Firm Description Finaport was founded in 2007 to provide investment management and advisory services to persons and entities who are residents of the United States and United States citizens located overseas (U.S. Persons”). Located in Switzerland, the Firm has been established to afford U.S. Persons an opportunity to avail themselves of investment management and advisory services that focus on a broad range of international markets and multi-currency alternatives, in addition to U.S. dollar-based investments in the U.S. markets. Finaport also serves US taxpayers or dual citizens living outside the US and in certain cases may work with clients who are not resident in the US or US taxpayers. Principal Owners Finaport is 100% owned by Finaport Holding Ltd, which is owned by Mr Hellmut Schuemperli (50%) and Mr Alexei Borissov (50%). Services Finaport provides wealth management solutions to high-net-worth individual clients as well as companies and it offers both discretionary asset management (investment management mandates) and non-discretionary investment advisory services (investment advisory mandates). Each client’s assets are managed in a separate account (an “account”) maintained at a third-party financial institution. Finaport’s client portfolios are diversified across a variety of asset classes, including cash, US dollar and non-US dollar currencies, defensive strategies in marketable securities, growth strategies in marketable securities, and, in certain cases, private investments. Accounts may include, without limitation: equity securities, fixed income securities, limited partnership interests, mutual funds, exchange traded funds, hedge funds, options, structured product investments, digital assets and other alternative investments consistent with a client’s suitability, his or her overall investment strategy, and his or her risk tolerance. Generally, client investments are concentrated in non-US securities consistent with most clients’ objective of obtaining jurisdictional diversification from the US. Whilst generally Finaport makes investments with a longer time horizon, Finaport may recommend changes to allocations in an attempt to take advantage of conditions in the current economic environment whilst being sensitive to transaction costs and taxes, as applicable. Such allocation changes may involve short-term underweight or overweight positions to various asset classes designed to capitalize on current economic conditions over the short-term. Finaport’s advice is limited to the types of securities and transactions as set forth in Item 8. Finaport does not render any legal or tax advice. Discretionary Asset Management Services Finaport offers discretionary asset management services whereby Finaport has the authority to supervise and direct the investments of and for each client’s account without prior consultation with the client. Finaport determines the securities that are bought and

sold for the client’s account and the total amount of the purchases and sales. Finaport’s authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the investment management agreement entered into between Finaport and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Finaport seeks to obtain a rate of return consistent with each client’s objectives, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Generally, Finaport manages each client’s portfolio in line with model portfolios constructed by the 4 investment committee of the firm. However, these model portfolios serve only as a general guide and not every client’s portfolio will replicate the model portfolio as a result in differences in client risk tolerance, tax ramification, client specifications, liquidity and timing. Finaport currently offers Its clients the following Investment Strategies that do not correlate with each other.
• Investment Committee Strategy (with division by risk appetite: conservative, balanced and growth)
• FPSDM (Finaport Systematic Discretionary Mandate) (with division by risk appetite: conservative, balanced and growth)
• The ALL-IN Strategy
• Tailored client services
• Cryptocurrency Strategy Client Accounts within these strategies are broadly manage, d in a similar manner. However, differences in each portfolio may occur due to client-specific investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations, reference currency, legal restrictions and overall suitability. Non-discretionary Asset Management Services For clients who desire a non-discretionary investment advisory service, Finaport offers investment advice similar to its discretionary asset management service in a non- discretionary mandate whereby prior consultation and client approval is required before Finaport purchases or sells any security. Finaport works with its non-discretionary clients to define their investment objectives and consults with each client on a regular basis with investment suggestions in line with the defined objectives. If explicitly required by a non-discretionary client, Finaport may implement investment ideas which do not pertain to Finaport’s investment universe. Finaport will disclose to the client if an investment idea is not part of Finaport’s investment universe. Wrap Fee Programs Finaport does not participate in wrap fee programs. This means the custodian and Finaport will always invoice separately therefore the client has full transparency of the fees charged. Assets under Management Finaport managed approximately USD 90.8 million on a discretionary basis and approximately USD 56.1 million on a non- discretionary basis, for a total of approximately USD 146.9 million as of December 31, 2023.