Firm Description Proventus AG Vermögensverwaltung (“Proventus AG”, “Proventus Ltd” or “the Firm” or “we”), a Swiss corporation based in Zurich, Switzerland, provides investment advisory services to clients resident in the United States (“US”). We also serve US taxpayers or dual citizens living outside the US and clients who have no connection to the US. Proventus Ltd commenced operations in November 1998. Principal Owners Markus Widmer principally owns Proventus Ltd. Discretionary Portfolio Management Proventus Ltd offers a discretionary asset management service to individuals and high net worth clients and their families. The services provided are designed for investors who wish to have their assets fully managed by Proventus Ltd and include asset allocation, investment selection, active portfolio management and portfolio rebalancing consistent with the circumstances, preferences and objectives of each client. Proventus Ltd discusses a client's prior investment history, as well as family composition and background. As part of this information-gathering process, Proventus Ltd determines the client's individual objectives, time horizon, risk tolerance, tax situation and liquidity needs and develops a tailored investment policy. Each client’s assets are managed in a separate account (an “Account”) maintained at a third-party financial institution. Proventus Ltd purchases and sells securities for the client’s Account without prior consent of or notification to the client. Proventus Ltd determines the securities that are bought and sold for the client’s Account and the total amount of the purchases and sales. Proventus Ltd’s authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the asset management agreement

entered into between Proventus Ltd and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Client Accounts broadly are managed in a similar manner, however, differences in each portfolio occur due to client specific objectives, tax considerations, liquidity needs, risk tolerance, reference currency, expected returns, legal restrictions, investment time horizon and overall suitability. Proventus Ltd primarily invests in: Equity securities, fixed income, high quality rated debt instruments, mutual funds, exchange traded funds, hedge funds, precious metals and in rare occasions structured products. For the purpose of diversification, client accounts will hold non-dollar securities in markets outside the United States. Whilst generally Proventus Ltd makes investments with a longer time horizon, Proventus Ltd may recommend changes to allocations in an attempt to take advantage of conditions in the current economic environment whilst being sensitive to transaction costs and taxes, as applicable. Such changes may involve underweight or overweight positions designed to capitalize on current economic conditions over the short- term. Exceptionally and on client request Proventus Ltd may recommend other investment advisers for its clients. Proventus Ltd’s advice is limited to the types of securities and transactions as set forth in Item 8. Proventus does not render any Legal or Tax advice. Wrap Fee Programs Proventus Ltd does not participate in wrap fee programs. Assets under Management and Advisement Proventus Ltd managed approximately $645 million on a discretionary basis and $ 0 million March 2024 Proventus AG Vermögensverwaltung, CRD: 167142 4 on a non-discretionary basis as of December 31, 2023.