Welton is a Delaware limited liability company that was formed on June 12, 2014. Welton is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity pool operator and a commodity trading adviser and is a member in good standing of the National Futures Association in those capacities. Welton Investment Corporation, a Delaware corporation that was formed on May 19, 1997, owns in excess of 25% of Welton. Welton Investment Corporation is owned by The Welton Family Trust. Futures Trading Programs Welton provides discretionary investment management services regarding the trading of commodity futures contracts and over the counter (“OTC”) foreign exchange products through separately managed accounts (collectively, “Separate Futures Account Investors”) , Welton sponsored private investment funds and as a sub-adviser to mutual funds operated by unaffiliated advisers pursuant to Welton’s proprietary trading systems (the “Futures Trading Programs”). The Futures Trading Programs focus on the trading of futures and forward contracts through managed futures/global macro trading strategies that seek to invest across a diversified group of global futures markets and OTC foreign exchanges spanning four market sectors (traditional commodities (e.g., agriculture, energy, and metals), currencies, equity indices, and interest rates). With respect to certain Welton sponsored private investment funds described above, Welton also provides and/or delegates and oversees discretionary investment management services regarding cash securities portfolios on behalf of certain series or classes of such private investment funds (collectively, “Advisory Futures Fund Clients”). The cash securities portfolios for which Welton provides discretionary investment management services consist of investments in high-quality, short-term debt securities and money market instruments for temporary defensive purposes. These short-term debt securities and money market instruments generally include, among other things, shares of other mutual funds, commercial paper, certificates of deposit, bankers’ acceptances, U.S. Government securities and repurchase agreements. Welton may also provide investment management services to other pooled investment vehicles managed by Welton pursuant to the Futures Trading Programs that do not allocate assets to a cash securities portfolio (collectively, “Other Futures Fund Clients”). For purposes of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), “investment advisory clients” does not include Other Futures Fund Clients and Separate Futures Account Investors (collectively, “Futures Clients”). Therefore, Futures Clients are generally not discussed in this Brochure except in the context of conflicts of interest that may arise between Welton’s Advisory Futures Fund Clients and Futures Clients. Multistrategy Trading Program Welton also provides multistrategy investment management services pursuant to Welton’s proprietary

trading systems (the “Multistrategy Trading Program” and together with the Futures Trading Programs, the “Trading Programs”). Currently, the Multistrategy Trading Program is provided to Welton sponsored private investment funds (the “Multistrategy Fund Clients” and together with Advisory Futures Fund Clients, the “Funds”) and is also available to separately managed accounts (the “Multistrategy Managed Accounts” and together with Multistrategy Fund Clients, “Multistrategy Clients” and Multistrategy Clients together with Advisory Futures Fund Clients, “Clients”). The Multistrategy Trading Program seeks to achieve its investment objective through investing in domestic equity securities along with a group of global derivative markets spanning four major market sectors. The Multistrategy Trading Program uses price data from exchange sources and sustainability data from third-party non-exchange sources including, as of the date of this Brochure, Sustainalytics (a Morningstar company); Institutional Shareholder Services (“ISS”); World Bank Group (“World Bank”); U.S. Environmental Protection Agency (“EPA”); and U.S. Department of Energy (“DOE”). The Multistrategy Trading Program uses the sustainability data to score potential investments using a proprietary values-based scoring methodology (“Values-Based Scores”) towards its goal of maximizing risk-adjusted return along with above average sustainability. This means that the portfolio is intended to have an overall Values-Based Score that is higher than the corresponding equity index. For equities, the Multistrategy Trading Program incorporates ISS and Sustainalytics scores into the proprietary equity algorithm. For derivatives, the Multistrategy Trading Program incorporates World Bank, EPA, and DOE data into the proprietary derivative algorithm. As a result, the Multistrategy Trading Program generally holds a portfolio of several hundred companies among the 1,000 largest U.S. capitalization stocks. The Multistrategy Trading Program's algorithms will dynamically allocate more assets to instruments with rising price trends and higher Values-Based Scores, and fewer assets to those with falling price trends and lower Values-Based Scores. To further achieve its goal of increased investment sustainability, the Multistrategy Trading Program eliminates instruments linked to specific sectors such as weapons, tobacco, and fossil fuels. Additional information about the Funds managed by Welton, including information about investment strategies, investment policies and restrictions, fees, risks and other material information, is contained in each Fund’s respective offering documents, including any exhibits thereto (collectively, “Memorandum”). As of December 31, 2023, Welton managed approximately $440,234,325 of regulatory assets under management on a discretionary basis in Client accounts. Welton, across all trading programs, manages approximately $1.6 billion, through managed accounts and private investments funds.