A. Description of the Advisory Firm Zsenia Investments INC. (hereinafter “ZII”) is a Corporation organized in the State of Delaware. The firm was formed in April 2021, and the principal owner is LRG Venture Inc. Reaz Islam is the founder of Zsenia Investments Inc. B. Types of Advisory Services Robo-Advisory Portfolio Management Services ZII provides “robo-advisory” portfolio management services through an online interface. This entails the use of algorithm-based portfolio management advice, rather than in- person investment advice. All investment advice is generated and provided by an interactive website. These automated investment solutions are customized to each client and based on individual characteristics, such as the client’s age, risk tolerance, and current assets, among others. ZII’s investment advisory personnel oversee the algorithm but may not monitor each client’s account. Clients are encouraged to update their account/questionnaire with any change in their objectives, risk tolerance, or other pertinent information, as that information factors into the portfolio’s composition. ZII will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. ZII seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of ZII’s economic, investment or other financial interests. To meet its fiduciary obligations, ZII attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, ZII’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 ZII’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. Services Limited to Specific Types of Investments ZII generally limits its investment

advice to equities and ETFs, although ZII primarily recommends ETFs. ZII 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; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions ZII offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. ZII does not participate in any wrap fee programs. E. Assets Under Management ZII has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $10,867,556 $ 0.00 December 2023