A. Systematic Alpha Investments, LLC’s (“SAI”) is a limited liability company formed on May 30, 2018, in the State of New Jersey. SAI became registered as an investment adviser in July 2018. SAI is wholly owned by Stephen Edwin Evans. B. As discussed below, SAI offers investment management services to high net worth clients. SAI does not provide financial planning services. INVESTMENT MANAGEMENT SERVICES Clients can engage SAI to provide discretionary investment management services. SAI manages client portfolios using quantitative and algorithmic methods with interaction and oversight from SAI’s portfolio manager. In any event, the portfolio manager may override the quantitative and algorithmic processes. SAI generally manages client accounts using one or more proprietary investment strategies. SAI generally will purchase individual securities among global equities, but may also use options, exchange-traded funds (“ETFs”) and fixed income securities. In the future, SAI may use other securities and may engage the services of other independent investment managers. SAI reserves the right to select from any securities in managing client accounts and is not limited by the preceding description of the types of securities it may purchase in client accounts. In performing its services, SAI shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on information in its possession. Each client is responsible for promptly notifying SAI if there is ever any change in their

financial situation or investment objectives so that SAI can review, and if necessary, revise its previous recommendations or services. SAI does not provide financial planning and related consulting services, such as estate, tax and insurance planning. SAI and its agents do not serve as attorneys, accountants, or insurance agents. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents.). You are under no obligation to engage the services of any recommended professional. The client is free to accept or reject any recommendation that we make. If the client engages any recommended professional, and a dispute arises thereafter, the client agrees to seek recourse exclusively from and against the engaged professional. C. SAI shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client their particular investment objectives. SAI will manage each client’s investment assets consistent with their designated investment objectives. Clients may, at any time, impose reasonable restrictions, in writing, on SAI’s services. SAI retains discretion in determining whether any restriction request is reasonable. D. SAI does not participate in a wrap fee program. E. As of December 31, 2023, SAI managed approximately $2,400,000,000 in assets on a discretionary basis.