Firm Description St. Columbanus AG (“Columbanus” or “the Company” or “we”), a Swiss corporation based in Teufen, provides dedicated investment advisory services to client’s resident in the United States (“US”). We also serve US taxpayers or dual citizens living outside the US. Columbanus commenced operations in 2011. In November 2013, the company repositioned itself with an exclusive focus on US Persons. Principal Owner The principal owner of St. Columbanus AG is Jose M. Soriano Jr. Services Columbanus offers both discretionary asset management and non-discretionary investment advisory services. Columbanus provides portfolio management consistent with the circumstances, preferences and objectives of each client. Investment advisory services are provided based on the individual needs and investment objectives of each client as communicated to Columbanus. Specifically, the structure for each client’s investment program is created in the context of certain considerations such as expected returns, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Each client’s assets are managed in a separate account (an “Account”) maintained at a third-party financial institution. Columbanus’ client portfolios are designed to meet client’s individual objectives. Accounts may include, without limitation: equity securities, fixed income securities, limited partnership interests, mutual funds, exchange traded funds, hedge funds, and other alternative investments consistent with a client’s objective, risk tolerance, reference currency, tax situation, investment time horizon and overall suitability. For the purpose of diversification, client accounts may hold non-dollar securities in markets outside the United States. Whilst generally Columbanus makes investments with a longer time horizon, Columbanus 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. Columbanus’ advice is limited to the types of securities and transactions as set

forth in Item 8. Columbanus does not render any Legal or Tax advice. Discretionary Service Columbanus offers a discretionary asset management service designed for investors who wish to have their assets fully managed by Columbanus. This service provides asset allocation, investment selection and active portfolio management including portfolio rebalancing in accordance with a client’s stated objectives, investment time horizon, risk tolerance, and tax situation. Company purchases and sells securities for the client’s Account without prior consent of or notification to the client. Company determines the securities that are bought and sold for the client’s Account and the total amount of the purchases and sales. Columbanus’ authority may be subject to conditions imposed by individual clients as set forth and agreed upon in the asset management agreement entered into between Columbanus and the client. For example, a client may restrict or prohibit transactions in certain types of securities. Investment Advisory Service Columbanus also offers investment advisory service on a non-discretionary basis which is similar to the discretionary portfolio management service in terms of; however, Columbanus requires client consent before effecting any securities transaction. The Company provides portfolio advice and trading recommendations but all decisions regarding the investment of the Account reside with the client. This service is designed for clients who desire holistic management of their Account but who want to retain involvement in every investment decision. As a result, clients under this service offering may not be invested in the same manner as those clients with the Discretionary Asset Management service. If explicitly required by a non-discretionary client, Columbanus may implement investment ideas which do not pertain to Columbanus’ investment universe. Columbanus will disclose to the client, if an investment idea is not part of its investment universe. Wrap Fee Programs Columbanus does not participate in wrap fee programs. St. Columbanus AG CRD 169895 4 Assets under Management and Advisement Columbanus managed approximately $42.3 million on a discretionary and approximately $11.7 million on a non-discretionary basis as per December 2023.