ASTRA VENTURES

1. Brochure Supplement – Part 2B Stephen Christopher Buehler CRD#: 5331641 Astra Ventures Investment Partners LLC (dba Astra) 102 Alton Road Nashville, Tennessee 37205 901-230-5576 March 17, 2026 Part 2B (“Brochure Supplement”) This Brochure Supplement provides information about Stephen Christopher Buehler that supplements the Astra Ventures Investments Partners LLC’s Brochure (dba Astra). You should have received a copy of that Brochure. Please contact Stephen Buehler at 901-230- 5576, or at buehler@astravc.com if you did not receive the Brochure or if you have any additional questions about the contents of this supplement. Additional information about Stephen Christopher Buehler is available on the SEC’s website at www.adviserinfo.sec.gov/.  2. Item 2 – Education Background and Business Experience Stephen Christopher Buehler Founder Investment Advisory Representative Born: 1977 Formal Education after High School: Northwestern University—Kellogg School of Management—MBA Finance, Management and Strategy Mississippi State—Bachelor of Business Administration, Bachelor of Accountancy Professional Designations Completed: North American Securities Administrators Association (NASAA) Series 65 and Series 3 National Association of Securities Dealers (NASD) Series 7 and 63 The Series 65 designation qualifies an individual to act as an investment adviser representative (IAR), providing investment advice and managing client portfolios. It is administered by the North American Securities Administrators Association (NASAA) through FINRA. To achieve Series 65 designation, candidates must pass a 180-minute exam with 130 scored multiple-choice questions. The exam covers investment products (e.g., stocks, bonds, mutual funds), portfolio management, fiduciary duties, securities regulations, and ethical practices. The Series 3 designation qualifies an individual to engage in the solicitation, purchase, or sale of commodity futures contracts, options on futures, and related derivatives. It is administered by NASAA through FINRA. To achieve Series 3 designation, candidates must pass a 120-minute exam with 120 scored multiple-choice questions. The exam covers futures markets, hedging, margin requirements, trading strategies, regulatory frameworks (e.g., Commodity Exchange Act), and customer protection rules. The Series 7 designation qualifies an individual to act as a registered representative, selling a broad range of securities, including stocks, bonds, mutual funds, options, and certain alternative investments. It is administered by the Financial Industry Regulatory Authority (FINRA), formerly the National Association of Securities Dealers (NASD). To achieve Series 7 designation, candidates must pass a 225-minute exam with 125 scored multiple-choice questions. The exam covers investment products, risk analysis, client suitability, securities regulations, and trading practices. The Series 63 designation qualifies an individual to act as a securities agent, ensuring compliance with state securities laws (Blue Sky Laws). It is administered by NASAA through FINRA and is often paired with the Series 7. To achieve Series 63 designation,  candidates must pass a 75-minute exam with 60 scored multiple-choice questions. The exam covers state securities regulations, registration requirements, antifraud provisions, and ethical practices. Recent Business Background: Blackstone Advisory Partners, LLC 4/2010-7/2018 Merrill Lynch, Pierce, Fenner and Smith INC 10/2008-3/2010 3. Item 3—Disciplinary Information Mr. Buehler has not been in the past nor is he currently the subject to any criminal, civil, or disciplinary action. 4. Item 4—Other Business Activities Mr. Buehler serves as an independent director on the Board of Directors of Braiin Ltd., which as of February 12, 2026 is traded as a public security listed on the Nasdaq under ticker “BRAI”. In this role, Stephen Buehler could have access to material non-public information. To mitigate the conflict and prevent insider trading risks (under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, as applicable to advisers via fiduciary duties), Astra implemented policies and procedures as detailed in the ADV Part 2A. This company does not operate in the financial services industry. 5. Item 5—Additional Compensation Mr. Buehler is compensated by Braiin Ltd. for his role as an independent director as described in Item 4. 6. Item 6—Supervision The firm has adopted policies and procedures to oversee, monitor and control the activities of its Supervised Persons. 7. Item 7—Requirements for State-Registered Advisers Mr. Buehler has not had a judgement against him nor has he been found liable for any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following: a) an investment or an investment-related business or activity;  b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) theft, embezzlement, or other wrongful taking of property; d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices.  1. Brochure Supplement – Part 2B Charles Edgar Lalanne CRD#: 3005327 Astra Ventures Investment Partners LLC (dba Astra) 102 Alton Road Nashville, Tennessee 37205 901-230-5576 March 2026 Part 2B (“Brochure Supplement”) This Brochure Supplement provides information about Charles Edgar Lalanne that supplements the Astra Ventures Investments Partners LLC’s Brochure (dba Astra). You should have received a copy of that Brochure. Please contact Stephen Buehler at 901-230- 5576, or at buehler@astravc.com if you did not receive the Brochure or if you have any additional questions about the contents of this supplement. Additional information about Charles Edgar Lalanne is available on the SEC’s website at www.adviserinfo.sec.gov/.  2. Item 2 – Education Background and Business Experience Charles Edgar Lalanne Chief Investment Officer (CIO) Investment Advisory Representative Born: 1976 Formal Education after High School: Northwestern University—Kellogg School of Management—MBA Finance, Decision Sciences Dartmouth College —Bachelor of Arts, Earth Sciences Professional Designations Completed: North American Securities Administrators Association (NASAA) Series 65 and Series 3 National Futures Association (NFA) Series 3 National Association of Securities Dealers (NASD) Series 7 and 63 The Series 65 designation qualifies an individual to act as an investment adviser representative (IAR), providing investment advice and managing client portfolios. It is administered by the North American Securities Administrators Association (NASAA) through FINRA. To achieve Series 65 designation, candidates must pass a 180-minute exam with 130 scored multiple-choice questions. The exam covers investment products (e.g., stocks, bonds, mutual funds), portfolio management, fiduciary duties, securities regulations, and ethical practices. The Series 3 designation qualifies an individual to engage in the solicitation, purchase, or sale of commodity futures contracts, options on futures, and related derivatives. It is administered by NASAA through FINRA. To achieve Series 3 designation, candidates must pass a 120-minute exam with 120 scored multiple-choice questions. The exam covers futures markets, hedging, margin requirements, trading strategies, regulatory frameworks (e.g., Commodity Exchange Act), and customer protection rules. The Series 7 designation qualifies an individual to act as a registered representative, selling a broad range of securities, including stocks, bonds, mutual funds, options, and certain alternative investments. It is administered by the Financial Industry Regulatory Authority (FINRA), formerly the National Association of Securities Dealers (NASD). To achieve Series 7 designation, candidates must pass a 225-minute exam with 125 scored multiple-choice questions. The exam covers investment products, risk analysis, client suitability, securities regulations, and trading practices. The Series 63 designation qualifies an individual to act as a securities agent, ensuring compliance with state securities laws (Blue Sky Laws). It is administered by NASAA  through FINRA and is often paired with the Series 7. To achieve Series 63 designation, candidates must pass a 75-minute exam with 60 scored multiple-choice questions. The exam covers state securities regulations, registration requirements, antifraud provisions, and ethical practices. Recent Business Background: Tse Capital Management LLC 4/2017-12/2020 Bloomberg LP 5/2016-3/2017 3. Item 3—Disciplinary Information Mr. Lalanne has not been in the past nor is he currently the subject to any criminal, civil, or disciplinary action. 4. Item 4—Other Business Activities No securities-related other business activities 5. Item 5—Additional Compensation None 6. Item 6—Supervision The firm has adopted policies and procedures to oversee, monitor and control the activities of its Supervised Persons. 7. Item 7—Requirements for State-Registered Advisers Mr. Lalanne has not had a judgement against him nor has he been found liable for any of the events listed below. 3. An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following: f) an investment or an investment-related business or activity; g) fraud, false statement(s), or omissions; h) theft, embezzlement, or other wrongful taking of property; i) bribery, forgery, counterfeiting, or extortion; or j) dishonest, unfair, or unethical practices. 4. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following:  f) an investment or an investment-related business or activity; g) fraud, false statement(s), or omissions; h) theft, embezzlement, or other wrongful taking of property; i) bribery, forgery, counterfeiting, or extortion; or j) dishonest, unfair, or unethical practices. 

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure Astra Ventures Investment Partners LLC dba Astra 102 Alton Road Nashville, Tennessee 37205 (901) 230-5576 April 15, 2026 This brochure provides information about the qualifications and business practices of Astra Ventures Investment Partners LLC (herein after referred to “Astra” and dba “Astra”). If you have any questions about the contents of this brochure, please contact Stephen Buehler at (901) 230- 5576. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Astra also is available on the SEC's website at Additional www.adviserinfo.sec.gov. Registration does not imply any level of skill or training. Page 1 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Item 2: Material Changes This Firm Brochure is the disclosure document for Astra Ventures Investment Partners LLC ("Astra", "we" and/or the "firm" but, in any case, dba “Astra”) prepared according to regulatory requirements and rules. Astra is required to advise you of any material changes to our Firm Brochure ("Brochure") from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update or date of the last update of material changes of our Brochure. Furthermore, we will provide you with other interim disclosures about material changes, as necessary. Since our latest annual update as filed on March 17, 2025 and the last update with material changes as filed on April 24, 2025, we have made the following changes to our Brochure:  Updates to regulatory assets under management (AUM) and regulatory assets under advisement (AUA) as of January 1, 2026: o Regulatory assets under management (AUM) of $179,551,937  Stephen Buehler serves as an independent director on the Board of Directors of Braiin Ltd., which as of February 12, 2026 is traded as a public security listed on the Nasdaq under ticker “BRAI”. In this role, Stephen Buehler could have access to material non-public information. To mitigate the conflict and prevent insider trading risks (under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, as applicable to advisers via fiduciary duties), Astra strictly prohibits: o Any purchase, sale, or holding of Braiin Ltd. securities (including derivatives or related instruments) by: Immediate family members living in the same household.  Firm personnel (including owners, employees, and supervised persons).   Clients in any advised accounts (discretionary or non-discretionary). o Exceptions:  Trading may be conducted by Stephen Buehler in accordance with Section 16 which requires formal filings of Forms 3, 4 and 5 and in accordance with any Rule 10b-5 plan as applicable.  Any other trading must be pre-approved by the CCO in writing for de minimis or legacy holdings, subject to immediate divestiture plans. Whenever you would like to receive a complete copy of the current Brochure, please contact us at (901) 230-5576 or buehler@astraalts.com. We will be happy to provide you with a complete copy. Page 2 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................... 1 Item 2: Material Changes .............................................................................................. 2 Item 3: Table of Contents............................................................................................... 3 Item 4: Advisory Business.............................................................................................. 4 Item 5: Fees and Compensation..................................................................................... 9 Item 6: Performance-Based Fees .................................................................................. 12 Item 7: Types of Clients ............................................................................................... 13 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ...................... 13 Item 9: Disciplinary Information .................................................................................23 Item 10: Other Financial Industry Activities and Affiliations .................................... 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................... 24 Item 12: Brokerage Practices ....................................................................................... 26 Item 13: Review of Accounts ........................................................................................ 30 Item 14: Client Referrals and Other Compensation .................................................... 30 Item 15: Custody ............................................................................................................ 31 Item 16: Investment Discretion .................................................................................... 31 Item 17: Voting Client Securities ..................................................................................32 Item 18: Financial Information .....................................................................................32 Page 3 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Item 4: Advisory Business Description of the Firm Astra Ventures Investment Partners LLC dba as Astra ("Astra"), is a Delaware limited liability company formed in 2018. Astra has its principal place of business in Nashville, Tennessee. Astra filed for initial registration as an Exempt Reporting Adviser (“ERA”) in November of 2019. In January of 2020, Astra commenced the business of providing investment advisory services and, accordingly, updated its filing status to be a state-registered investment adviser. In June of 2024, Astra registered with the Securities and Exchange Commission (“SEC”) given it exceeded the AUM thresholds that require graduation from state registration to SEC registration. Astra is wholly-owned by Astra Investment Holdings LLC which is then, in turn, wholly-owned by Stephen Buehler. Stephen Buehler serves as the Chief Compliance Officer. Astra maintains a website that is located at the following URL: www.astraalts.com. Description of Services Offered The following paragraphs describe the services offered by Astra. As used in this Brochure, the words "our" and "us" also refer to Astra. The words "you," "your" or "client" refer to our clients and prospective clients. Other terms may be defined later in this Brochure as well. Investment Advisory Service Categories Astra offers continuous and ongoing investment advice, portfolio management services and advisory services. Astra provides these services to individual high net worth investors, institutional investors and to a private fund. Astra offers its clients investment services that fall into the following categories: 1) Investment advisory services whereby Astra manages the client’s assets (a service where client assets are commonly referred to as Assets Under Management or “AUM”). Such investment advisory services can be performed on either a Discretionary basis or Non- Discretionary basis, although most typically the service is Discretionary. When Astra provides investment advisory services for clients when their assets are managed (e.g. AUM), a qualified Custodian is used to hold the assets. At present, the list of approved custodians is as follows (this list of custodians can and will change as the needs of Astra and its clients evolve): a. Charles Schwab b. Interactive Brokers 2) Investment advisory services whereby Astra advises the client on investments but does not directly manage the assets (a service where client assets are commonly referred to as Assets Under Advisement or “AUA”). Such investment advisory services are most typically performed on a Non-Discretionary basis where Astra recommends one or multiple investments but the client chooses whether he/she wants to invest and then, typically, invests directly with the third-party fund manager in question. Astra will then provide ongoing investment advice on the investments. When Astra provides investment advisory Page 4 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  services for clients when their assets are AUA, the client’s assets are held with the third- party asset manager in question or with a custodian chosen by that third-party asset manager. 3) Investment advisory services to private funds, including any series of those funds, in which case the funds and their series are the clients of Astra. The terms of these services are outlined in the respective offering documents of those private funds. 4) Investment Research & Trade Idea Exchange whereby Astra contributes investment research and trade ideas to a third-party in exchange for a flat fee. Whether its investment advice is structured as AUM or AUM (as described above), Astra will seek to meet its clients’ objectives, which could include any of the objectives describe below. Portfolio Management Services Our Portfolio Management Service encompasses asset management on a discretionary or non- discretionary basis. It is designed to assist clients in meeting their financial goals through the use of one or more financial investments or one or more investment strategies or models. We conduct at least one, but sometimes more than one meeting (in person, telephone or video conference, or via email) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we will propose an investment approach. The investment approach, guidelines and restrictions will form the investment objectives of the account. Upon the client's agreement to the proposed investment plan, we will work with the client to establish or transfer investment accounts so that we can manage the client's portfolio. Once the relevant accounts are under our management, we review such accounts on an ongoing basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client's investments. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in an investment portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, funds or investment instruments, and the amount of each, to be purchased or sold for your account without obtaining your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. In addition to other types of investments, we may invest your assets according to one or more model portfolios developed by our firm. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of Page 5 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Targeted Investment Objective Services On both an AUM and AUA basis, Astra may engage with clients to seek an investment or investments that meet a specific and targeted investment objective. In these cases, Astra may not provide Comprehensive Portfolio Management Services. Instead, Astra may be seeking to provide advice on an investment fund or funds that serve a role for the client as part of his/her broader portfolio, which Astra may not manage for the client. Many of the investment funds that Astra recommends in its Targeted Investment Objective Services pursue “alternative” investment strategies. Examples of alternative investment strategies may include, but is not limited to, private equity, growth equity, venture capital, real estate, infrastructure, real assets, direct lending and hedged strategies. These funds are often advised by third-party advisers that Astra selects with the investment objective in mind. Each of these strategies could be used to meet a specific client objective. Examples of targeted investment objectives that a client may pursue could include any of the following (this list is not intended to be comprehensive nor are the objectives mutually exclusive): • Seeking a target total or gross return (pre-tax) • Seeking diversification from traditional investment asset classes • Seeking a target gross yield (pre-tax) • Seeking a target total or gross return via illiquidity or complexity premium Our Targeted Investment Objective Service encompasses asset management on a discretionary or non-discretionary basis. They are designed to assist clients in meeting unique financial goals through the use of select investment funds or strategies. We conduct at least one, but sometimes more than one meeting (in person, telephone or video conference, or via email) with clients in order to understand their current financial situation, investment holdings, and tolerance for risk. Based on what we learn, we will recommend securities, a fund or a variety of funds that seeks to meet the clients’ targeted goal. For certain investment funds, the client must meet certain accreditation standards to be eligible to invest. To invest in such a fund, the client must meet the required standard. The investment approach, guidelines and restrictions will form the investment objectives of the account. Upon the client's agreement to the proposed investment plan, we will work with the client to establish or transfer investment accounts so that we can manage the client's portfolio, if applicable. We review such accounts on an ongoing basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client's investments. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in an investment portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Page 6 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Financial and Investment Instruments for the client's circumstances. Our For each of the services models described above, Astra aims to assist clients in meeting select financial goals through use of financial investments. We explore different types of investment options and strategies appropriate investment recommendations are not limited by any specific product or service offered by a broker-dealer or custodian. These recommendations may generally include, but not necessarily be limited to, security types from the following list: • Money market funds and other cash instruments • Exchange listed securities, and securities traded over-the-counter (OTC) • Mutual fund shares, SMAs and exchange traded fund shares – passive and actively managed, including mutual funds held at the fund company • Exchange traded funds (“ETFs) • Closed end fund shares • Business Development Companies (BDCs) – both listed and non-listed • Real Estate Investment Trusts (REITs) – both traded and non-traded • Certificates of deposit • Corporate debt securities • Municipal securities • U.S. governmental securities • Options • Private funds (spanning private equity, growth equity, venture capital, real estate, real assets, infrastructure, direct lending, and hedged strategies) • Private Placements Each type of security has its own unique set of risks associated with it, and it would not be possible to list all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the potential return of an investment, the higher the risk of loss associated with it. Because some types of investments involve certain additional degrees of risk, they will only be recommended and implemented where the investment is determined to be suitable. Private Funds Astra provides investment advisory services to privately-offered pooled investment vehicles (“Private Fund” or “Private Funds” or collectively, the “Funds”). Private Fund investments are managed in accordance with the investment objectives set forth in each Private Fund’s confidential offering memorandum (“Memorandum”) and such investments are not tailored to the individual needs of any particular limited partner. In return for our investment advisory services, Astra receive is paid management fee that is calculated on a pro rata share of Committed or Invested Capital. The Private Funds are not available for purchase by the general public. Please refer to the partnership documents for more detailed information and requirements. Astra generally requires such investors to make representations concerning their sophistication as investors and their ability to bear the risk of loss of their entire investment under Astra management. Page 7 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Commodity Trading Advice Astra offers strategies that incorporate financial instruments that are commonly associated with commodity trading advisors (“CTAs”) as defined by the Commodity Exchange Act (“CEA”). Effective 12/28/21, Astra registered with the NFA as a Commodity Trading Adviser (“CTA”). In addition, Stephen Buehler registered with the NFA as a Principal, Associated Person and Associated Member. Ed Lalanne registered with the NFA as a Principal and Associated Person. In conjunction with registration as a CTA, Astra has filed for relief through the 4.7 Exemption. This exemption is available to firms, such as Astra, that only offer services to clients that meet the definition of a Qualified Eligible Persons (“QEPs”) in CFTC Regulation 4.7. This exemption offers Astra certain relief from recordkeeping requirements as outlined in 4.7(c). Generally, a Qualified Eligible Person must meet the following two requirements (refer to the CEA for full text of this definition): (i) the investor must be an accredited investor as defined by the SEC. The most common ways for this are to either have a net worth of $1,000,000 or more OR an annual income of $200,000 or more for the last two years OR, combined with a spouse, $300,000 per year for two years. (ii) the investor must meet an additional portfolio requirement, which is having $2,000,000 in securities holdings OR $200,000 in margin on deposit with a Futures Commission Merchant OR a combination of the two (for example, $1,000,000 in securities and $100,000 in margin). In pursuing investment strategies as CTA, Astra may utilize any of the following financial instruments (this list may not be comprehensive): foreign exchange (cash currencies and forward contracts); futures contracts on equity indices (domestic and international indices across developed, emerging and frontier markets); futures contracts on interest rates, commodities and foreign exchange; swaps on interest rates equities and foreign currencies; options on equities, interest rates and foreign currencies; credit default swaps and credit default swap indices; equities (corporate and indices); and corporate, government and municipal bonds. Prior to 12/28/21, Astra was not registered with the NFA or CFTC as a CTA given its position that it was not deemed to be a CTA given Astra limited itself to providing commodity trading advice to 15 or fewer clients and Astra did not publicly hold itself out as a CTA. Accordingly, Astra met the conditions noted in Rule 4.14(a)(10) and Section 4(m)(1) of the CEA whereby it was deemed to be excluded from the definition of a CTA and, thus, not required to register with the NFA and CFTC. Client Assets Under Management (AUM) As of January 1, 2026, Astra had regulatory assets under management (AUM) of $179,551,937. All the assets under management are managed on a discretionary basis and encompass the assets in the private funds and other discretionary accounts for individuals and institutions. Client Assets Under Advisement (AUA) As of January 1, 2026, Astra had regulatory assets under advisement (AUA) of $0. All assets under advisement are managed on a non-discretionary basis and encompass assets in accounts for select individuals and institutions that are invested in third-party managed funds. Information Regarding Potential Conflicts of Interest Page 8 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Although Astra seeks to avoid conflicts of interest, we may have actual or potential conflicts of interest arising from its advisory services. These may include, but are not limited to: • Conflicts related to allocating time and resources between client accounts • Conflicts related to allocating investment opportunities generally and recommending internally-managed funds or strategies including private funds to which Astra serves as investment adviser. For further information on our brokerage and allocation policies, and related conflicts of interest, please refer to Item 12 below. • Conflicts related to investment advisory offerings that charge different fees. Astra has a financial incentive to recommend one strategy instead of another based on the fee that it earns. Clients should evaluate the level and complexity and value of the advisory services to be provided when negotiating the account fee with the Advisor. • Conflicts related to investing in securities recommended to clients and contemporaneous trading of securities (i.e., personal trading) by Astra or its related persons. Please refer to Item 11 for further information. Actual or potential conflicts of interest generally can be addressed in a number of ways, including, but not limited to, the following: • We prohibit the conduct that gives rise to the conflict of interest; • We comply with an impartial standard conduct, which means we must give advice in the best interests of our clients; • We give a received benefit to a client; • We implement procedures to prevent a person from gaining knowledge that may give rise to a conflict; • We establish benchmarks and parameters for conduct that are designed to protect client interests or limit the benefit that creates the conflict of interest; • We disclose the conflict of interest to our clients; and/or • We set a de minimis threshold for benefits that are considered too small to influence conduct and are therefore permitted. Astra has adopted a Code of Ethics. Please refer to Item 11 below for further information on our Code of Ethics. We also have policies and procedures in place to mitigate and address conflicts of interest. We believe that such policies and procedures are reasonably designed to treat clients equitably and to advance the best interests of the clients. The clients' best interest is paramount in any situation involving a conflict of interest. Item 5: Fees and Compensation Investment Advisory Services Depending upon the type of advisory service to be provided, fees will be calculated for such services in one of the following manners: • Percentage of Assets under Management (AUM): Clients will be charged as a percentage of assets under management with us, according to the schedule set forth in the client management agreement between us and the client; or for private funds clients will be charged a management fee based on a percentage of invested or committed capital. Page 9 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  • Percentage of Assets under Advisement (AUA): Clients will be charged as a percentage of assets under advisement with us, according to the schedule set forth in the client management agreement between us and the client. • Flat Fee: Select clients may be charged a flat fee in exchange for contributing investment research and/or trade ideas. The standard fee schedule for accounts subject to a fee based on a percentage of AUM or AUA is detailed below. Aggregate value of the Client’s Account $0 to $1,000,000 $1,000,001 to $5,000,000 $5,000,001 to $10,000,000 >$10,000,000 Fee % 0.95% 0.85% 0.75% 0.65% The fee charged to the client will be set forth and identified in an agreement between Astra and that client. We may negotiate other fee schedules depending on the size of the account, type of account, the level of client service required and other factors we consider relevant, including timing of client relationship. We typically do not impose a minimum account size or a set minimum annual fee for investment advisory services. For the fee charged as a percentage of assets under management or assets under advisement, fees are charged quarterly in arrears based on the average daily market value of the client's account(s), as determined by the custodian(s), fund managers and/or by an aggregating technology service vendor. For private funds, management fees will be charged as described in the offering documents. Astra does not charge Advisory Fees on assets invested in private funds managed by Astra where Astra earns a management fee as this would result in a double charge. For any investment holdings that are not valued daily, the average daily market value calculation will use the most recent valuations available at the time of billing. For the avoidance of doubt, for certain illiquid funds that are valued quarterly, the valuation for a given day will be the most recent quarter-end valuation that is available. Therefore, absent an intra-period valuation update, the valuation may be held static for the entire period. To illustrate such an instance, for a 2nd quarter billing cycle of April 1 to June 30, the fee for an investment that prices quarterly would be based off the March 31 valuation, given the June 30 valuation may not be available until after the billing cycle is completed. Absent an-intra period valuation update, the March 31 price of this investment would be held static for each day from April 1 to June 30. Cash and assets which are invested in shares of mutual funds, exchange-traded funds, non- exchange traded funds (including BDCs, REITs), individual securities, collective trusts, unit investment trusts and/or closed-end funds and private funds not advised by Astra and private placements shall be included in the calculation of the value of the client's assets under management or advisement, as applicable, for purposes of computing our fee. A client's margin balance is typically included when calculating assets under management with Astra. This will be in addition to any margin interest being paid by the client. For partial quarters, fees are pro-rated based on the policy to bill in arrears and based on the Page 10 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  average daily market value of each account. Further, if there is a deposit to or withdrawal from a client's account(s), our fees will be prorated based on this methodology. To the extent any transactions happen to fall outside of this methodology, all unearned fees will be refunded to the client in the event the client terminates our services. Unless other arrangements are made, fees are typically collected via ACH payment, check, credit card or direct debit to a custodial account. Fees collected via ACH or credit card are processed using a third-party software vendor. In addition, clients must independently approve and initiate each payment by ACH or credit card. Astra does not have access to the banking or credit card information for any client nor does it have an ability to auto-draft fees via ACH, check or credit card. In addition, invoices for such fees are sent to the clients. The client is responsible for verifying the accuracy of the fee calculation. In addition, upon the client’s direction, fees could also be directly debited from a client's custodial account(s). If a client chooses this approach, each client is required to provide the qualified custodian of the client's account(s) written authorization to deduct the fees described. In addition, invoices for such fees are sent to the Custodian(s) and Custodians send quarterly statements to clients. The custodian sends the client a statement, at least quarterly, indicating the amount of our fees and all amounts disbursed from the account to Astra for our fees. The client is responsible for verifying the accuracy of the fee calculation, as the custodian will not verify the calculation. Payment of fees may result in the liquidation of client's securities if there is insufficient cash in the client's account(s). Depending on agreed upon billing terms, clients may not receive from Astra an account statement or a fee invoice. Only the custodians' account statement will be sent to clients. Asset based fees are always subject to the management agreement between the client and Astra, and we generally retain the right to amend our fee schedule with 30 days prior written notice to the client. Clients have the option to purchase investment products that the adviser recommends through other brokers or agents and are not affiliated with the adviser. General Information An investment management agreement may generally be terminated at any time, by Astra or the client, for any reason upon prior written notice. The timing is specified in the client management agreement between Astra and the client. In addition, if a client receives this Brochure at the time the client enters into the investment management agreement, the client has the right to terminate the agreement within 5 business days after entering into it by giving written notice of such termination to Astra. Astra is deemed to have taken custody or possession of client funds or securities in conjunction with the discretionary management of the private funds. In addition, Astra may be deemed to have limited custody of client funds to the extent that it deducts fees directly from the client's account(s). All fees paid to Astra are separate and distinct from fees and expenses charged by any mutual fund, exchange-traded funds, closed-end funds and any externally-managed private funds. Fund fees Page 11 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  are described in the respective fund's prospectus or offering memorandum. These fees will generally include management fees, various expenses, possible distribution fees and performance fees (for private funds). The client should review all fees being charged on its investments and those charged by Astra to fully understand the total amount of fees to be paid by the client and to evaluate the advisory services being provided. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, trade execution fees, deferred sales charges, odd-lot differentials, transfer taxes, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Please refer to Item 12 (Brokerage Practices) in this Brochure for additional information. Clients may incur certain pass-through charges related to technology services or other vendors that Astra utilizes in the performance of its investment advisory and portfolio management services. Such an expense may include, but not be limited to, pass-through costs of account and data aggregation vendor fees. These vendors allow clients to aggregate their account and financial holdings in a single dashboard via systematic data feeds. Astra has a fiduciary duty to all its clients. Astra is also a fiduciary to advisory clients that are individual retirement accounts (IRAs of all types) pursuant to ERISA or the Internal Revenue Code ("IRC"). Astra is subject to specific duties and obligations under ERISA and the IRC that include among other things, restrictions concerning certain forms of conflicted compensation. To avoid engaging in prohibited transactions, Astra may only charge fees for investment advice (i) about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or (ii) about products for which our firm and/or our related persons receive commissions or 12b-1 fees if such commission and fees are used to offset Astra advisory fees. Clients should be aware that similar advisory services may or may not be available from other investment advisors for similar or lower fees. Private Funds As discussed in Item 4, Astra provides investment advisory services to privately offered pooled investment vehicles. In return for our investment advisory services, we receive a management fee, calculated and accrued quarterly, and payable to Astra in advance on a pro rata share of Committed or Invested Capital. The private fund does not charge a performance-based fee. Astra is deemed to have taken custody or possession of client funds or securities, most notably in conjunction with the discretionary management of the private funds. Astra does not charge Advisory Fees on assets invested in private funds managed by Astra where Astra earns a management fee as this would result in a double charge. Item 6: Performance-Based Fees Astra does not charge performance-based fees. Performance-based fees are fees which are based on the share of capital gain or appreciation of a client's account. Page 12 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Item 7: Types of Clients Astra may offer its services to individuals, high net worth individuals, corporations and other business entities, pension and profit-sharing plans, endowments, foundations, charitable organizations, investment advisors, estates and trusts. Astra also acts as investment adviser to Private Funds. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Astra may use one or more of the following methods of analyses and/or implement one or more of the following investment strategies when providing investment advice to clients, subject to the clients' investment objectives, risk tolerance, time horizons and stated guidelines: • Fundamental Analysis. We attempt to measure the intrinsic value of a security or investment by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the investment is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). We look at historical and present financial statements of the company, annual reports, governmental filings and/or other financial information. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security or investment can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock or investment. Individualized analysis of underlying documentation can vary. • Technical Analysis. We may analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not necessarily consider the underlying financial condition of a company or investment. This presents a risk in that a poorly managed or financially unsound company or investment may underperform regardless of market movement. Past performance is not a guarantee of future performance. • Quantitative Analysis. We may use mathematical models and statistical modeling in an attempt to obtain more accurate measurements of a company's or investment’s quantifiable data, such as the value of a share price or earnings-per-share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Quantitative analysis does not necessarily factor in all variables. • Qualitative Analysis. We may subjectively evaluate non-quantifiable factors such as broad macroeconomic trends or more specific factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes in value based on that data. A risk is using qualitative analysis is that our subjective judgment may prove incorrect. Astra' analysis methods rely on the assumption that the investment vehicles which we recommend Page 13 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  for our clients, the companies whose securities we purchase and sell on behalf of our clients, the rating agencies that review these securities, and other publicly or privately available sources of information about these securities, are providing accurate, timely and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate, misleading or untimely information. This is an ongoing risk with regard to all the strategies discussed below. Investment Strategies Astra may use the following strategies in managing client accounts. Investment strategies and advice may vary depending upon each client's specific financial situation. We may manage households and accounts on a goals-based approach so not every account is diversified. Certain accounts may be more heavily weighted in one investment when compared to another account as determined by the specific goals and financial circumstances of each client. As such, we determine investments and allocations based upon the client's predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. The client's restrictions and guidelines may affect the composition of the client's portfolio. • Targeted Investment Goals via Third-Party Manager/Fund Selection - Registered and Unregistered (Private) Funds. Rather than constructing a diversified portfolio, we may provide clients with a service whereby we identify and recommend an investment that aims to provide a specific investment objective. The investment fund or funds are typically managed by third-party asset managers who we deem to have a specialization in a given investment strategy or strategies. We look at the experience and track record of the manager of the fund with an aim of determining if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. A risk of fund analysis is that, as in all investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client's portfolio. Investment strategies that we may pursue via third-party managed funds may include but not be limited to private equity, growth equity, venture capital, infrastructure, real assets, real estate, private credit, asset backed finance, and hedged strategies. There are risks associated with strategies of this nature including but not limited to market risk, manager risk, illiquidity risk, and risks due to use of leverage. These risks are detailed in greater • Long-term Purchases (Buy & Hold). We may purchase securities or investments with the idea of holding them in the client's account for some period of time, often a year or longer. Typically, we employ this strategy when we believe the securities or investments to be currently undervalued, and/or we want exposure to a particular asset class over time, regardless of the short-term projections. A risk in a long-term purchase strategy is that by holding the security or investments for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security or investments may decline sharply in value before we make the decision to sell. However, in certain circumstances, it may be appropriate to sell a security or investments, although held only for a short term, to capture any gain or avoid a loss. Page 14 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  • Short-term, Tactical Purchases. When utilizing this strategy, we purchase securities or investments with the idea of selling them when they reach or pass their price targets. We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities or investments we purchase. • Option-Related Strategies. We may use options as an investment strategy outright or in conjunction with the other investment strategies noted previously. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. We may also utilize structured notes, closed end funds or mutual funds that utilize options strategies. The two types of options are calls and puts. A call gives us the right to buy an asset at a certain price within a specific period of time. We may buy a call if we have determined that the stock will increase substantially before the option expires. A put gives us the holder the right to sell an asset at a certain price within a specific period of time. We may buy a put if we have determined that the price of the stock will fall before the option expires. We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use "covered calls," in which we sell an option on a security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a "spreading strategy," in which we purchase two or more option contracts (for example, a call option that you buy and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time and other factors. Option writing is not a fundamental part of Astra 's overall investment strategy, but we may use this strategy occasionally when given authority and we determine that it is suitable given a client's stated investment objectives and tolerance for risk. • Discretionary Macro Strategies. Discretionary macro strategies are primarily reliant on the evaluation of global market data and events (including actions by central banks) and the relative relationships and influences these events have on asset classes across global markets and asset classes. This strategy is one that is heavily influenced by top-down analysis of macroeconomic variables. This strategy may involve trading actively in developed and emerging markets, focusing on both absolute and relative levels on equity markets, interest rates/fixed income markets, currency and commodity markets; frequently employing spread trades to isolate a differential between instrument identified to be inconsistent with expected value. Portfolio positions typically are predicated on the evolution of investment themes we expect to materialize over a relevant timeframe, which in many cases contain contrarian or volatility focused components. A risk of this strategy is that we may misinterpret global data or macroeconomic trends or their impact on asset prices and, as a result, lose value in our attempt to create a positive return for our clients. In addition, a risk of this strategy is that it often involves the use of derivatives and other securities and instruments that are relatively complex when compared to those used in more traditional investment strategies. Risk of Loss Investing involves a risk of loss. Clients should be prepared to bear investment loss, including the Page 15 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  loss of the original principal. Clients should never presume that future performance of any specific investment or investment strategy will be profitable. Further, there may be varying degrees of risk depending on different types of investments and investment strategy employed. Clients should know that all investments carry a certain degree of risk ranging from the variability of market values to the possibility of permanent loss of capital. Although certain investments seek principal protection, asset allocation and investment decisions may not achieve this goal in all cases. There is no guarantee a portfolio will meet a target return or an investment objective. Risks to capital include, but may not be limited to, changes in the economy, market volatility, company results, industry sectors, accounting standards, changes in interest rates and/or geopolitical factors. Investments are generally subject to risks inherent in governmental actions, exchange rates, inflation, deflation, and fiscal and monetary policies. Market risks include changes in market sentiment in general and styles of investing. Diversification will not protect an investor from these risks and fluctuations. Astra does not engage in high-frequency trading activities or algorithmic trading strategies. Depending on the investment strategy employed for a given client, additional risks may include: General Portfolio Risks Market Risk: Economies and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region will adversely impact markets or issuers in other countries or regions. Securities or investment in any one strategy may underperform in comparison to general financial markets, a particular financial market or other asset classes, due to a number of factors, including inflation or expectations for inflation), deflation (or expectations for deflation) interest rates, global demand for particular products or resources, market instability, debt crises and downgrades, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs and related geopolitical events. In addition, the value of a strategy's investments may be negatively affected by the occurrence of global events such as war, terrorism, environmental disasters, natural disasters or events, country instability, and infectious disease epidemics or pandemics. For example, if the stock market or the value of an individual company goes down, the value of a client portfolio could decline. Stocks and other investments are susceptible to general fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. Issuer Risk: There is always a certain level of issuer or industry specific risk that is inherent in each investment. Although this risk can be reduced through appropriate diversification, it cannot be eliminated. There is the risk that the issuer will perform poorly or have its value reduced based on factors specific to the issuer or its industry. If the issuer experiences credit issues or defaults on debt, the value of the issuer may be reduced. Management Risk: Investments managed by Astra and third-party asset managers vary with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians and exchanges through which Page 16 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over- the-counter ("OTC") transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. Liquidity Risk. Investments in some equity and privately placed securities, structured notes or other instruments may be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity may also cause the value of investments to decline and the illiquid investments may also be difficult to value. Geographic and Sector Risks: Certain strategies and funds concentrate their investments in a region, small group of countries, an industry or economic sector, and as a result, the value of the portfolio may be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. Foreign & Emerging Markets Risks: Non-U.S. investments, currency and commodity investments may contain additional risks associated with government, economic, political or currency volatility. Emerging markets can experience high volatility and risk in the short term. Investments in securities of foreign issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets, which may have relatively unstable governments and less-established market economies than those of developed countries. Emerging markets may face greater social, economic, regulatory and political uncertainties. These risks make emerging market securities more volatile and less liquid than securities issued in more developed countries. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Currency Risk. Changes in foreign currency exchange rates will affect the value of investments. Generally, when the value of the U.S. dollar rises in value relative to a foreign currency, an investment impacted by that currency loses value because that currency is worth less in U.S. dollars. Currency exchange rates may fluctuate significantly over short periods of time for a number of reasons, including changes in interest rates. Devaluation of a currency by a country’s government or banking authority also will have a significant impact on the value of any investments denominated in that currency. Currency markets generally are not as regulated as securities markets, may be riskier than other types of investments and may increase the volatility Page 17 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  of a portfolio. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you 18 were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. Cyber Security Risk. As the use of technology has become more prevalent in the course of business, we become more susceptible to operational and financial risks associated with cyber security, including: theft, loss, misuse, improper release, corruption and destruction of, or unauthorized access to, confidential or highly restricted data relating to Astra and its clients, and compromises or failures to systems, networks, devices and applications relating to the operations of Astra and its service providers. Cyber security risks may result in financial losses to Astra and its clients; the inability of Astra to transact business with its clients; delays or mistakes in materials provided to clients; the inability to process transactions with clients or other parties; violations of privacy and other laws; regulatory fines, penalties and reputational damage; and compliance and remediation costs, legal fees and other expenses. Because of the inherent risk of loss associated with investing, we are unable to represent, guarantee or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. Recommendation of Particular Types of Securities, Investments and Investment Funds We may manage and advise on a variety of investment securities, investments and funds, as appropriate, since each client has different needs and different tolerance for risk. Each type of security, investment or fund has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Risks that Apply Primarily to Equity Investments Equity Securities Risk. Investments in equity securities (such as stocks) may be more volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements may result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Growth Investing Risk. Growth investing attempts to identify companies that we or a third-party manager believe could experience rapid earnings growth relative to value or other types of stocks. The value of these stocks generally is much more sensitive to current or expected earnings than stocks of other types of companies. Short-term events, such as a failure to meet industry earnings expectations, can cause dramatic decreases in the growth stock price compared to other types of stock. Growth stocks may trade at higher multiples of current earnings compared to value or other Page 18 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  stocks, leading to inflated prices and thus potentially greater declines in value. Value Investing Risk. Value investing attempts to identify companies that are undervalued according to a consensus estimate of their true worth. We or a third-party manager may select stocks at prices that that are believed to be temporarily low relative to factors such as the company’s earnings, cash flow or dividends. A value stock may decrease in price or may not increase in price as anticipated if other investors fail to recognize the company’s value or the factors that are believed will cause the stock price to increase do not occur. Smaller Companies Risk. Certain strategies invest in securities of smaller companies. Investments in smaller companies may be riskier than investments in larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies may be more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an account’s investments. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. Risks that Apply Primarily to Fixed Income and Other Debt Instruments Interest Rate Risk. Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. Variable and floating rate securities are generally less sensitive to interest rate changes than fixed rate instruments, but the value of variable and floating rate securities may decline if their interest rates do not rise as quickly, or as much, as general interest rates. Many factors can cause interest rates to rise. Some examples include central bank monetary policy (such as an interest rate increase by the Federal Reserve), rising inflation rates and general economic conditions. Credit Risk. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. Such default could result in losses. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain credit securities or instruments are rated in the lowest investment grade category. Such securities or instruments are also considered to have speculative characteristics similar to high yield securities, and issuers or counterparties of such securities or instruments are more vulnerable to changes in economic conditions than issuers or counterparties of higher grade securities or instruments. Prices of fixed income securities may be adversely affected and credit spreads may increase if any of the issuers of or counterparties to such investments are subject to an actual or perceived deterioration in their credit quality. Credit spread risk is the risk that economic and market conditions or any actual or perceived credit deterioration of an issuer may lead to an increase in the credit spreads (i.e., the difference in yield between two securities of similar maturity but different credit quality) and a decline in price of the issuer’s securities. Page 19 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Government Securities Risk. Securities not issued or guaranteed by the U.S. government or its agencies and instrumentalities (such as the Government National Mortgage Association ("Ginnie Mae"), the Federal National Mortgage Association ("Fannie Mae") or the Federal Home Loan Mortgage Corporation ("Freddie Mac"). U.S government securities are subject to market risk, interest rate risk and credit risk. Securities, such as those issued or guaranteed by Ginnie Mae or the U.S. Treasury, that are backed by the full faith and credit of the United States are guaranteed only as to the timely payment of interest and principal when held to maturity. Notwithstanding that these securities are backed by the full faith and credit of the United States, circumstances could arise that would prevent the payment of principal and interest. Securities issued by U.S. government related organizations, such as Fannie Mae and Freddie Mac, are not backed by the full faith and credit of the U.S. government and no assurance can be given that the U.S. government will provide financial support. High Yield Securities Risk. Securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed (known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Risks that Apply Primarily to Exchange Traded Funds, Mutual Funds and Private Funds Exchange Traded Funds and Mutual Funds Risk: The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will incur additional costs associated with ETFs and mutual funds. Private Fund Risk: There are risks associated with investing in privately managed funds. This risks include but are not limited to valuation risk, illiquidity risk and non-marketability of investments interests. Clients should read the offering documents of private funds and understand the risks prior to investing (see Item 5). Risks That Apply Primarily to Derivatives Investments and Short Sales Derivatives Risk: Derivatives, including forward currency contracts, futures, options and commodity-linked derivatives and swaps, may be riskier than other types of investments because they may be more sensitive to changes in economic and market conditions, and could result in losses that significantly exceed the investor’s original investment in the derivative. Many derivatives create leverage thereby causing a portfolio to be more volatile than it would have been if it had not been exposed to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the derivative counterparty will not fulfill its contractual obligations), including the credit risk of the derivative counterparty. Certain derivatives are synthetic instruments that attempt to replicate the performance of certain reference assets. With regard to such derivatives, an investor does not have a claim on the reference assets and is subject to enhanced counterparty risk. Derivatives may not perform as expected, so an investor may not realize the intended benefits. The possible lack of a liquid secondary market for derivatives and the resulting ability to sell or otherwise close a derivatives position could expose a portfolio to losses. When used for hedging, the change in value of a derivative may not correlate as expected with what is being hedged. In addition, given their complexity, derivatives expose an investor to risks of mispricing or improper valuation. Short Selling Risk: A portfolio will incur a loss as a result of a short sale if the price of the security Page 20 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  sold short increases in value between the date of the short sale and the date on which the portfolio re purchases the security. In addition, if the security sold short was first obtained by borrowing it from a lender, such as a broker or other institution, the lender may request, or market conditions may dictate, that the security sold short be returned to the lender on short notice, and the portfolio may have to buy the security sold short at an unfavorable price. If this occurs, any anticipated gain to the portfolio will be reduced or eliminated or the short sale may result in a loss. The portfolio’s losses are potentially unlimited in a short sale transaction. Short sales are speculative transactions and involve special risks, including greater reliance on the Adviser’s ability to accurately anticipate the future value of a security. Furthermore, a portfolio may become more volatile because of the form of leverage that results from taking short positions in securities. Risks That Apply Primarily to Real Estate Investments Real Estate Risk: There are certain risks associated with the development, construction and/or ownership of real estate and the real estate industry in general, including: the burdens of ownership of real property; local, national and international economic conditions (which may be adversely affected by industry slowdowns, decreases in government spending and changing government policies); the supply and demand for properties; the financial condition of tenants, buyers and sellers of properties; changes in interest rates and the availability of mortgage funds which may render the sale or refinancing of properties difficult or impracticable; labor costs; construction materials costs; changes in environmental laws and regulations, planning laws, fiscal and monetary policies and other governmental rules; environmental claims arising with respect to properties acquired with undisclosed or unknown environmental problems or with respect to which inadequate reserves have been established; changes in real property tax rates; changes in energy prices; negative developments in the economy that depress travel activity; uninsured casualties; force majeure acts, terrorist events, under-insured or uninsurable losses; and other factors that are beyond the reasonable control of the Adviser. In addition, real estate assets are subject to long-term cyclical trends that contribute to significant volatility in values. Many of these factors could cause fluctuations in occupancy rates, development costs, rent schedules, or operating expenses, causing the value of an investment to decline and negatively affect an investment’s returns. The value of investments may fluctuate significantly due to these factors among others and may be significantly diminished in the event of a sudden downward market for real estate and real estate-related assets. The returns available from investments depend on the amount of income earned and capital appreciation generated by the relevant underlying properties, as well as expenses incurred in connection therewith. If properties do not generate income sufficient to meet operating expenses, including amounts owed under any third- party borrowings and capital expenditures, returns will be adversely affected. In addition, the cost of complying with governmental laws and regulations and the cost and availability of third-party borrowings may also affect the market value of and returns from real estate and real estate related investments. Returns would be adversely affected if a significant number of tenants were unable to pay rent or if properties could not be rented on favorable terms. Certain significant fixed expenditures associated with purchasing properties (such as third-party borrowings, taxes and maintenance costs) may stay the same or increase even when circumstances cause a reduction in returns from properties. REITs Risk: The value of real estate securities in general, and REITs in particular, are subject to the same risks as direct investments in real estate and mortgages, and their value will be influenced by Page 21 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  many factors including the value of the underlying properties or the underlying loans or interests. The underlying loans may be subject to the risks of default or of prepayments that occur later or earlier than expected and such loans may also include so-called "subprime" mortgages. The value of these securities will rise and fall in response to many factors, including economic conditions, the demand for rental property, interest rates and, with respect to REITs, the management skill and creditworthiness of the issuer. In particular, the value of these securities may decline when interest rates rise and will also be affected by the real estate market and by the management of the underlying properties. REITs may be more volatile and/or more illiquid than other types of equity securities. Risks That Apply Primarily to Private Equity Investments Risks of Corporate Finance, Venture Capital and Growth Investments: Investments made in connection with acquisition transactions are subject to a variety of special risks, including the risk that the acquiring company has paid too much for the acquired business, the risk of unforeseen liabilities, the risks associated with new or unproven management or new business strategies and the risk that the acquired business will not be successfully integrated with existing businesses or produce the expected synergies. Venture and growth companies may be in a conceptual or early stage of development, may not have a proven operating history, may have products that are not yet developed or ready to be marketed, or may not have an established market. Companies may face significant fluctuations in operating results, may need to engage in acquisitions or divestitures of assets to compete successfully or survive financially, may be operating at a loss, may be engaged in a rapidly changing business with products subject to a substantial risk of obsolescence, may require substantial additional capital to support their operations, to finance expansion or to maintain their competitive position, or otherwise may have a weak financial condition. Companies may be highly leveraged and, as a consequence, subject to restrictive financial and operating covenants. The leverage may impair the ability of these companies to finance their future operations and capital needs. As a result, these companies may lack the flexibility to respond to changing business and economic conditions, or to take advantage of business opportunities. Companies may face intense competition, including competition from companies with far greater financial resources, more extensive development, manufacturing, marketing and other capabilities, and a larger number of qualified managerial and technical personnel. Specific Risks of Secondary Investments: The market for secondary fund investments is limited and competitive. Identifying attractive investment opportunities and, in the case of pooled vehicles, favorably priced portfolios and the right investment managers, is difficult and involves a high degree of uncertainty. Illiquidity of Private Equity Investments: Private equity funds are highly illiquid, long-term investments. In addition, other legal, contractual or practical limitations may limit the ability to sell private equity investments. Sales also may be limited by financial market conditions, which may be unfavorable for sales of securities of particular issuers or issuers in particular markets. These limitations on liquidity of private equity investments could prevent a successful sale or result in the delay of any sale or reduction in the amount of proceeds that might otherwise be realized. Risks That Apply Primarily to Real Estate, Infrastructure Transportation, Special Situations and Private Equity Investments Page 22 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Long-term Commitment Required: A commitment to a fund is typically a long-term investment. The expected term of each closed-ended fund vehicle can generally be up to fifteen years. There is a substantial period of time during which investors in a closed-ended fund vehicle may be obligated to provide capital without receiving any return and regardless of the performance of the funds. Investors should be willing to hold their interests until the liquidation of the closed-ended fund. An open-ended fund generally may draw down the capital commitments of investors at any time during their term. Additionally, certain open-ended funds may be relatively illiquid over an extended period of time and in these cases investors will be required to bear the financial risk of their investment for such time. Lack of Control by Investors: Investors generally will not have the ability to select, veto or cause the sale or other disposition of any investments by the funds or client accounts or to determine the timing of any takedown, distribution or liquidation of the funds in which a client invests directly or indirectly. Carried Interest and Other Fees Allocated or Payable to Third-Party Managers: To the extent a client invests in investment funds managed by third-party managers, the general partners or managers of such funds typically will receive a carried interest or performance fee based on a percentage of realized net profits. Generally Cash balances are typically invested daily in interest-bearing money market accounts or in bank sweep accounts at the respective Custodian. Our strategies and investments may have unique and significant tax implications. Astra will manage portfolios with an awareness of tax implications, but long-term wealth compounding is our primary consideration. Regardless of account size or other factors, Astra strongly recommends that its clients continuously consult with a tax professional prior to and throughout the investing of clients' assets. Each client is responsible for contacting his/her tax advisors to determine which cost basis accounting method is the right choice for the client. Clients should provide Astra with written notice of a client's selected accounting method, and Astra will alert the client's custodian of the individually selected accounting method. Clients should be aware that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Item 9: Disciplinary Information Astra is required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of us, our business or the integrity of our management or associated persons. Neither Astra, nor any of our associated persons has any reportable disciplinary events to disclose. Page 23 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Item 10: Other Financial Industry Activities and Affiliations Astra offers strategies that incorporate financial instruments that are commonly associated with commodity trading advisors (“CTAs”) as defined by the Commodity Exchange Act (“CEA”). Effective 12/28/21, Astra registered with the NFA as a Commodity Trading Adviser (“CTA”). In addition, Stephen Buehler registered with the NFA as a Principal, Associated Person and Associated Member. Ed Lalanne registered with the NFA as a Principal and Associated Person. In conjunction with registration as a CTA, Astra has filed for relief through the 4.7 Exemption. This exemption is available to firms, such as Astra, that only offer services to clients that meet the definition of a Qualified Eligible Persons (“QEPs”) in CFTC Regulation 4.7. This exemption offers Astra certain relief from recordkeeping requirements as outlined in 4.7(c). Astra is not a registered broker-dealer, commodity pool operator, or futures commission merchant, and does not have an application to register for any of the same pending. Astra does not recommend investment products in which it receives any form of compensation from the separate account manager or unaffiliated investment product sponsor. Astra always seeks to act in the best interest of the client, and any person providing investment advice on behalf of the firm must seek to act in the best interests of the client and put that client's interests ahead of the individual's own interests. Astra acts as the investment adviser to Private Funds. The Managing Member of the Private Fund is also an Astra affiliate. This presents a conflict of interest in situations where interests in the Fund may be recommended to qualified clients or prospects. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Astra has adopted a Code of Ethics that sets forth high ethical standards of business and professional conduct which we require our employees to follow. The Code of Ethics outlines proper conduct related to all services provided to clients by Astra and our associated persons and includes guidelines for compliance with applicable laws and regulations governing our practice. Our goal is always to protect our clients’ interests and demonstrate our commitment to our fiduciary duties of honesty, good faith and fair dealing. Personal Securities Transactions and Interests Through its professional activities, Astra and its supervised persons are exposed to potential conflicts of interest and the Code of Ethics contains provisions designed to mitigate certain of these potential conflicts by governing the personal securities transactions of certain of its employees, officers and directors. In particular, the Code of Ethics governs the conduct of certain "access persons" in circumstances where Astra or access persons may desire to purchase or sell securities for their personal accounts that are identical to those recommended by Astra to its clients. For these Page 24 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  purposes, the Code of Ethics defines an "access" person as a supervised person of Astra that (1) has access to nonpublic information regarding any clients' purchase or sale of securities, (2) has access to nonpublic information regarding the portfolio holdings of any fund the adviser or its control affiliates manage or sponsor, or (3) is involved in making securities recommendations (or has access to such recommendations) to clients that are nonpublic. Access persons' trades must be executed in a manner consistent with the following principles: • The interests of client accounts will at all times be placed first. • All personal securities transactions will be conducted in such manner as to avoid any actual or potential conflict of interest or any abuse of an individual's position of trust and responsibility. • Access persons must not take inappropriate advantage of their positions. • Preclearance of access persons' transactions in securities in a limited offering or private placement is required. Access persons must submit quarterly reports regarding securities transactions and newly opened accounts, as well as annual reports regarding holdings and existing accounts. Astra monitors access persons' personal trading activity at least quarterly to ensure compliance with internal control policies and procedures and our Code of Ethics. The Code of Ethics does not prevent or prohibit access persons from trading in securities that we may recommend or in which we may invest client assets, but rather prescribes the governing principals relative to the same (see above). As such, it is possible that (1) Astra or its access persons could recommend to clients, or buy or sell for client accounts, securities in which one or more access persons (including Astra or its affiliates) has a material financial interest, (2) access persons (including Astra or its affiliates) could invest in the same securities (or related securities) that we recommend to clients, or (3) Astra (including its affiliates) and its access persons could recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that one or more access persons (including Astra or its affiliates) buys or sells the same securities for its own account. This presents a potential conflict in that the access person might seek to benefit himself or herself from this type of trading activity in the same securities, either by trading for personal accounts in advance of client trading activity, or otherwise. All such activity must be in strict adherence with our Code of Ethics and must fundamentally place the clients' interests first. Moreover, it is our policy that neither the firm nor its associated persons will have priority over a client's account(s) in the purchase or sale of securities. We may also combine orders to purchase securities for Astra, its associated persons and/or their families with a client's order to purchase securities ("block trading"). Please refer to Item 12 for more information on block trading. A conflict of interest may exist in these events because we have the ability to trade ahead of clients and may potentially receive more favorable prices (for Astra, its associated persons and/or their families) than the client will receive. To eliminate this conflict of interest, we will make reasonable attempts to trade securities in client accounts at or prior to trading the securities in Astra accounts, or accounts of associated persons and/or their families. Trades executed the same day will likely be subject to an average pricing calculation. Moreover, it is our policy that neither Astra nor its associated persons will have priority over a client's account(s) in the purchase or sale of securities. Neither Astra nor its associated persons has any material financial interest in client transactions beyond the provision of investment advisory services or other services as disclosed in this Page 25 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  Brochure. Astra does not engage in principal trading (i.e., the practice of selling stock to advisory clients from our inventory or buying stocks from advisory clients into our inventory). Nor does the firm engage in agency cross transactions. Stephen Buehler serves as an independent director on the Board of Directors of Braiin Ltd., which as of February 12, 2026 is traded as a public security listed on the Nasdaq under ticker “BRAI”. In this role, Stephen Buehler could have access to material non-public information. To mitigate the conflict and prevent insider trading risks (under Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, as applicable to advisers via fiduciary duties), Astra strictly prohibits:  Any purchase, sale, or holding of Braiin Ltd. securities (including derivatives or related instruments) by: Immediate family members living in the same household. o Firm personnel (including owners, employees, and supervised persons). o o Clients in any advised accounts (discretionary or non-discretionary).  Exceptions: o Trading may be conducted by Stephen Buehler in accordance with Section 16 which requires formal filings of Forms 3, 4 and 5 and in accordance with any Rule 10b-5 plan as applicable. o Any other trading must be pre-approved by the CCO in writing for de minimis or legacy holdings, subject to immediate divestiture plans. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the e-mail or phone number listed on the cover page of this Brochure. Item 12: Brokerage Practices Astra will generally not allow advisory clients to determine the broker-dealer to use and the commission costs that will be charged to these clients for securities transactions. Order Aggregation/Block Trading/Allocations Astra' advice to certain clients and the action of Astra for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his/her applicable investment objective, guidelines, risk tolerance and circumstances. Thus, any action of Astra with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice or actions of Astra to or on behalf of other clients. Astra acts in accordance with our duty to seek best price and execution and will not continue any arrangements if we determine that such arrangements are no longer in the best interest of our clients. As Astra may be managing accounts with similar investment objectives, Astra may aggregate orders Page 26 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  for securities for such accounts. In this event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by Astra in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. Astra' allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account clients' best interests. Astra will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. Astra will aggregate, i.e., "block," trades where possible and when advantageous to clients. We must reasonably believe that the order aggregation will benefit and will enable us to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Astra will block trades among clients whose accounts can be traded at a given broker-dealer. Astra' associated persons may be included in a block trade on the same terms and conditions as Astra' clients. Blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, as long as transaction costs are shared equally and on a pro-rata basis between all accounts included in the block. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended exposure. All clients participating in each aggregated order will generally receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro-rata portion of commissions, provided, however, that an adjustment may be appropriate in some circumstances. Prior to entry of an aggregated order, each client account participating is identified in the order and the proposed allocation of the order, upon completion, to those clients. If the order cannot be executed in full at the same price or time, the securities purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. Our client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. Funds and securities for aggregated orders are clearly identified in our records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. To minimize performance dispersion, "strategy" trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if Astra believes that a larger size block trade would lead to best overall price for the security being transacted. Page 27 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  All allocations will be made prior to the close of business on the trade date. In the event an order is "partially filled," the allocation will be made in the best interests of all the clients in the order, taking into account all relevant factors including, but not limited to, the size of each client's allocation, clients' liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is "over-filled." Transactions for any client account may not be aggregated for execution if the practice is prohibited by the client. Clearing & Custody Astra has custodial and clearing relationship with various custodians. These custodians include Charles Schwab and Interactive Brokers (collectively “Custodians”). Atlantic Capital Bank serves as a depository institution for the assets of the private funds. Custodians provide Astra with access to institutional trading and operations services, which typically are not available to retail customers. These services are generally available, without cost, to financial advisory firms who maintain a minimum threshold of client assets. Services provided by Custodians may include research (including mutual fund research, third- party research, and proprietary research), brokerage, clearing, custody, and access to mutual funds and other investments that are available only to institutional investors or would require a significantly higher minimum initial investment. In addition, Custodians may make available software and other technologies that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution; provide research, pricing information, quotation services, and other market data; assist with contact management; facilitate payment of fees to Astra from client accounts; assist with performance reporting; facilitate trade allocation; and assist with back-office support, record-keeping, and client reporting. Custodians may also provide access to financial planning software, practice management consulting support, best execution assistance, consolidated statements assistance, educational and industry conferences, marketing and educational materials, technological and information technology support, and corporate discounts. Many of these services may be used to service all or a substantial number of Astra 's clients' accounts, including accounts not maintained at Custodians. We may be eligible for a specific schedule of fees based upon our assets under management with Custodians. We have no discretion to determine the commissions charged by Custodians. Custodians may also provide Astra with other services intended to help Astra manage and further develop its business enterprise, including assistance in the following areas: consulting, publications and presentations, information technology, business succession, and marketing. In addition, Custodians may make available or arrange and/or pay for these types of services provided by independent third parties, including regulatory compliance. While Astra does not presently receive any such benefits, in the event that such services are received in the future, it is Astra’ policy that all "soft dollar" benefits received from Custodians must be eligible research and brokerage services as defined under section 28(e) of the Securities Exchange Act of 1934. As stated below and in Item 14, Custodians may also make available to Astra other products and services that benefit Astra, but may not benefit its clients' accounts. Astra, subject to its best execution obligations, may trade outside of Custodians. In the selection of Page 28 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  broker-dealers, Astra may consider all relevant factors, including the commission rate, the value of research provided, execution capability, speed, efficiency, confidentiality, familiarity with potential purchasers and sellers, financial responsibility, responsiveness, and other relevant factors. Astra may retain and compensate Custodians to provide various administrative services that include determining the fair market value of assets held in the account at least quarterly and producing a brokerage statement for client detailing account assets, account transactions, receipt and disbursement of funds, interest and dividends received, and account gain or loss by security as well as for the total account. Astra and Custodians are not affiliates, and no broker-dealer affiliated with Astra is involved in the relationship between Astra and Custodians. Best Execution Depending on the nature of the relationship, Astra may require clients to establish broker accounts with Custodians. Such accounts will be "prime broker" eligible so that if and when the need arises to effect securities transactions from those accounts at broker-dealers other than with Custodians the current custodian ("executing brokers"), such custodian will accept delivery or deliver the applicable security from/to the executing brokers. Custodians may charge a "trade away" fee which is charged against the client's account(s) for each "trade away" occurrence. Astra receives no part of the trade away fees. Other custodians have their own policies concerning prime broker accounts and trade away fees. If the client is receiving discretionary advisory services, Astra, pursuant to the terms of its management agreement with clients, will have discretionary authority to determine which securities are to be bought and sold and the price of such securities to effect such transactions. Astra recognizes that the analysis of execution quality involves a number of qualitative and quantitative factors. Astra will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include, but are not limited, to the following: • The financial strength, reputation and stability of the broker-dealer; • The efficiency with which the transaction is effected; the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); • The availability of the broker-dealer to stand ready to effect transactions of varying degrees of difficulty in the future; • The efficiency of error resolution, clearance and settlement; • Block trading and positioning capabilities; • Performance measurements; • Online access to computerized data regarding customer accounts; • Availability, comprehensiveness, and frequency of brokerage and research services; • Commission rate; • The economic benefit to the clients; and • Related matters involved in the receipt of brokerage services. Consistent with its fiduciary responsibilities, Astra seeks to ensure that clients receive best execution with respect to the clients' transactions by blocking client trades to reduce commissions and transaction costs. To the best of Astra' knowledge and due diligence inquiries, Custodians Page 29 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  provide high-quality execution, and Astra' clients will pay competitive rates for such execution. Based upon its own knowledge of the securities industry, Astra believes that Custodians' commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Trade Errors Where a trade error occurs in a client account due to Astra' error, we will seek to take action with an aim to correct the error or reimburse the client such that the client does not suffer a loss or incur a transaction cost related to that error. If a trade error occurs in a client account due to a Custodians’ error, we will pursue the custodian or broker-dealer to correct the error or reimburse the client such that the client does not suffer a loss or incur a transaction cost related to that error. If the error results in a profit, due to market movement, the client will keep the profit. “Trade Error” shall mean: an administrative error made prior to or during the trade’s execution (e.g., a trader executes an order for the wrong instrument, an incorrect amount or number of an instrument or an order in the opposite direction of what was intended (e.g., a buy instead of a sell order or a sell instead of a buy order in a particular instrument). For the avoidance of doubt, an investment or trade that was made as intended but that happens to result in a loss is not a Trade Error. Brokerage for Client Referrals Astra does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Item 13: Review of Accounts Astra will review client accounts periodically. Accounts are reviewed through various means, including telephone calls, in-person meetings, overall strategy reviews, and/or the review of quarterly statements with clients. However, reviews may also be performed by Astra without meeting or speaking to the client so long as they are based on account objectives and parameters established by clients, which are generally memorialized through their client management agreements. More frequent reviews may also be triggered by a change in the client's investment objectives or risk tolerance, tax considerations, large deposits or withdrawals, large purchases or sales, loss of confidence in investment or fund managers, or changes in the economy or financial markets. Item 14: Client Referrals and Other Compensation Solicitor Arrangements Astra does not currently pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. Page 30 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  It is our policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from any third-party in conjunction with the advisory services we provide our clients. Item 15: Custody Astra is deemed to have custody of certain client funds or securities as defined by rule 206(4)-2 of the Advisers Act and 0780-04-03-.07 of the Rules of Tennessee Department of Commerce and Insurance Division of Securities. Accordingly, Astra has implemented the necessary procedures as determined by these rules. Specifically, Astra has engaged an independent audit firm to (i) perform an audit of the private funds and (ii) perform a surprise examination, as required by 0780-04-03-.07 of the Rules of Tennessee Department of Commerce and Insurance Division of Securities. The results of the audit and surprise examination will be disclosed with regulatory bodies and with clients as required by the governing rules. Upon registration with the SEC, Astra will comply with all applicable custody rules and regulations including the requirement for a Surprise Examination, as relevant. In addition, Astra could be deemed to have limited custody of client funds and securities to the extent that it directly debits advisory and other fees from client accounts. As part of this billing process, if chosen by the client, the independent, qualified custodian of the client's account(s) is advised of the amount of the advisory or other fee to be deducted from the client's account(s). The client will receive account statements from the custodian holding the account(s) at least quarterly. These statements will show all transactions within the account during that reporting period, including the amount of advisory or other fees debited from the client's account(s). Because the custodian does not calculate the amount of the fees to be deducted, it is important for clients to carefully review their account statements to verify the accuracy of the fee calculation, among other things. A client should contact us directly if he/she believes there is an error or has a question regarding an account statement. Item 16: Investment Discretion When a client hires Astra to provide discretionary investment advisory services, we have the authority to place trades, buy and sell securities on the client's behalf, determine the amount of the securities to buy and sell, and determine the nature and type of securities to buy and sell without obtaining a client's consent or approval prior to each transaction. In some cases, we will have the authority to hire and fire third-party money managers. Clients who give us discretionary authority will give Astra a limited power of attorney and/or trading authorization forms to make the above decisions on the client's behalf. In certain situations, agreed to by Astra, Clients may limit our authority by giving us written instructions, restrictions and guidelines via email communication or other written instructions. Page 31 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)  For example, a client may specify that the client's account should not contain investments in a specific industry. Clients can change such instructions, restrictions and guidelines by providing us with written instructions. The most current written instructions will control. We will not accept instructions via text message or similar instant messaging methods. If the client enters into a non-discretionary arrangement with Astra for investment advisory, portfolio management services, or retirement plan consulting, we will obtain the client's approval prior to the arranging or execution of any transactions in the account(s). With such an arrangement, the client has the unrestricted right to decline to implement advice provided by us on a non-discretionary basis. If you do not grant us discretionary authority over your accounts, we are limited to make periodic recommendations to you regarding which securities to be purchased or sold and the size of the transactions. You will ultimately be responsible for implementation of those recommendations and the timing of the transaction. Item 17: Voting Client Securities Regardless of whether we have discretion over a client's account(s), we will not vote proxies on behalf of any client or respond to any legal notices or class action claims on behalf of a client. We will instruct the qualified, independent custodian to forward all proxy materials, legal notices and class action information to the client to review and make his or her own informed decision on how to vote. In the event we receive the proxy material, we will forward them directly to the client by mail or by electronic mail (if the client has authorized electronic communication). Item 18: Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Astra does not have any financial issues that would impair its ability to provide services to clients, and Astra has not been the subject of a bankruptcy petition at any time. We have no additional financial circumstances to report. Page 32 Part 2A of Form ADV: Astra Investment Partners LLC Brochure (dba Astra)