A. Vega Capital Group LLC (“Vega Capital Group” or the “Firm”) is a California Limited Liability Company, in business since June 2001. The firm was registered as an Investment Adviser with the California Department of Business Oversight. Since August 30, 2017, Vega Capital Group has been registered with the Securities and Exchange Commission as it currently has assets under management of at least $100,000,000. The Firm’s single member and Chief Compliance Officer is Mr. Leonid Pinski. B. Based on the client's individual needs, Vega Capital Group provides investment management services to its clients. Such investment management services represent 100% of Vega Capital Group’s business and income. A client, upon engaging Vega Capital Group as its discretionary investment manager, must select the combination of Vega Capital Group's styles of management for his or her portfolio. The client may change the selection upon written request to Vega Capital Group. The Firm will manage the client's portfolio in accordance with the client's individual investment objectives, financial situation, risk tolerance, and any reasonable investment guidelines established by the client. THE FOLLOWING DESCRIBES EACH OF THE INVESTMENT STYLES UTILIZED BY VEGA CAPITAL GROUP IN MANAGING INVESTMENT ADVISORY ACCOUNTS. THIS INFORMATION SHOULD BE REVIEWED BY A CLIENT BEFORE ENGAGING VEGA CAPITAL GROUP TO ACT AS AN INVESTMENT ADVISER. INVESTMENT ADVISORY ACCOUNT CLASSIFICATIONS AND FEES: 1) Vega Safety (Fixed Income accounts): Primary investment objectives: Capital Preservation, Income. Quarterly Management Fee: 0.15% of assets under management, discounts are given for accounts with special circumstances. Typical Investment Horizon: Defined by client. Eligibility: General. Fixed Income accounts are tailored to meet individual income needs of the client. Depending on the particular client’s situation, Vega Capital Group may purchase income-generating securities, such as government, agency, municipal and corporate bonds, convertible bonds, preferred stock, short-term notes, closed-end funds and similar instruments. 2) Vega Equity ETF: Primary investment objective: Capital Appreciation Quarterly Management Fee: 0.5% of assets under management, discounts are given for accounts with special circumstances. Typical Investment Horizon: 3-10 Years. Eligibility: General. This type of account is for a sophisticated investor who understands and can tolerate risks associated with actively managed portfolio of varied securities. Vega Capital Group will attempt to outperform the market indices by primarily utilizing US and/or international exchange traded funds (ETFs) and protective options. 3) Vega Equity Star: Primary investment objective: Capital Appreciation Quarterly Management Fee: 0.375% of assets under management, discounts are given for accounts with special circumstances. Performance Fee (charged annually in arrears): 10% of the net gain. Net gain is defined as the sum of all realized and unrealized gains and losses for the year. The concept of “high water mark” is utilized. “High water mark” is defined as the highest peak in value that an investment account has reached. Typical Investment Horizon:

3-10 Years. Eligibility: Qualified Clients only. SEC defines a “qualified client” as a person or company who immediately after entering into the Investment Advisory Contract has at least $1,100,000 under management or has a total net worth of more than $2,200,000. The strategy involves taking a combination of equities and options and other derivative positions to achieve aggressive growth of investments while attempting to control the risk. Trades are based on the fundamental and quantitative research and the positions are managed dynamically using technical analysis. 4) Vega Aggressive Growth and Enhanced Yield: Primary investment objective: Capital Appreciation and Income Quarterly Management Fee: 0.375% of assets under management, discounts are given for accounts with special circumstances. Performance Fee (charged annually in arrears): 10% of the net gain. Net gain is defined as the sum of all realized and unrealized gains and losses for the year. The concept of “high water mark” is utilized. “High water mark” is defined as the highest peak in value that an investment account has reached. Typical Investment Horizon: 5-15 Years. Eligibility: Qualified Clients only. SEC defines a “qualified client” as a person or company who immediately after entering into the Investment Advisory Contract has at least $1,100,000 under management or has a total net worth of more than $2,200,000. This strategy is suitable for qualified clients who would like to achieve both long- term capital appreciation and current income. The strategy involves taking a combination of equities, options and fixed income securities (US and International). Both equity and fixed income parts of the portfolio are tailored to meet the needs of the client. The assets are dynamically allocated between equity and fixed income parts of the portfolio. 5) Vega Balanced: Primary investment objective: Capital Appreciation and Income. Quarterly Management Fee: 0.25% of assets under management, discounts are given for accounts with special circumstances. Typical Investment Horizon: 3-10 Years. Eligibility: General. The strategy involves taking a combination of equities and equity-like securities and fixed income securities similar to those in our Vega Safety Program. The assets are dynamically allocated between equities and fixed-income instruments. Trades are based on the fundamental and quantitative research and the positions are managed dynamically using technical analysis. C. The Firm’s investment advice for individually managed accounts is based on a number of factors, which may include the client's investment objectives, risk tolerances, asset class preferences, time horizons, or liquidity needs. As stated above, each client’s account is individually managed according to one the investment programs selected by the client. Clients may impose reasonable restrictions on the Firm’s discretion to invest in certain securities or types of securities if a client provides clear, written directions to that effect. D. Vega Capital Group does not participate in wrap fee programs. E. As of December 31, 2023, Vega Capital Group managed $128 million of client assets on discretionary basis.