A. Firm Information Seeds Investor LLC (“Seeds” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware and located in the state of New York. Seeds was founded in December 2018 and became a registered investment advisor in May 2020. Seeds is a wholly-owned subsidiary of Seeds Investor Holdings LLC. The Principal Officer of Seeds is Zachary A. Conway (Founder, Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Seeds. For information regarding this Disclosure Brochure, please contact Mr. Conway at (212) 287-7370. B. Advisory Services Offered Seeds primarily offers investment management and related services to other financial institutions through sub- advisory engagements (each referred to as a “Client”). Seeds does not provide these services directly to individual investors. Advisory Persons of the Client will serve as the primary Advisor and manage all aspects of their relationship with the underlying investor. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Seeds’ fiduciary commitment is further described in the Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Seeds provides customized investment advisory solutions for its Clients including discretionary investment sub- advisory services and investment model management. Seeds develops and maintains its internal investment models and may also assist the Client with the design, oversight and maintenance of models designed by the Client. The Advisor also makes available its services via an investment management software that provides the Client with various financial management services. Seeds offers values-aligned investment solutions through proprietary strategies. These strategies focus on investing in companies that, relative to their industry group peers, are both seeking to mitigate environmental, social, governance (ESG) risks and exhibiting strong underlying fundamentals. Seeds will typically construct investment models and portfolios utilizing stocks, exchange-traded funds (“ETFs”) and mutual funds. Seeds may also utilize individual bonds, American Depository Receipts (ADRs), options contracts, and other types of derivatives or investments, as appropriate, to meet the needs of a specific Client mandate. Seeds’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. The Client is responsible for the selection of the appropriate investment strategy for each underlying investor. The Client is further responsible to ascertain the goals, objectives, circumstances, risk tolerance and financial situation for each of their underlying investors. Seeds assumes no responsibility to obtain such information from the underlying investor of the Client. The Client will have the opportunity to place reasonable restrictions on the types of investments to be held in accounts for their investors, subject to acceptance by the Advisor. Seeds evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Seeds may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Seeds may recommend specific positions to increase sector or asset class weightings, however typically the strategies will seek to be in line with respective broad market benchmarks. Seeds may recommend

selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] Page 5 in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Seeds accept or maintain custody of a Client’s or Investor’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage Practices. Investment Platform - Seeds may utilize turn-key portfolio and practice management software platform (“Platform”) provided by unaffiliated third parties. These unaffiliated third parties have developed a customized single-source managed account solution which it makes available to its clients and the clients of third-party investment advisers such as the Firm. The Platform assists investment advisers with intuitive tools to provide SMA and UMA portfolios, bringing an increased scale and flexible wealth management solutions to assist in providing better outcomes. Seeds utilizes the Platform, depending on its relationship with its Clients, for trade order management, order aggregation, and other administrative and operational services. The Advisor may also enter into arrangements with other independent third party investment advisory firms permitting them to utilize Seeds’ strategies, and the Advisor will charge fees as appropriate for the type of securities and style of investment management implemented in these managed portfolios. Investment Modeling Services The Advisor develops model portfolios using proprietary methodologies. The model portfolios are made available to investment advisors, through a third party, who can select, at their discretion, to allocate assets based on the actionable investment outputs via the Advisor’s designed models. Although fees are charged as a percent of total assets advised upon in the models, Seeds does not manage these assets but only provides non-discretionary investment advice in the form of the model outputs. These assets are held in accounts of the Client’s or of end retail clients for which the Client provides advisory services, and are not directly managed by Seeds. Seeds does not have the authority to decide which securities to buy or sell with respect to these assets, nor does it have the authority to place trade orders, as the decision to trade based on the model outputs are the sole responsibility of the Client. C. Client Account Management Prior to engaging Seeds to provide investment advisory services, each Client is required to enter into a written agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Seeds, in connection with the Client, will define the investment mandates as required by the Client. ● Asset Allocation – Seeds will develop a strategic asset allocation to assist the Client in recommending a portfolio for their investors. ● Portfolio Construction – Seeds will implement an investment portfolio for each Investor account assigned to Seeds as a Sub-Advisor. ● Investment Management and Supervision – Seeds will provide investment management and ongoing oversight of the accounts placed under its management and supervision. The Client will assume responsibility for communications with its underlying Investors. D. Wrap Fee Programs Seeds does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2023, Seeds manages $165,456,769 in Client assets, all of which is on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Page 6