Bachrach Asset Management Inc. principal business is to provide fee-based investment advisory services to pooled investment vehicles. The advisor manages portfolios, on a discretionary basis, according to the fund's investment guidelines. The advisor's main approach is to use three levels of analysis: a) at a general level, top-down macroeconomic analysis, to determine general economic conditions and potential macroeconomic risks or opportunities worldwide. b) at a security level, fundamental and financial analysis to determine the attractiveness of a particular security; and c) to a lesser extent, for the execution of investment decisions, technical analysis to determine the timing of purchases or sales of selected securities. The advisor thinks that the best approach to attain consistent long-term returns is to diversify risk, avoid excessive leverage and carefully select each investment using objective criteria with a view to protect downside risk as much as seeking upside rewards. Furthermore, the advisor concentrates on the selection of individual security investments, risk diversification, protection of downside risks and a long-term horizon. The advisor may use exchange listed securities, over-the- counter securities, foreign securities, corporate or sovereign debt securities, CDs, mutual funds, hedge funds, options in securities and commodities, and futures on tangibles to accomplish this objective. The advisor may invest in Mutual Funds or Hedge Funds when it is more economic or practical to build a portfolio in this fashion. This may be due to the costs of building a portfolio in non-OECD local markets; the difficulties of gaining exposure to a sector/country for the size of investment contemplated, or due to superior expertise in picking securities in specific subsectors by mutual fund specialists. The advisor may invest in Closed End Funds,

in particular when those trade at a significant discount to the net value of their underlying assets. 4 Bachrach Asset Management, Inc. The advisor may invest in Hedge Funds, to the extent that it believes that a particular Hedge Fund offers a superior advantage to what could be done by the advisor both in terms of absolute return and risk control via strategy diversification. The advisor may reduce risk exposure and carry significant levels of cash positions as a possible hedge against market movement which may adversely affect the portfolio. The advisor 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) in the portfolio. The advisor may sell securities short, sell against the box, covered call writing, naked put writing and/or other strategies to reduce risk and/or improve performance. Bachrach Asset Management Inc. will only provide investment advisory services and portfolio management services but will not provide securities custodial or other administrative services. Exceptionally, Bachrach Asset Management may have authority over a client’s bank and / or securities account(s), only to facilitate the payment of fees and other advisory related expenses, according to the Investment Advisory Agreement. Bachrach Asset Management Inc. has approximately One Hundred and Ninety Seven Million Dollars ($197,000,000) under discretionary management as of December 31, 2022. Bachrach Asset Management Inc. is a Delaware corporation. The shareholders and principal owners of Bachrach Asset Management Inc. are:
• Miguel Bachrach (50 %)
• Carlos Bachrach (50 %) 5 Bachrach Asset Management, Inc.