A. Description of the Advisory Firm Gramercy Strategic Capital LLC (hereinafter “GSC”) is a Limited Liability Company organized in the State of New York. The firm was formed in June 2021, and the principal owners are Keith Cho and Yoon Hwang. B. Types of Advisory Services Portfolio Management Services GSC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GSC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring GSC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GSC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GSC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GSC’s economic, investment or other financial interests. To meet its fiduciary obligations, GSC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GSC’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is GSC’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. GSC may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, GSC will always ensure those other advisers are properly licensed or registered as an investment adviser. GSC conducts due diligence on any third-party investment adviser, which may involve

one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. GSC then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of GSC's client. GSC may also allocate among one or more private equity funds or private equity fund advisers. GSC will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Services Limited to Specific Types of Investments GSC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. GSC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions GSC offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GSC from properly servicing the client account, or if the restrictions would require GSC to deviate from its standard suite of services, GSC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. GSC does not participate in any wrap fee programs. E. Assets Under Management GSC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 50,553,200.00 $ 94,392,449.00 December 2023