Description of Services and Fees Alexander Beard (USA) Inc. (hereinafter “AB USA”) is a registered investment adviser based in Cheshire, United Kingdom. We are a corporation, formed under the laws of the State of Delaware. We have been providing investment advisory services since 2004. The Alexander Beard Group of Companies, LTD, is the Principal Owner of AB USA. Paul Douglas Beard is the principal owner of the Alexander Beard Group of Companies, LTD. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Such persons are properly registered as investment adviser representatives in applicable jurisdictions where required. Our firm’s services are described below: Pension Consulting Services for UK Pension Account Holders We provide ongoing investment advice to United Kingdom (UK) citizens currently residing in the US who have existing UK based pension plans. Our service includes a review of each client's existing UK pension assets and recommendations with regard to a potential transfer of such pension assets to a new pension provider (Pension Transfer Report), and ongoing discretionary on non-discretionary investment management services. Our ongoing investment management services are described in detail in the Portfolio Management Services section below. Pension Transfer Reports are provided to clients in conjunction with Alexander Beard Global Services Limited, our firm’s UK affiliate. Additional information about our affiliated firms in provided in Item 10 below. At the start of services, we ask clients to provide us with an authorization form that allows us to request a statement of benefit from the client's existing UK pension plan administrators or trustees. Once obtained, we will generally deliver to the client an assessment of the client's UK pension assets based upon the statement of benefits received. The firm's advice extends to those pension plans available to UK expatriates for their existing UK pension assets. These can include Self-Invested Personal Pensions ("SIPP") and/or other applicable plans. By assisting with the transfer of pension assets from existing UK pension plans to a new plan, the firm aims to provide clients with greater control of their UK pension assets via a more flexible pension plan with wider investment- related options. As part of our service, we also notify clients of changes in UK pension legislation that could impact their pension assets. All pension assets are held by regulated pension trustees that are properly authorized to render such services by the relevant financial services regulator where the pension plan is held and subject to the terms and conditions of a separate agreement between the client and the pension trustee. Additional information about the pension trustee(s) are provided in Item 12 below. Portfolio Management Services Our firm offers discretionary, and in limited cases, non-discretionary portfolio management services to our clients. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Non-discretionary portfolio management service means that we must obtain your approval prior to placing any transactions in your account. Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and help you decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. AB USA does not recommend one particular type of security over other types of securities, but we do provide advice on various types of securities, such as exchange listed equities, over the counter equities, foreign issues, American depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities and/or commodities, private equity instruments, return enhanced notes, and interests in partnership investing in real estate. Additionally, will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. Recommendation of Sub Advisors As part of our overall portfolio management strategy, we may use one or more sub-advisors to manage all or a portion of your account. All sub-advisors recommended by our firm must either be registered as investment advisors or exempt from registration requirements. In the case of non-US sub-advisors, such as UK based Discretionary Fund Managers, AB USA will only recommend firms that are properly registered with their respective regulators, such as the UK Financial Conduct Authority. These sub-advisors may specialize in traditional portfolio management, private equity investments, private credit markets, hedge funds or other types of alternative investments. Factors that we take into consideration when making our recommendations include, but are not limited to, the following: the sub-advisor’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the sub-advisor’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. We retain the right to hire and fire sub-advisors and the right to reallocate client assets to other model portfolios at the same sub-advisor. Consulting Services for US Qualified Retirement Plans AB USA provides several retirement plan consulting related

services. While the primary clients for these services will be US based qualified retirement plans, AB USA will also offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Retirement plan consulting services are comprised of the following components. Clients may choose to use any or all of the following services:
• Assistance with the development and/or review and revision of an Investment Policy Statement (“IPS”) as requested.
• Provision of recommendations on appropriate investments that have a level of risk commensurate with the anticipated return, seeing to it that risk is minimized through diversification, and ensuring that the Plan has sufficient liquidity to meet its cash flow requirements.
• Assistance with the selection of a qualified default investment alternative (“QDIA”) and determination of the continuing suitability of a QDIA.
• Assistance with on-going monitoring and make recommendations regarding the replacement of the Plan’s investments and investment providers.
• Assistance with the monitoring of investment options by reviewing quarterly reports that document investment performance, consistency of fund management, and conformance to any guidelines set forth in the IPS and will notify you with any recommendations.
• Analysis of the fees and expenses associated with the investments and the service providers and recommend changes when warranted. These services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Security Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). Other retirement plan consulting services are available on request. All of our retirement plan consulting services, whether general or customized, will be outlined in an Agreement that shows the services that will be provided and the fees that will be charged for those services. AB USA is registered as an investment advisor and represents that it is not subject to any disqualification as set forth in Section 411 under ERISA. To the extent AB USA performs Fiduciary Services, AB USA is acting as a fiduciary of the Plan as defined in Section 3(21) or Section 3(38) under ERISA. AB USA may also perform the following non-Fiduciary services:
• Assistance with the education of the participants in the Plan about general investment principles. Client understands that AB USA’ assistance in participant investment education shall be consistent with and within the scope of the definition of investment education of Department of Labor Interpretive Bulletin 96-1. As such, AB USA is not providing fiduciary advice (as defined in ERISA) to the participants. AB USA will not provide individualized investment advice concerning the prudence of any investment or combination of investment for a particular participant or beneficiary under the Plan.
• Assistance with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. AB USA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between AB USA and client. General Consulting Services AB USA provides general consulting services that focus on the specific needs and concerns of the client. Advisory consulting services may include giving advice on investment and investment related matters. These services include the identification of financial goals and objectives, collection and assessment of all relevant data, identification of financial problems and formulation of solutions, and the preparation of a financial plan in the form of specific written recommendations. The services we provide will typically focus on one or more of the following areas: Cash Flow Analysis: Cash Flow Analysis involves the assessment of present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk; and, to coordinate and organize records and estate information. Retirement Planning: Retirement Planning is a process of determining retirement income goals and the actions and decisions necessary to achieve those goals. Retirement planning includes identifying sources of income, estimating expenses, implementing a savings program and managing assets. Future cash flows are estimated to determine if the retirement income goal will be achieved. Investment Planning: The goal of investment planning is to determine the investment mix and policy, matching investments to objectives, asset allocation for individuals and institutions, and balancing risk against performance. The process realizes strengths, weaknesses, opportunities and risks in the choice of debt vs. equity, domestic vs. international, growth vs. safety, and many other tradeoffs encountered in the attempt to maximize return at a given risk. Our advice is based on your financial situation and the financial information you provide to our firm. If your financial situation, goals, objectives, or needs change, you must notify us promptly. The consulting engagement ends at the time the requested services are completed. The client is exclusively responsible for implementing any accepted recommendations. Clients should note that AB USA does not monitor the client’s account once the recommendation has been provided. Note: Information related to tax or legal matters that is provided as part of overall portfolio management service is for informative purposes only. Clients are instructed to contact their tax professionals or attorneys for tax or legal advice. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of December 31, 2023, AB USA manages approximately $43,642,645 on a discretionary basis and $0 on a nondiscretionary basis.