems of settlement in these markets may affect the net asset value and liquidity of a client’s portfolio or investments in such portfolios. Emerging Markets Adviser’s investment strategies include direct and indirect investments in securities in emerging markets, and such investments involve special considerations and risks. These include a possibility of nationalization, expropriation or confiscatory taxation, foreign exchange control, political changes, government regulation, social instability or diplomatic developments which could affect adversely the economies of such countries or the value of a client’s investments, and the risks of investing in countries with smaller capital markets, such as limited liquidity, price volatility, restrictions on foreign investment and repatriation of capital, and the risks associated with emerging economies, including high inflation and interest rates and political and social uncertainties. In addition, it may be difficult to obtain and enforce a judgment in a court in an emerging country. The economies of many emerging market countries are still in the early stages of modern development and are subject to abrupt and unexpected change. In many cases, governments retain a high degree of direct control over the economy and may take actions having sudden and widespread effects. Investments in products of emerging market may also become illiquid which may constrain Adviser’s ability to realize some or all of a client’s portfolio holdings. Accounting standards in emerging market countries may not be as stringent as accounting standards in developed countries. Investment Concentration Some client accounts may have a high concentration in one sector, industry, issuer or security that may subject such accounts to greater risk of loss in the event such investments take an economic downturn.

Material Risks for Particular Types of Securities The Adviser does not invest primarily in a specific security or type of security. The material risks involved with investing are described above.

Commodity Pool Operator, Commodity Trading Adviser, Futures Commission Merchant Registration Neither Adviser nor its management persons or associated persons are registered or associated with the Commodity Futures Trading Commission (“CFTC”) as a futures commission merchant (“FCM”), a commodity pool operator (“CPO”) or a commodity trading advisor (“CTA”) or an associated person of the foregoing entities. Other – Financial Affiliates Please see the Adviser’s Form ADV Part 1 for further details related to other affiliated entities, if applicable.

Adviser’s policy on insider trading applies to securities trading and information handling by all Supervised Persons of Adviser (including spouses, minor children and adult members of their households and any other relative of a Supervised Person on whose behalf Supervised Person is acting) for their own account or the account of any client of Adviser. Adviser takes its obligation to detect and prevent insider trading with the utmost seriousness. Adviser may impose penalties for breaches of the policies and procedures contained in this manual, even in the absence of any indication of insider trading. Depending on the nature of the breach, penalties may include a letter of censure, profit “give ups,” fines, referrals to regulatory and selfregulatory bodies and dismissal. Personal Securities Transactions Periodic Reports As more fully described in the Code, “access persons” are required to submit reports detailing their personal securities holdings to the Chief Compliance Officer on an initial basis, a quarterly basis, and an annual basis. As an alternative to submitting quarterly transaction reports, Adviser requires persons who are “access persons” to submit brokerage statements or trade confirmations as long as such documents contain the information required under Rule 204A-l(b)(2)(i)(A)-(E) under the Advisers Act. Initial Public Offerings and Limited Public Offerings Access Persons must obtain prior written approval from the Chief Compliance Officer before investing in initial public offerings (“IPOs”) or limited offerings (i.e., private placements). In the event the Chief Compliance Officer wishes to purchase IPOs or the securities of a private placement for his/her own employee account, the Chief Compliance Officer must obtain prior written approval from the Adviser’s Board Committee.

Review of Personal Securities Reports The Chief Compliance Officer (or their designee) is responsible for reviewing the Access Person’s Quarterly Transaction Reports as well as the Initial Holdings Report and the Annual Holdings Report as part of Adviser’s duty to maintain and enforce the Adviser’s Code. In instances when the Chief Compliance Officer has engaged in personal securities transaction, the Adviser’s Board Committee shall review the Chief Compliance Officer’s brokerage statements and trade confirmations. Outside Business Activities and Private Investments of Employees Unless otherwise consented by the Chief Compliance Officer, all employees are required to devote their full time and efforts to Adviser’s business. As such, no person may make use of either his or her position as an employee or information acquired during employment, or make personal investments in a manner that may create a conflict, or the appearance of a conflict, between the employee’s personal interests and Adviser’s interests. Accordingly, every employee is required to complete a disclosure form and have the form approved by Adviser’s Chief Compliance Officer prior to serving in any of the capacities or making any of the investments more fully described in the Code. Reporting Violations All Supervised Persons (any officer, director, partner and employee of Adviser) are required to report actual or known violations or suspected violations of Adviser’s Code promptly to the Chief Compliance Officer or his designee. Any report of a violation or suspected violation of the Code will be treated as confidential to the extent permitted by law. As part of Adviser’s obligations to conduct an annual review of all of its policies and procedures pursuant to Rule 206(4)-7 of the Advisers Act, the Chief Compliance Officer shall review on an annual basis the adequacy of the Code and the effectiveness of its implementation. Recordkeeping Adviser maintains the following:

Copies of the Code; Records of violations of the Code and actions taken as a result of the violations; Copies of Adviser’s supervised persons’ written acknowledgement of receipt of the Code; Records of Access Persons’ personal trading — Initial Holdings Reports, Annual Holdings Reports, and Quarterly Transaction Reports, including any information provided under Rule 204A- 1(b)(3)(iii) in lieu of such reports, i.e., brokerage confirmations and transaction reports; A record of the names of Adviser’s “Access Persons”;

Records of decisions, and the reasons supporting the decision to approve an Access Person’s acquisition of securities in initial public offerings or limited offerings; and Records of decisions, and the reasons supporting the decision to approve the Chief Compliance Officer’s acquisition of securities in initial public offerings or limited offerings.

Acknowledgement of the Code Each employee will execute a written statement certifying that the employee has (i) received a copy of Adviser’s Code; (ii) read and understands the importance of strict adherence to such policies and procedures; and (iii) agreed to comply with the Code. Training and Education All Supervised Persons, i.e., all employees, are to receive training on complying with the Code on an annual basis as part of Adviser’s annual employee compliance review meeting to ensure that all employees fully understand their duties and obligations and how to comply with the Policy’s procedures. Copies of Adviser’s Code A copy of Adviser’s Code is available upon request. For a copy, please contact Adviser at 954383-1919. Participation or Interest in Client Transactions and Associated Conflicts of Interest Adviser may recommend or invest in securities, including funds, issued or managed by its affiliates (or where the affiliate acts as general partner or managing member) in which its affiliates have a material financial interest. Adviser has polices that require personnel who develop advice and recommendations for clients to render only disinterested and impartial advice to clients and to comply with other fiduciary obligations, including having an adequate basis in fact for all recommendations and an obligation to recommend only investments that are suitable for the particular client. The potential conflicts of interest involved in any such transactions are generally governed by Adviser’s Code. Pursuant to the stipulations of the Code, Adviser or a related person may buy or sell for itself securities that it also recommends to clients. The potential conflicts of interest involved in such transactions are governed by the Code, which establishes sanctions if its requirements are violated and requires that Adviser and employees place the interests of Adviser’s clients above their own. Investments in Securities by Adviser and its Personnel Adviser’s personnel or a related person of Adviser may invest in the same or similar securities and investments as those recommended to or entered into on behalf of Adviser’s clients. The results of the investment activities of Adviser’s personnel or related persons for their accounts may differ

from the results achieved by or for client accounts managed by Adviser. The conflicts raised by these circumstances are discussed below. Adviser may recommend or effect the purchase or sale of securities in which its related persons or an affiliate, directly or indirectly, has a position or interest, or of which related or affiliated person buys or sells for itself. Such transactions may also include trading in securities in a manner inconsistent with the advice given to Adviser’s clients. Activities and transactions for client accounts may be impaired or effected at prices or terms that may be less favorable than would otherwise have been the case had Adviser or related persons not pursued a particular course of action with respect to the issuer of the securities. In addition, in certain instances Adviser’s personnel may obtain information about the issuer that could limit the ability of such personnel to buy or sell securities of the issuer on behalf of client accounts. Transactions undertaken by Adviser’s clients may also adversely impact one or more client accounts. Other clients of the Adviser may have, as a result of receiving reports or otherwise, access to information regarding Adviser’s transactions or views that may affect their transactions outside of accounts controlled by Adviser, and such transactions may negatively impact other clients’ accounts. A client’s account may also be adversely affected by cash flows and market movements arising from purchase and sale transactions by, as well as increases of capital in and withdrawals of capital from, other clients’ accounts. These effects can be more pronounced in less liquid markets. Adviser has adopted a Code of Ethics. Such Code of Ethics together with Advisers policies and procedures restrict the ability of certain officers and employees of Adviser from engaging in securities transactions in any securities that its clients have purchased, sold or considered for purchase or sale, for an appropriate “black out” period. Other restrictions and reporting requirements are included in Advisers procedures and Code of Ethics minimize or eliminate conflicts of interest. Trading Alongside by Adviser and its Personnel Client accounts managed by Adviser may trade in the same or similar securities at or about the same time as accounts managed or advised by affiliates of the Adviser. Investments by Adviser’s affiliates and their clients may have the effect of diluting or otherwise disadvantaging the values, prices or investment strategies of a client’s account, particularly in small capitalization, emerging market or less liquid strategies. This may occur when portfolio decisions regarding a client’s account are based on research or other information that is also used to support portfolio decisions for Adviser’s affiliates. If a portfolio decision or strategy for Adviser’s affiliates’ accounts or the accounts of clients of affiliates is implemented ahead of, or contemporaneously with, similar portfolio decisions or strategies for Adviser’s client’s account, market impact, liquidity constraints, or other factors could result in the account receiving less favorable trading results and the costs of implementing such portfolio decisions or strategies could be increased.

Errors Errors may occur from time to time in transactions for client accounts. The Adviser will typically correct any such errors that are the fault of the Adviser at no cost to the client, other than costs that the Adviser deems immaterial. To the extent that the subsequent sale of such securities generates a profit to the Adviser, the Adviser may retain such profits, and may, but is not required to, use such profits to offset errors in the future or pay other client-related expenses. The Adviser will not be responsible for any errors that occur that are not the fault of the Adviser. Privacy Policy Adviser considers your privacy our utmost concern. Adviser does not share any information of clients with nonaffiliated third parties, except such information may be disclosed as necessary to process a transaction an investor has requested, to the extent the investor specifically authorized the disclosure, to service providers or joint marketers who agree to limit their use of such information, and to the extent required or specifically permitted by law or reasonably necessary to prevent fraud, unauthorized transactions or liability. When Adviser discloses non-public personal information of clients to a non-affiliated third party that provides services to Adviser or engages in joint marketing, Adviser shall:

notify investors of the possibility of such disclosure; and enter into a contractual agreement with the third party that prohibits the third party from disclosing or using the investors’ information other than to carry out the purposes for which the information was disclosed to the third party.

In particular, Adviser may enter, in compliance with the above conditions, into an agreement with a non- affiliated third party to store the records of Adviser clients and investors including electronic and e-mail records. For more information about Adviser’s privacy policies or to request a brochure describing Adviser’s privacy policies contact Adviser at 954-383-1919. Other Conflicts of Interest The Investment Fund(s) will be subject to a number of actual and potential conflicts of interest involving the Adviser and one (1) or more of its affiliates, including Zest Capital Peru SAC (“Zest Peru”). However, the Investment Manager will, at all times, have regard in such event to its obligations to the Investment Fund and will endeavor to ensure that such conflicts are resolved fairly. The Investment Manager, the Administrator, auditors and brokers from time to time act in a similar capacity to, or otherwise be involved in, other funds or investment schemes, some of which may have similar investment objectives to those of the Investment Fund. Thus, each may be subject to conflicting demands in respect of allocating management time, services and other functions

between the activities each has undertaken with respect to the Fund and the activities each has undertaken or will undertake with respect to other investors or other accounts. It is therefore possible that any of them may, in the course of their respective businesses, have potential conflicts of interest with the Investment Fund and respective affiliated entities. In addition to managing the Investment Fund, the Adviser and its affiliates may engage in (i) investment and trading activities for their own accounts and/or for the accounts of third parties and (ii) other business activities not involving the Investment Fund, including, without limitation, the management of accounts for other investment advisory clients and possibly the organization and management of other funds, some of which may employ strategies that are the same or similar to those employed by the Investment Fund. As a result of their other business activities, the Adviser and its affiliates may have conflicts of interest in allocating management time, services and functions among the Investment Fund and such other business ventures. None of the Adviser or its affiliates is obligated to devote any specific amount of time to the affairs of the Investment Fund. The Adviser and its affiliates may expand the range of services that they provide over time and will not be restricted in the scope of their businesses or in the performance of any such services (whether now offered or undertaken in the future) even if such activities could give rise to conflicts of interest, and whether or not such conflicts are described herein. Clients are encouraged to review the Investment Fund documents and discuss directly with the Adviser or Zest Peru pertaining to a full and extensive list of all potential conflicts of interest.

Relevant factors used in evaluating “execution quality” include historical net prices, the execution, clearance, and settlement and error correction capabilities of the broker or dealer generally and in connection with securities of the type and in the amounts to be bought or sold; the broker’s or dealer’s willingness to commit capital; reliability and financial stability; the size of the transaction; availability of securities to borrow for short sales; and the market for the security. In addition to a broker-dealer’s ability to provide “execution quality,” the Adviser’s selection criteria may include the value of various services or products provided by the broker-dealer. For example, Zest may acquire: research reports on or other information about particular companies, sectors or industries; economic surveys and analyses; recommendations as to specific securities; electronic market quotations; non-mass-marketed financial publications; portfolio evaluation services; performance measurement services; market, economic and financial studies and

forecasts; data on pricing and availability of securities; certain financial database software and services; and other products or services that may enhance its investment decision making. On occasion, clients might require to have their account held in the custody and trades executed at a broker-dealer of their choice, which may or may not cost more to the client. Clients may pay commissions higher than those obtainable from other brokers for the same services rendered by other broker-dealer recommended to the client by Zest. Zest may aggregate sale and purchase orders of securities held by a client with similar orders being made simultaneously for other client accounts or entities if, in the reasonable judgment of Zest, such aggregation is reasonably likely to result in an overall economic benefit to clients based on an evaluation that the clients will benefit from relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In general, the average price of all securities purchased or sold in such transactions will be determined, and a client will be charged or credited, as the case may be, the average transaction price. Although, in any given case, this practice could have a detrimental or beneficial effect upon the price or value of the security for any client account, Zest believes that on an overall basis such practice is beneficial to clients. While Zest believes this is beneficial and fair on an overall basis with respect to all Zest accounts, there can be no assurance that on a trade-by-trade or overall basis that any particular client will not be treated more or less favorably than another client. It is the Adviser’s policy not to enter into soft dollar arrangements and the Adviser has no formal soft dollar arrangements. The Adviser does not consider, in selecting or recommending brokerdealers, whether it or a related person receives client referrals from such broker-dealer. Brokerage for Client Referrals Adviser does not direct brokerage to particular brokers in consideration for client referrals.

Zest does not maintain physical custody of its clients’ funds. Clients receive monthly or quarterly statements from the broker- dealer, bank or other qualified custodian that holds and maintains the client’s investment assets.