The Firm Pioneer Administrative Services Limited (PASL) is a limited company established under the laws of Israel. It was established in June 1988 and is wholly owned by Pioneer International Limited, which in turn is wholly owned by the Indigo International Group Limited. PASL is an independent multi‐family office. Pioneer’s Private Wealth Management team provides investment advisory services for a select niche of high net worth families around the world. The service offers clients an integrated approach to their financial well‐being by addressing their needs holistically: we provide one point of contact to coordinate and integrate all family financial matters looking at the asset allocation as well as the role of estate and tax planning. We specialize in cross‐platform portfolios, being able to collate information from multiple bank accounts and coordinate unified reporting for all investments. A. Services PASL manages both discretionary and non‐discretionary accounts. For each client relationship, these services include, but are not limited to, asset allocation analysis, portfolio monitoring, consolidated reporting, and selection of securities and fund managers. It is important to understand that the consolidated statements we prepare may contain information and data about accounts for which we do not provide investment management services or advise the client. Thus, no inference should be drawn that we serve as the adviser on all securities and assets listed on the consolidated financial summaries. Managing accounts on a discretionary basis means that we manage securities accounts on behalf of clients without asking for the client’s permission for each transaction. Once we meet with a client and determine their investment objectives and risk tolerances, among other factors, and have drafted an appropriate investment policy statement, PASL chooses the securities that we believe are suited for the client’s portfolio and trade in the client’s account on their behalf. We also will manage accounts on a non‐discretionary basis. In other words, we monitor and review an account and make securities recommendations to the client, but it is up to the client to decide whether to accept or reject our recommendations.

If the client accepts our recommendations, we will place the trades with the custodian, who will settle those trades. In these cases, we can also monitor and report on these accounts to the client. From time to time, PASL may recommend using a sub‐advisor to provide certain portfolio management services for clients. Clients will choose a sub‐advisor based on their preference and then PASL will manage the investment mandate provided by PASL to that sub‐advisor on behalf of the client. PASL is responsible for modifying the investment mandate if necessary and has the authority to terminate the investment mandate with sub‐advisors. In the event that a new sub‐advisor is selected to manage a portion of the client’s assets, the client will be notified by PASL. PASL performs a due diligence review on each sub‐advisor it selects. Where a sub‐advisor is used, PASL remains responsible for determining suitability of the managed assets and for determining the investment strategies employed. PASL has the discretion to terminate the services of the sub‐advisor with thirty days’ advance notice in writing. Clients are free to select the financial institutions that custody their assets. PASL will recommend custodians to clients upon request; however, the Firm does not receive any compensation from these financial institutions for recommendations made. PASL blends its own portfolio management services with outsourced services in an effort to ensure that clients’ interests are best served and that the clients are diversified across asset managers. Investment Instruments: Generally, the Firm’s investment advice is confined to the following universe of securities and products:  Exchange listed securities  Securities traded over‐the‐counter  Securities issued by foreign issuers, including foreign sovereign debt instruments  Corporate debt securities, including commercial paper  U.S. government securities  Municipal Securities  Mutual funds (foreign and domestic)  Exchange‐traded funds  Structured products, including principal‐protected notes  Private equity funds  Hedge funds  Non‐registered real estate‐related funds B. Assets Under Management As of December 31, 2022, we were managing $1,317,383 of client assets on a discretionary basis.