General Aqua Advisors LLC (AQUA) is a limited liability company duly organized under the laws of the State of Florida on September 9, 2016 and registered with the U.S. Securities & Exchange Commission (“SEC”), CRD# 285399. AQUA ’s members are Milagros Varela (CRD# 6708707) and Jose Pedro Varela (CRD# 4163995). Milagros Varela is the Manager and Chief Compliance Officer of AQUA and Jose Pedro Varela is a Member of the LLC. From its main office in Miami, FL AQUA offers the following services to its advisory clients: Investment Advisory Services Adviser provides investment advisory services to its clients through various types of discretionary and non-discretionary accounts in accordance with each client’s investment objectives. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that is intended to fit within the client’s objectives, strategies and risk profile as described by each client. AQUA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AQUA creates an Investment Policy Statement for each client, which outlines the client’s current investment profile (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Policy Statement may include, but not limited to, the following: ■ Investment strategy ■ Asset allocation ■ Risk tolerance ■ Personal investment policy ■ Asset selection ■ Regular portfolio monitoring AQUA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in Item 8. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. P a g e | 5 As an investment adviser, AQUA provides portfolio management and administrative services to client accounts (the “Accounts”), including investigating, analyzing, structuring and negotiating potential investments, monitoring the performance of investments and advising the Accounts as to the disposition of investment opportunities. Aqua provides investment advisory services to its clients through the management of investment portfolios in accordance with the objectives, guidelines and risk profiles of individual clients. Clients provide such information to Aqua at or

before the time they enter into an advisory agreement with Adviser. AQUA offers several specialized programs, as follows: 1. Family Wealth Services As an investment adviser, AQUA provides portfolio management and administrative services to our clients, including investigating, analyzing, structuring and negotiating potential investments, monitoring the performance of investments and advising the clients as to the disposition of investment opportunities.
4. Portfolio Review & Consulting Services Aqua provides clients with advice and recommendations on cash flow analysis, cash management, portfolio trading, portfolio management selection, and other investment related topics. The firm may charge either a fixed fee or an hourly fee dependent upon the scope of the assignment.
Aqua Wealth Management S.A. (Uruguay), an affiliated investment advisory firm located in Uruguay and registered with the Central Bank of Uruguay maintains a Consulting Agreement with Aqua Advisors; pursuant to this agreement, Aqua Wealth Management assists Aqua Advisors with the supervision and surveillance of the portfolios, provides due diligence services for all Private Equity deals, provides asset allocation models, financial and markets analysis and participates in Aqua Advisors investment committee meetings.
Other Services Adviser provides investment advisory services to clients through the management of investment portfolios in accordance with the objectives, guidelines and risk profiles of the individual clients. Clients provides such information to Adviser at or before the time they enter into an advisory agreement with the Adviser. The Adviser may provide additional services to the clients. The scope of services and additional fees are negotiated individually with each client and incorporated into the Portfolio Management Agreement. Additional General Information Other professionals (e.g., trust companies, lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. Additionally, AQUA ’s client agreements may not be assigned without client consent. P a g e | 6 Investment Restrictions Adviser offers an array of services and clients can select among the services that the client and the Adviser feel are suited for the client. Clients may impose reasonable restrictions on the management of their accounts, including by restricting particular securities or types of investments. Clients should be aware that performance of restricted accounts may differ from performance of accounts without such impediments, possibly producing lower overall results. Assets Under Management AQUA had approximately $147,710,488 in assets under management as of December 31, 2023; $10,157,442 managed on a discretionary basis and $137,553,046 non-discretionary basis.