A. Description of the Advisory Firm Kinetic Investment Management, Inc. (hereinafter “Kinetic Investment Management”) is a corporation organized in the State of California. The firm was formed in January 2016, and the principal owner is Ali Hashemian. B. Types of Advisory Services Portfolio Management Services Kinetic Investment Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. We create an Investment Policy Statement for you which outlines your current situation (income and risk tolerance levels) and then we construct a plan to aid in the selection of a portfolio that matches your specific situation. Portfolio management services include but are not limited to the following:
• Investment strategy • Asset selection
• Personal investment policy • Risk tolerance
• Asset allocation • Regular portfolio monitoring We evaluate your current investments with respect to your risk tolerance level and time horizon. We will request discretionary authority from you to select securities and execute transactions without permission from you prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement which is given to each client. We seek to provide investment decisions that are made in accordance with the fiduciary duties owed to our clients’ accounts and without consideration of our economic, investment, or other financial interests. To meet our fiduciary obligations, we attempt to avoid, among other things, investment or trading practices that systematically advantage or disadvantage individual client portfolios. Thus accordingly, our policy is to seek fair and equitable allocation of investment opportunities/transactions among our clients to avoid favoring one client over another. It is our policy to allocate investment opportunities and transactions we identify as being appropriate and prudent among our clients on a fair and equitable basis. We may direct our clients to third-party investment advisers. Before selecting other investment advisers for clients, we will verify that all recommended advisers are properly licensed, notice filed or exempt in the states where we are recommending the adviser. Sub-Advisory Investment Management Services Kinetic Investment Management provides sub-advisory investment management services to unaffiliated registered investment advisers, RIA firms. Unaffiliated RIA firms may access third-party investment advisers through us for investment management of some or all their clients’ assets. We provide back-office services including but not limited to processing investment management requests and processing custodial relationship applications for the RIA firms in return for fees deducted from the advisor fee. The advisor fee is itemized on the third-party adviser’s platform on the statement of investment selection. Kinetic Investment Management is shown as the adviser/sub-adviser. Financial Planning Financial plans may include but are not limited to investment planning, tax planning, retirement planning, insurance planning, business consulting, and estate planning. Investment planning includes but is not limited to risk management, portfolio performance, asset allocation, and diversification. Tax planning includes but is not limited to tax forecasting, tax efficiency, and tax-advantaged strategies. Retirement planning includes but is not limited to income/distribution maximization, budgeting, inflation, and taxes. Insurance planning includes but is not limited to life insurance, long-term care insurance, health insurance, car insurance, and homeowner’s insurance. Estate planning includes but is not limited to trust strategies, incorporation strategies, and charitable/gifting strategies. Financial planning services are offered to all our clients, and it is anticipated that each of these services will take approximately 2-4 hours of planning. The

final fee structure for these services is based on hourly rates and is documented in Exhibit II of the Financial Planning Agreement. Educational seminars/workshops Kinetic Investment Management may provide educational seminars/workshops/presentations for free to ongoing or prospective clients. These services include presentations to individuals or groups about various aspects of wealth management. These seminars/workshops/presentations will be offered on an ad hoc basis. We do not charge for these educational seminars/workshops/ presentations. Services Limited to Specific Types of Investments We generally limit our investment advice to equity investments, fixed income investments, exchange traded fund (ETF) investments, real estate investments, commodities investments, international investments, and mutual fund investments. We may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Kinetic Investment Management will tailor a program for each client. This will include an interview session to get to know your specific needs and requirements as well as a plan that will be executed by us on your behalf. We may use “model portfolios” together with a specific set of recommendations for you based on your personal restrictions, needs, and targets. In addition to risk tolerance, we will use other quantitative factors such as investment goals, time horizon, lifestyle needs, retirement plans, and legacy concerns. We will also look at your entire portfolio (even the portions not managed by us) to align your risk tolerance in aggregate. You may impose restrictions on investing in certain securities or types of securities in accordance with your values or beliefs. However, if the restrictions prevent us from properly servicing your account or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to terminate the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where you pay one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Kinetic Investment Management may recommend various third-party money managers that manage a wrap fee program. E. Assets Under Management As of December 31, 2023, Kinetic Investment Management had $343,579,081 in assets under management, of which $319,281,071 in assets under management we manage on a discretionary basis, and $24,298,010 in assets under management on a non-discretionary basis. Additionally, Kinetic Investment Management had $50,144,010 in assets under administration. While we provide administrative services, we are not currently providing continuous investment management services regarding these assets under administration. Consequently, we have total assets of $393,723,091.