A. FIRM DESCRIPTION Asset Risk Consultants (UK) Limited (“ARCUK” or the “Firm”) was established in 2014 as a private limited company under the Companies Act 2006 of England and Wales. ARCUK is a wholly owned and UK regulated subsidiary of ARC Group Limited (“ARC Group”). ARC Group has some 73 staff and was established in 1995 and provides investment consulting, manager research and performance reporting to private clients, charities, family offices, professional trustees and their advisers. Through its investment consultancy arm, ARC Group assists families and large charities with their investment matters by providing an independent view and analysis which enables clients to understand what each investment manager is doing for them. The Firm provides clients with reassurance and peace of mind regarding their personal wealth in an industry which is full of jargon. ARC Group has a global client base and is 100% owned by senior management. No individual has a direct interest in over 15% of the ordinary voting shares, although by means of his co-trusteeship of the employee benefit trust Graham Harrison could exercise control over 30% of the ordinary voting shares. Graham Harrison was the founder of ARC and principal shareholder until 2014. B. TYPES OF ADVISORY SERVICES ARCUK investment consulting services assist clients with the selection and monitoring of the performance of discretionary investment managers; setting up the overall strategic asset allocation and risk-profile and manager specific objectives. In certain cases we also assist clients with selection of collective investment vehicles as satellite holdings to complement the core of discretionary managers. The methodology for assessing the success or otherwise is the same regardless of whether we are looking at a discretionary portfolio manager or a fund manager. In our investment consultancy service ARCUK provides advice and written reports to our clients and sits alongside them at meetings with their investment managers. We seek to de-mystify the investment management business and allow clients to see what progress they are making both against their own objectives, the industry average and other available options. We either operate to review existing wealth structures or help clients set up and transition to new arrangements, as necessary. That may involve manager selection and on-going monitoring. Often we operate alongside other advisors such as lawyers, accountants or trustees, to ensure that the client and Family Office receive appropriate input across the board. ARC has expertise in geopolitical and operational risk management for international investors who manage risks and investment opportunities across a number of jurisdictions. Typically, our on-going investment consulting offering includes the following:
• Monthly (or quarterly) performance reporting on each portfolio and the “Aggregate Portfolio”, with any potential issues being identified
• Monthly (or quarterly) review of the tactical asset allocation of each manager and the portfolio as a whole
• Monthly insight into the global macro-economic events and financial market performance
• Semi-annual comprehensive written reports on sub-portfolio and Aggregate Portfolio structure and performance
• Regular meetings or conference calls to discuss findings and ensure the investment strategy remains appropriate
• Regular review of industry asset allocation trends.
• Annual review of the investment policy statement and risk profile in the light of changing client circumstances
• Annual report setting out 10-year asset class performance forecasts and implications for the investment policy statement
• Ad hoc manager selection

and general investment advice ARC Group is considered by many to be among the leading independent, private client discretionary investment consulting company in the British Isles. As a group we focus on the following key areas: ➢ Investment Consulting – forward looking investment advice designed to maximize the risk-adjusted returns being generated for our clients with investment managers; unique use of risk and style profiling questionnaires, investment audit on performance and structure of client portfolios as well as ongoing investment advice. Fee is typically 10 basis points pa of the assets under consulting but is designed bespoke to the clients’ needs. ➢ Research – more data held on discretionary managers than anywhere else ranging from due diligence through performance data to investment style, much of which is made freely available. Specific advice is available in relation to potential manager identification, appointment, fee negotiation and portfolio implementation is also available. Fee based on time charged. ➢ Reporting – multi-dimensional assessment of portfolios historical investment performance to meet specific client or fiduciary requirements for portfolios of all size and complexity, assisting and demonstrating fiduciary independent performance oversight. Fees circa US$1,000 per annum ongoing per portfolio. Our investment monitoring services complement our research and investment consulting services and has assisted in Asset Risk Consultants becoming a leading independent private client investment consulting practice. Our goal is to ensure you receive the best experience possible from the investment management industry. ARCUK does not undertake active portfolio management or execute trades on client portfolios. However, any restrictions that a client may wish to set are incorporated in investment guidelines to be issued to the appointed discretionary portfolio managers. The services to be provided in the US are those detailed above as services provided by ARCUK. In the wider ARC Group active portfolio management occasionally occurs, in which case such restrictions are taken into consideration when selecting potential mutual funds that may be held as ‘satellite’ holdings by the client. C. TAILORED RELATIONSHIPS ARC tailors its services to the needs of every client and therefore can provide solutions to client requirements ranging from portfolio audits, manager review, manager selection, through to the on-going monitoring of discretionary investment managers. There is a typical process to reviewing and monitoring a client’s portfolio but the outcome of each review will differ as will the appropriate solutions for the client. A risk profile questionnaire coupled with an assessment of the client’s circumstances and discussion of their aspirations, risk appetite and concerns lead to the crafting of an appropriate solution. D. WRAP FEE PROGRAMS Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks, and other financial institutions and affiliated and unaffiliated investment advisers through which clients of such firms receive discretionary investment advisory, execution, clearing, and custodial services in a “bundled” form. In exchange for these “bundled” services, clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. Due to the nature of its advisory services, ARCUK does not participate in and is not a sponsor of wrap fee programs. E. ASSETS UNDER MANAGEMENT As of June 30, 2023, ARCUK had assets under consulting and assets under advisement as follows: Discretionary Managed Assets $0 Non-Discretionary Managed Assets $0 Assets Under Advisement (not managed) $1024 million As a whole, the ARC Group has over USD 17 billion of assets under consulting.