Colliers Securities LLC (“CS or the Firm”) is registered with the SEC as a broker-dealer since 1977 and a registered investment adviser, and is a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). CS generally provides brokerage, custody and execution services through a clearing arrangement with National Financial Services LLC (“NFS” or “Custodian”), a nonaffiliated firm, member NYSE, SIPC and a Fidelity Investments® Company. CS is wholly owned by Colliers Mortgage Holdings LLC (“CMH”). The principal indirect and ultimate owner of CS is Colliers International Group Inc. CS offers two separate types of investment advisory services to its clients:
• Managed by non-affiliated investment advisers (“Wrap Programs” or “Outside Manager Programs”); and
• Managed by CS financial advisors (“Non-Wrap Programs”) As of December 31, 2023, CS manages $226,896,181 in assets on a non-discretionary basis and $35,726,587 on a discretionary basis. Advisory Services Offered Through CS Financial Advisors (“Non-Wrap Programs”) Colliers Director Overview Through the Colliers Director Program, CS provides non-discretionary investment advisory services to clients. The client pays an annual Advisory Fee (in lieu of commissions) which is billed on a quarterly basis and the client will incur other expenses when maintaining an account through this program such as Ticket Charge Fees (as defined and further explained herein below) for each transaction and other fees charged by the Custodian. The Colliers Director Program is not a Wrap program. CS will consider the customer’s personal financial information when making recommendations to the client regarding purchases and sales of securities. For non-discretionary accounts, investment decisions will be made by the client, as CS has no discretionary authority to effect securities transactions through the Colliers Director Program. Advisory Services Offered Through Outside Manager Programs (“Wrap Programs”) Rule 204-3(f) of the Investment Advisers Act of 1940 defines a wrap fee as a “program under which any client is charged a specified fee or fees not based directly on transactions in a client’s account for investment advisory services (which may include portfolio management or advice concerning the selection of other advisers) and execution of client transactions.” The wrap fee includes execution and custodial fees, investment advice and portfolio management services and reporting. Wrap fees are expressed as a percentage of the assets under management in a particular account, with clients being charged an annual Advisory Fee that is billed quarterly. When accounts are in a wrap fee program, clients may pay more or less than if the same securities were purchased and paid for separately. If the securities were purchased outside of a wrap fee program, clients would not receive ongoing investment advice and portfolio management services and generally would pay separately for execution or custodial fees. In addition, the same share class for securities in the wrap fee programs is not always available outside of a wrap fee or other advisory program. In general, clients that do not trade frequently or that do not wish to have ongoing investment advice or portfolio management services available to them will pay less in a non-wrap fee program. In CS’s wrap programs, which are managed as fully discretionary accounts, a Program Manager, Sub- Manager, or Sub-Adviser, not CS, has the authority to manage the assets in your account on a fully discretionary basis. For all services, this discretionary authority includes the authority, without first consulting you: to determine the portion of assets in your account that shall be allocated to each investment or asset class and to change such allocation of assets as necessary; to take any and all other actions on your behalf that CS determines is customary or appropriate for a discretionary investment adviser to perform, including the authority to buy, sell, select, remove and replace securities, including mutual fund shares, stocks, bonds and other investments for the account; and to select the broker-dealers or others with which transactions for the account are effected. CS does not have the authority to withdraw funds or securities from your account other than for payment of quarterly advisory fees as agreed to in writing by you. CS offers clients two wrap fee programs through the Envestnet Programs and the Dana Direct Program. Envestnet Programs Overview CS offers to its clients fully discretionary investment advisory services through Envestnet Asset Management, Inc. (“Envestnet”), an unaffiliated investment management firm, which is registered with the SEC as an investment adviser. Envestnet is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE: ENV), a publicly held company. Envestnet provides CS and its clients with a range of investment sub-advisory services through its various wrap programs, including Separately Managed Accounts (“SMA”) and Unified Managed Accounts (“UMA”) (together, the “Envestnet Programs” and individually, each an “Envestnet Program”). Clients that enroll in an Envestnet Program will execute an advisory agreement with CS and Envestnet. CS and the client compile pertinent financial and demographic

information to determine which Envestnet Program(s) to utilize and, if appropriate, identify appropriate managers and investment vehicles that will seek to meet the client’s goals and objectives. Based on information provided by clients, CS also determines whether other third-party services providers should be used in conjunction with the Envestnet Programs. CS may also use Envestnet’s advisory service tools, whereby Envestnet provides only administrative and technology services to CS. Utilizing Envestnet tools, CS seeks to allocate the client’s assets among the different options in the Envestnet Programs and determine the suitability of the asset allocation and investment options for the client, based on the client’s age, other investments, financial situation, needs, investment objectives, investment experience, investment time horizon, liquidity needs, and risk tolerance, among other pertinent factors. CS performs due diligence regarding the various managers of the Programs selected by clients. Envestnet is responsible for building its Programs, including selecting managers, day to day trading, rebalancing and reconciling the accounts. The managers in the Envestnet Programs will have full discretion over the trading activity in the client’s account. In addition to receiving the CS Disclosure Brochure, each client will receive the Envestnet Asset Management, Inc. brochure and Appendix to the brochure (the Wrap Fee Program brochure), which discuss the Envestnet Programs in detail. These brochures and disclosures are also available at https://adviserinfo.sec.gov/ Dana Direct Program Overview CS offers to its clients a fully discretionary investment advisory service through Dana Investment Advisors (“Dana”), an unaffiliated, SEC-registered investment advisory firm based out of Brookfield, Wisconsin. Dana provides CS and its client with a range of investment sub-advisory services through its SMA wrap program. Clients that enroll in this program will execute an advisory agreement with both CS and Dana. CS and the client compile pertinent financial and demographic information to determine which Dana investment vehicles that seek to meet the client’s goals and objectives. Based on information provided by clients, CS seeks to allocate the client’s assets among the different options in Dana’s Programs and determine the suitability of the asset allocation and investment options for the client, based on the client’s age, other investments, financial situation, needs, investment objectives, investment experience, investment time horizon, liquidity needs, and risk tolerance, among other pertinent factors. CS performs due diligence regarding Dana’s Programs selected by clients. Dana is responsible for building its Programs, including day to day trading, rebalancing and reconciling the accounts. Dana will have full discretion over the trading activity in the client’s account. In addition to receiving the CS Disclosure Brochure, each client will receive Dana’s brochure and Appendix to the brochure (the Wrap Fee Program brochure), which discuss Dana’s Programs in detail. These brochures and disclosures are also available at https://adviserinfo.sec.gov/. Other Unaffiliated Investment Managers CS may recommend or approve arrangements with unaffiliated investment advisers that provide discretionary investment supervisory services. Any reports other than brokerage reports prepared by unaffiliated investments advisers issued to the clients are not verified by CS. Unaffiliated investment advisers may impose minimum account size requirements. CS will receive its usual commissions on trades the client directs to CS, if any. Information About Your Account To ensure that you remain informed about your account, CS’s Custodian, NFS, delivers trade confirmations and monthly statements to you when there is activity in your account. You should promptly review all account statements and trade confirmations to ensure that your account is being handled in accordance with your instructions, and immediately inform CS in writing of any discrepancies. If you have questions or need additional information regarding your account, you should contact your CS financial advisor. Colliers Director Program accounts, Dana Direct Program accounts, and Envestnet Program accounts are held through CS’s broker-dealer, which in turn introduces assets to and clears transactions on a fully-disclosed basis through Custodian. CS directs all transactions related to the Colliers Director Program to Custodian for execution and confirmation. Solicitors CS may solicit clients for investment advisers that provide services that CS may choose not to provide, such as market timing services, and some consulting services such as assistance with investment policies, selection criteria, or portfolio monitoring. In each such case, a separate solicitor’s disclosure document prepared by the investment adviser providing such services will describe the nature of the solicitor relationship, including any fee sharing arrangements between the solicitor and CS. The client will receive a disclosure acknowledgement of any such arrangement.