Sendero Wealth Management (“Sendero”) is a boutique, partner-led firm created to help families and select institutions focus on navigating wealth and the complexities surrounding wealth. We have an experienced investment team, having managed billions of dollars. Through real world experience, we have developed the expertise to deal with complex, multi-generational family needs, and we have incorporated institutional investment practices to create a disciplined and thoughtful approach to the potential challenges families face. Sendero’s partners bring decades of personal experience to each situation. Our goal is to create and sustain a repeatable, long-term plan for our clients that includes public and private investments, acquisition and disposition of business and personal assets, risk management, family office management, family foundation management, and multi-generational legacy training. Additionally, we have developed a dedicated program that focuses on women’s differentiated needs surrounding wealth. Founded in 2008, Sendero is a privately owned, partner-led firm headquartered in San Antonio, Texas. The ownership of Sendero Wealth Management is allocated between Sendero Partners (88.4%) and a passive, client investor (11.6%) of the firm. Sendero Partners is the parent company of Sendero Wealth Management, LLC and Sendero Securities, LLC, (“Sendero Securities”), a FINRA member broker-dealer. Sendero manages client portfolios on both a discretionary and non-discretionary basis as selected by the client in the Sendero Advisory Agreement. Sendero Guidance Process At Sendero, we identify the clients’ financial values and associated goals through a dynamic and collaborative process. The Sendero Guidance Process (“SGP”) is designed to discover what is important to our clients and includes in-depth conversations around goals and values, financial planning, and a comprehensive reporting of a client’s financial picture. The SGP assists our clients in the review, evaluation, and formulation of investment objectives and policies and helps them develop asset allocation strategies. These strategies are developed based on the information provided to Sendero in the Client Profile, in discussions with our client, and in the client’s Investment Policy Statement (“IPS”), as applicable. We assist our clients in the selection of a combination of investment strategies to manage all or a portion of their assets in a manner consistent with the client’s financial circumstances, investment objectives, risk tolerance, and any restrictions they wish to impose on the management of the assets. Sendero will only identify investment managers that are included in our advisory program (“Investment Managers”) pursuant to an agreement between Sendero and the Investment Manager (the “Sub-Adviser Agreement”), or strategies that are approved by Sendero’s Investment Committee. Investment Managers or strategies not included in our advisory program will be evaluated on a case-by-case basis. Clients can impose reasonable restrictions on the management of their accounts, such as restrictions on investing in certain securities or types of securities. Each client should note, however, that restrictions imposed by a client can adversely affect the composition and performance of the client’s investment P a g e | 5 portfolio. Each client should also note that each investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, the performance of client investment portfolios within the same investment objectives, goals, and/or risk tolerance will differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with those of other clients of Sendero. We provide continuous, regular, and ongoing monitoring and due diligence of strategies approved by the Investment Committee with which the assets have been invested, as well as ongoing and continuous recommendations regarding the retention or termination of such strategies, according to our client’s investment objectives. We provide ongoing performance reporting with respect to the assets, as well as other such reporting when mutually agreed upon by you and Sendero. Discretionary Management In its discretionary accounts, Sendero has investment discretion with respect to the agreed-upon investment allocation, client investment objectives and approved IPS ranges. Sendero has discretion to rebalance client portfolios based on the approved IPS ranges, to debit accounts for advisory and Third- Party Investment Manager fees, as agreed upon by the client, and to hire and terminate Third-Party Investment Managers. Sendero has the discretion to substitute Third-Party Investment Managers within the client-approved asset class. This discretion will be used in this manner exclusively and will not be utilized for any other purposes, such as changing client investment objectives. Should this discretion be utilized, Sendero will provide the client with the rationale behind and a description of any such change, upon request. Sendero will only have investment discretion on assets included in the Sub-Adviser Agreement or strategies that are approved by Sendero’s Investment Committee. The client must authorize the use of any strategy other than mutual funds, ETFs, or strategy(ies) where Sendero has a Sub-Adviser Agreement. Sendero cannot retain, on the client’s behalf, any Third-Party Investment Manager(s) with whom Sendero does not have a Sub-Adviser Agreement. Sendero does not have discretion to move funds without the client’s written consent other than to same-name accounts within the same Custodian. If a client chooses to use a Third-Party Investment Manager or strategies that are not Sendero-approved, that client will not receive the full range of advisory services described in this brochure with respect to the non-approved Third-Party Investment Manager or strategies. Sendero is not responsible for reviewing Third-Party Investment Managers or strategies that are not approved by its Investment Committee or for communicating any information regarding those Third-Party Investment Managers or strategies to any client. Clients, unless otherwise noted in the client agreement, will pay the full Advisory Fee to Sendero for assets invested with Third-Party Investment Managers not approved by the Sendero Investment Committee, even though a client does not receive from Sendero the full range of services and due diligence that the client would receive with respect to Sendero approved Third-Party Investment Managers or strategies. Non-Discretionary Management In its non-discretionary accounts, Sendero does not have investment discretion for any of the assets. It is understood that the client is relying on Sendero for general investment advice and the client is under no obligation to act on any investment advice provided by Sendero. Sendero is given the ability to debit client accounts for advisory and Third-Party Investment Manager fees. Sendero does not have discretion to move funds without the client’s written consent, other than to same-name accounts with the same Custodian. For these clients, Sendero can only act on behalf of clients

upon their express instructions. In such cases, P a g e | 6 we cannot act on the clients’ behalf in the event of a volatile market with price swings that affect, negatively or positively, the values of the clients’ holdings. Any action taken must first be approved by the clients. Assets Under Management or Advisement (AUM) As of December 31, 2023, Sendero Wealth Management had $6.0 billion in assets under advisement, breakdown as follows; $4.9 billion in non-discretionary assets under advisement and $1.1 billion in discretionary assets under management. Our Services Sendero offers customized investment strategies to help our clients preserve, protect, and grow their wealth. We offer traditional asset allocation, manager selection, and sophisticated investment oversight to our clients. Sendero focuses on clients with $3MM or more in investable assets. Advisory Services We develop and implement investment strategies based on a client’s entire financial situation, not just their managed assets. Our open architecture strategy selection process provides a selection of both traditional and alternative investment strategies. We are a privately-owned, independent firm with deep family values and a passion for personalized service. Organization of Wealth Sendero provides the expertise to sort through the complexities of investing large pools of assets. We consider a client’s assets in the aggregate and present a clear, easy-to-understand analysis of total wealth. Strategic Asset Allocation Sendero uses a holistic view of wealth combined with an investment policy directive from the client to gain important insight into the most appropriate asset allocation. Portfolios usually include traditional equity and fixed income securities combined with non-correlated asset classes such as alternative investments, real estate, and private equity. Open Architecture Investment Manager Selection Sendero uses an open architecture platform. The strategies and investment vehicles used for client portfolios exercise discretion (buy and sell within our client’s account) within the mandate for which they have been hired. Expert Oversight We leverage sophisticated analysis and investment techniques to delicately balance a long-term, tax- sensitive discipline with the immediate cash flow needs of each relationship. Sub-Advisory Arrangement Sendero uses sub-advisors to assist and provide advisory services in the capacity of sub-advisor for certain clients. This relationship does not affect the fees agreed upon between Sendero and clients. Ongoing Manager Due Diligence Sendero’s due diligence team has adopted a hybrid on-site and virtual rotation for annual reviews, based on AUM and complexity of the strategy. The team conducts a high number of visits and/or conference calls each year with approved portfolio managers. Sendero also requests and reviews quarterly updates and annual due diligence questionnaires from all approved managers as part of its ongoing due diligence process. In addition, approved managers often visit the Sendero offices throughout the year. The due P a g e | 7 diligence team researches the investment process, current trades in the portfolio, and themes the managers are implementing in the portfolios; evaluates analysts’ reports, risk metrics, and attribution reports; and reviews manager personnel and turnover. The relationships with our managers are very important, and we allocate significant capital to the due diligence process. In all the situations discussed above, if the team identifies an issue with any investment or management team, the due diligence team will bring it to the Investment Advisor or Investment Committee’s attention for potential action. Custodians and Broker-Dealers used by Sendero Sendero uses various non-affiliated custodians in connection with its advisory activities where clients direct brokerage to these firms. Most advisory accounts serviced by Sendero use Pershing Advisor Solutions (“PAS”), which utilizes their affiliated broker-dealer to execute trades, Pershing LLC. Some advisory accounts serviced by Sendero also use Fidelity Investments (“Fidelity”), which utilizes their affiliated broker-dealer to execute trades, Fidelity WealthscapeSM. Clients’ transactions in some alternative investments are executed through Sendero Securities, LLC, the firm’s affiliated broker-dealer. Other alternative investments, not offered through Sendero, that are used in client portfolios will use various other custodians. Third-Party Service Providers Sendero works with various third-party service providers to help support the operational needs of managing and servicing discretionary advisory accounts. These providers perform operational functions such as portfolio reporting, account rebalancing, and trade execution. Third-party service providers may also place transactions with broker-dealers at the direction of Sendero and facilitate operational requests on behalf of clients based on instructions provided by Sendero. When providing these services, the third- party service provider is acting as an agent of Sendero and may charge fees based on a percentage of assets in the accounts they service. Investment Advocates We seek to provide intelligent advice for investment situations, recommending prudent and responsibly priced services for each client. When appropriate, we facilitate access to specialists for services beyond our scope of expertise, such as tax or legal advice, for which we receive no referral fees. We consider it our duty to help identify the most appropriate solution for any investment decision impacting our clients. Sendero’s advisory services include:
• Goal Assessment and Prioritization
• Comprehensive Aggregate Reporting
• Spending Policy Development
• Asset Allocation and Diversification
• Public and Private Security Expertise
• New Investment Opportunities
• Market Commentary
• Comprehensive Wealth Management Recommendations Investable vs. Accommodation Assets Sendero defines “Investable Assets” as those assets that are utilized in implementing the client's investment strategy. For example, assets transferred into Sendero without restriction as to their holding period or sale would be considered Investable Assets. Typical Investable Assets include listed stocks, bonds, ETFs, and mutual funds and are not included in Sendero’s due diligence process. However, Sendero reviews these P a g e | 8 assets on behalf of the client to ensure any decisions affecting the Investable Assets fall in line with the client’s goals. Sendero will not be responsible for valuing any Investable Asset. Sendero defines “Accommodation Assets” as those that are held in client accounts and reviewed in connection with client-specific portfolio allocation but are not included in Sendero’s due diligence process. Sendero does not conduct any due diligence on Accommodation Assets. However, Sendero reviews these assets on behalf of the client to ensure any decisions affecting the Accommodation Assets fall in line with the client’s goals. Typical Accommodation Assets include real estate, collectibles, and non-traded investments. Sendero will not be responsible for valuing any Accommodation Asset.