UCAP Asset Management, LLC (“UCAP” or the Firm) is an investment advisory firm that is registered with the U.S. Securities and Exchange Commission. It has been in business since 2015. UCAP is a wholly owned subsidiary of Union Capital Group USA, LLC, which is wholly owned by Lawrence D. Howell by way of Holdco LDH LLC. UCAP provides portfolio management (implemented by UCAP, a sub-adviser, or an independent, third-party money manager), investment consulting, and financial planning. We generally market under the UCAP AMERICAS brand. INVESTMENT ADVICE Clients may engage UCAP to manage all or a portion of their assets on a discretionary or non- discretionary basis or to provide investment advice on consulting non-binding basis. UCAP and its representatives provide advice that is tailored to the individual needs of the client based on the financial information and the investment objective(s) communicated by the client. Clients may impose restrictions on investing in certain securities or groups of securities by notifying the firm or representative in writing (including in the Account Application). UCAP may recommend that clients authorize the active discretionary management of all or a portion of their assets by and/or among certain sub-advisors, based on the stated investment objectives of the client or upon the client's request. The terms and conditions under which the client engages the sub-advisor are set forth in a separate written agreement between UCAP or the client and the designated sub-advisor. UCAP provides the service of selecting or recommending the sub-advisor. UCAP also periodically monitors and reviews the account performance and the client's investment objectives. UCAP receives an advisory fee which is based on a percentage of the market value of the assets being managed, including assets being managed by a sub-advisor. UCAP pays a portion of its advisory fee to the sub-advisors; the client does not pay an additional fee for management by a sub-advisor. Fees charged by the broker-dealer/custodian of the client's assets are exclusive of, and in addition to, UCAP's investment advisory fee, and the client may incur additional fees beyond those charged by UCAP/the sub-advisor and the

broker- dealer/custodian. In addition to UCAP's Brochure, the client also receives the Brochure or other disclosure documents, if applicable, of the sub-advisor. Clients should be aware that non-U.S. sub-advisors who serve only non-U.S. clients may not be registered in the United States, with the U.S. Securities and Exchange Commission or any State; depending on the laws of their home jurisdictions, they may be registered in their home jurisdictions. Certain sub-advisors may impose more restrictive account requirements or may have billing practices that differ from UCAP's; UCAP may, in its discretion, alter its account requirements and/or billing practices to accommodate those of the sub-advisors who manage or participate in managing the client's assets. UCAP will notify clients about changes in account requirements and/or billing practices prior those changes become effective. FINANCIAL PLANNING SERVICES UCAP does not generally offer financial planning services on a stand-alone basis. UCAP prefers to enter into long-term, holistic relationships with clients, in which its financial planning services are part of its overall engagement for investment management services. The scope of the plan will be discussed with the client. Financial plans may encompass all or some of the following areas of financial concern to the client:
• Insurance Planning/Risk Management
• Investments
• Asset Allocation Review and Recommendations The representative obtains appropriate information from the client through personal interviews (including a discussion of current financial status, future goals and attitude towards risk) and reviews the documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. ASSETS UNDER MANAGEMENT As of December 31, 2023, UCAP had $ 164,262,402 in assets under management on a discretionary basis and $ 1,180,679 on non-discretionary basis for a total of $165,443,081 in regulatory assets under management.