AZIMUT INVESTMENT ADVISORS LLC

Item 1 – Cover Page AZIMUT INVESTMENT ADVISORS LLC (formerly known as Azimut Genesis Advisors, LLC) 1450 BRICKELL AVENUE SUITE 2610 MIAMI, FLORIDA 33131 +1 786 866 3700 December 22, 2025 This Brochure provides information about the qualifications and business practices of Azimut Investment Advisors LLC (formerly known as Azimut Genesis Advisors, LLC). If you have any questions about the contents of this Brochure, please contact us at +1 786 866 3700. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Azimut Investment Advisors LLC is a registered investment adviser. The registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Azimut Investment Advisors LLC (formerly known as AZ Genesis Advisors LLC) also is available on the SEC’s website at www.adviserinfo.sec.gov. Azimut Investment Advisors LLC  Item 2 – Material Changes As required by SEC rules, Azimut Investment Advisors LLC formerly known as AZ Genesis, LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”), is required to inform our clients of material changes to its business that have occurred since the last annual update of the Firm’s brochure. Since our last update, we have had the following material changes: (i) Effective December 08, 2025, Azimut Genesis Advisors, LLC changed its name to Azimut Investment Advisors LLC; and (ii) effective December 22, 2025, Uzi Rosha (founder and managing director of Aviv Compliance, LLC) is the Outsourced Chief Compliance Officer for Azimut Investment Advisors LLC. Azimut Investment Advisors LLC  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 .................................................................................................................. 7 Item 6 – Performance-Based Fees and Side by Side Management ............................................................ 12 Item 7 – Types of Clients ............................................................................................................................. 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................13 Item 9 – Disciplinary Information ................................................................................................................ 22 Item 10 – Other Financial Industry Activities and Affiliations .....................................................................22 Item 11 – Code of Ethics, Participation or Interest in client Transactions and Personal Trading ................24 Item 12 – Brokerage Practices ..................................................................................................................... 25 Item 13 – Review of Accounts ..................................................................................................................... 29 Item 14 – Client Referrals and Other Compensation .................................................................................. 29 Item 15 – Custody ....................................................................................................................................... 29 Item 16 – Investment Discretion ................................................................................................................. 30 Item 17 – Voting Client Securities/Class Actions/ Claims/Settlements/Proof of Claims .............................30 Item 18 – Financial Information .................................................................................................................. 30 BROCHURE SUPPLEMENTS ADV PART 2B .......................................................................................... 31 AZIMUT GENESIS ADVISORS PRIVACY POLICY NOTICE ................................................................ 49 Azimut Investment Advisors LLC  Item 4 – Advisory Business BRIEF DESCRIPTION Azimut Investment Advisors LLC, a limited liability company, was originally established in March 2000 as BSI Investment Advisors LLC. In April 2005, it became Genesis Investment Advisors LLC. On September 28, 2020, AZ US Holdings, LLC acquired majority ownership of RGP2, LLC (the owner of Genesis Investment Advisors LLC) and renamed it: Azimut Genesis Holdings LLC. Effective December 08, 2025, the firm changed its name to Azimut Investment Advisors LLC (“AIA” or the “Firm”). AIA is incorporated in Delaware and domiciled in Florida, with its primary place of business in Miami, Florida. AIA provides both discretionary and non-discretionary investment advisory services to high-net- worth individuals and institutional clients. AIA also provides investment advisory services to institutional fund administrators and managers. ASSETS UNDER MANAGEMENT As of September 30, 2025, AIA (as of that date operating under its former name AZ Genesis) has an approximate total of $639,091,944 in assets under management. Approximately, $390,804,724 is non- discretionary, and $ 248,287,220 is discretionary. ADVISORY SERVICES OFFERED As a SEC Registered Investment Advisor, AIA provides investment advisory services to individuals as well as to institutional clients. When providing investment advisory services to its clients, AIA investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objective and pursuant to the terms outlined in its investment advisory agreement. AIA discretionary and non-discretionary investment management services include the design, structure, and implementation of investment strategies for Managed Accounts. Investment advisory activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to be in the client’s best interest considering the client’s objectives, strategies and risk profile as described by each client during an interview process. Clients may impose restrictions on investing in certain securities or types of securities. Each agreement typically defines the services to be provided, and the fees will be agreed on in the advisory agreement. Regardless of the type of account (discretionary or non-discretionary) the client enters into, AIA has continuous and regular supervisory or management services over the relationship. Azimut Investment Advisors LLC  The overall advisory services offered by AIA falls within the following categories listed below. Non-Discretionary Advisory Services AIA provides non-discretionary advisory services to both institutional and retail clients in accordance with a nondiscretionary advisory agreement between AIA and the client. Under the non-discretionary mandates, AIA designs a specific investment strategy considering each client’s risk profile, investment objective and financial goal outlook. In a non-discretionary relationship, AIA will provide investment advice to clients and will discuss the recommendations and obtain the clients consent prior to implementing the advised strategy. It is up to the client to execute the strategy with their individual custodian. However, AIA may, when authorized by the client, assist in the implementation of such strategies by forwarding instructions to the client’s custodian and arranging/effecting the purchase or sale of the securities we advise on. AIA also provides recommendations regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs, and such advice may be provided to accounts with assets maintained at various third parties. Each client is required to sign an investment advisory agreement (non-discretionary) where they state their investment objectives, risk profile and overall financial profile. In the agreement, AIA clearly disclosed all fees and costs associated with the investment advisory mandate. Also, in this agreement AIA discloses, and the client acknowledges if there is any cash compensation to a promotor for referring the relationship to AIA. Each agreement defines the services to be provided and fees to be charged. The fees are agreed upon and specified in the advisory agreement. Discretionary Advisory Services AIA offers discretionary Separately Managed Accounts that focus on investments in specific and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts are based on AIA core strategies for different investment objectives and goals. Currently, AIA discretionary managed accounts fall within the following profiles: Income Plus: designed for investors who seek to maximize current income, wish a significant degree of principal protection and diversification into alternative investments. Investments, generally, are limited to fixed income securities (including preferred securities and high yield securities) and alternative investments. Income Latin America: For investors seeking high current income and long-term growth potential and who understand the risks of investing in emerging Latin American markets. Azimut Investment Advisors LLC  Balanced: For investors seeking moderate current income with moderate long-term growth potential and global diversification of their assets, including a portion in alternative investments. The equity component consists of value and/or growth-oriented stocks, Exchange Traded Funds and indices for capital appreciation while the balance of the portfolio is invested in investment grade, fixed income securities (including preferred securities) and in alternative investments. Growth: For investors seeking to maximize their investment return through investment in equity securities and/or alternative investments. Attractive for those seeking currency and global diversification in equity markets and alternative investments. Custom: The investment objectives and guidelines for custom accounts are agreed upon by AIA and the client on a case-by-case basis. The clients work with an account manager in choosing the investment strategy most in line with their investment goals, objective, and acceptable risk level. Under normal market conditions, AIA invests all or part of its clients’ assets in portfolios of marketable securities and / or funds (on shore and offshore funds, including non-registered funds and Hedge Funds). Each client is required to sign a discretionary investment advisory agreement where they select a specific strategy. In the agreement, AIA clearly disclosed all fees and costs associated with the investment advisory mandate. Portfolio Consolidation Services: AIA also provides portfolio consolidation services designed for clients using multiple custodians and / or asset managers. This service provides an overview of the client’s consolidated portfolio and several analytical tools to help optimize asset allocation, risk, performance, and cost. Reporting is customized to the client’s needs and requirements. The portfolio consolidation offered by AIA is part of its services and is a non-investment advisory product or service. See Item 8 for AIA’s methods of analysis, investment strategies and potential risk of loss associated. INVESTMENT TYPES AIA can invest clients’ assets in, but is not limited to, the following types of investments: (cid:0) Emerging Market Debt (cid:0) Sovereign Debt (cid:0) Corporate Debt Securities (cid:0) UCITS funds (cid:0) Private funds (including SIFs) Azimut Investment Advisors LLC  (cid:0) Equity Securities (cid:0) Exchange Traded Funds (cid:0) Commercial Paper (cid:0) Certificates of Deposit (cid:0) Mutual Fund Shares (cid:0) Unites States Government Securities (cid:0) Options Contracts on Securities and Commodities (cid:0) Futures Contracts on Intangibles (cid:0) Other High-Quality Liquid Short Term Instruments (cid:0) Pooled Investment Vehicles WRAP FEE PROGRAMS AIA does not participate in wrap fee programs. FUND MANAGEMENT AIA serves as a sub-advisor to AZ Fund 1 Bond Latin America Bonds Fund (the “Fund”), a non-US registered investment company. The Fund is managed by Azimut - Kaan Asesores en Inversiones SAPI de CV, (“AZ Kaan”) an affiliate to AIA. The Fund is a sub-fund within and structured as a ‘Societe d’Investissment a Capital Variable’ (“SICAV”) under the ‘Undertaking for Collective Investment in Transferable Securities’ (“UCITS”) directive for non- U.S. investors. The Fund operates as a sub-compartment to an umbrella investment company of AZ Fund 1 SICAV with variable capital and segregated liability between funds incorporated with limited liability in the Luxembourg and authorized by the Commission de Surveillance du Secteur Financier (“CSSF”). Item 5 – Fees and Compensation The specific way fees are charged by AIA is established in the client’s written investment management agreement with the Firm. AIA bills its fees on a quarterly basis in arrears, each calendar quarter based on the market value of the client's assets managed or advised by the Firm (see detailed fee calculation methodology below). Clients can elect to be billed directly or to authorize AIA to directly debit fees from client accounts with the respective custodian. Accounts initiated or terminated during a calendar quarter are charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Further, generally, AIA does not accept prepaid fees. If, however, prepaid fees are mistakenly received, all unearned fees will be refunded to the client in the event the advisory relationship is terminated. Azimut Investment Advisors LLC  AIA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients can incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, foreign currency exchange fees and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, private funds, UCITS and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to AIA’s fee. Clients agree to the terms of their fee calculation methodology in the investment management agreements with AIA. All fees are subject to negotiations and clients and potential clients should note that similar advisory services may be available from other registered investment advisors for similar or lower fees. Finally, please be aware that our fee and compensation structure creates a conflict of interest for us as it encourages us to request that you increase your asset base that we manage. We mitigate this conflict by only advising you to increase assets and advise you to invest when we believe it is in your best interest to do so. HOURLY FEES FOR NON-DISCRETIONARY ACCOUNTS For certain non-discretionary accounts, AIA can provide investment advice on an hourly basis. The current hourly fee is $500 per hour and is billed on a quarterly basis as services are provided. There shall be no prorating of the hourly fee. For example, whether a conversation lasts the full 60 minutes or only 10 minutes, the flat hourly fee charged shall be $500. Additionally, our hourly rate shall apply not just for the communication of investment advice, but also for all research and other work conducted to formulate the advice given. Payment is due within 30 days of the date on the bill received. Our compensation can be changed at any time after giving you 30 days’ written notice. MINIMUM FEES/FLAT FEES For certain small non-discretionary accounts, AIA imposes a minimum fee threshold of $1,250 per quarter and may negotiate a flat fee. Both minimum and flat fees are paid quarterly in arrears. For certain small discretionary accounts, AIA imposes a minimum fee threshold of $3,750 per quarter and may negotiate a flat fee. Both minimum and flat fees are paid quarterly in arrears. AFFILIATED FUND FEES As identified under Item 4 above, AIA may recommend certain clients to invest in SICAV based UCITS managed by an affiliate. Investments in affiliated funds are subject to each fund’s operating and administrative expenses that are indirectly borne by individual investors. Such fees include the affiliate’s Azimut Investment Advisors LLC  management and incentive fees, in addition to the advisory fees paid to AIA. Please be aware and as further explained below this practice constitutes a conflict of interest as AIA benefits from the additional fees paid to its affiliate. Expenses borne by the affiliated investment funds are described in detail in each fund’s offering documents or prospectus. PORTFOLIO CONSOLIDATION FEES Pricing for the AIA portfolio consolidation service is a fixed dollar amount per year based on the number of custodians, the number of investment positions and the ease of access to the data (varying from electronic data interface to manual input from printed statements). Pricing ranges from $1,000 to $5,000 per month in addition to a one-time set-up fee of $3,000 to $5,000. DISCRETIONARY ACCOUNTS Generally, the basic fee for discretionary accounts ranges from 1.50% - 2.50% per annum computed on the balance of all account assets, including cash, with a minimum of $3,750 per quarter. However, the fee could require customization and fall outside of the general parameters listed above, depending on the size, nature, complexity, etc. of the account. The fee is based on the balance of all account property for the preceding three months by averaging the market value of all property in the account during that period at the four following dates: • • • • the last day of the quarter immediately preceding the quarter for which our compensation is being calculated. the last day of the first month of the quarter for which our compensation is being calculated. the last day of the second month of the quarter for which our compensation is being calculated; and the last day of the third month of the quarter for which our compensation is being calculated. Additionally, please note that, depending on the jurisdiction of your custodian and/or your own tax status, a sales tax or a value added tax could apply to the management fee. In any partial quarter, the management fee shall be prorated based on the number of days that the account was open during the quarter. The fee will be based on the balance of all account assets for the preceding partial quarter by averaging the market value of all property in the account during that period at the four following dates, whenever it applies: Azimut Investment Advisors LLC  • • • • day of the quarter for which our compensation is being calculated and on which the Agreement has been signed. the last day of the first month of the quarter for which our compensation is being calculated, if it applies. the last day of the second month of the quarter for which our compensation is being calculated, if it applies. and the last day of the third month of the quarter for which our compensation is being calculated, if it applies, or the day of the quarter for which our compensation is being calculated and on which the agreement has been terminated. NON-DISCRETIONARY ACCOUNTS The basic fee for non-discretionary accounts starts at 1.50% per annum based on the market value of all the account assets, including cash, with a minimum of $1,250 per quarter. The fee is based on the balance of all account property, including cash, for the preceding three months by averaging the market value of all property in the account during that period at the four following dates: • • • • the last day of the quarter immediately preceding the quarter for which our compensation is being calculated. the last day of the first month of the quarter for which our compensation is being calculated. the last day of the second month of the quarter for which our compensation is being calculated. and the last day of the third month of the quarter for which our compensation is being calculated. Additionally, please note that, depending on the jurisdiction of your custodian and / or your own tax status, a sales tax or a value added tax could apply to the management fee. In any partial quarter, the management fee shall be prorated based on the number of days that the account was open during the quarter. The fee will be based on the balance of all account property, including cash, for the preceding partial quarter by averaging the market value of all property in the account during that period at the four following dates, whenever it applies: • • • day of the quarter for which our compensation is being calculated and on which the agreement has been signed. the last day of the first month of the quarter for which our compensation is being calculated, if it applies. the last day of the second month of the quarter for which our compensation is being calculated, if it applies. Azimut Investment Advisors LLC  • and the last day of the third month of the quarter for which our compensation is being calculated, if it applies, or the day of the quarter for which our compensation is being calculated and on which the agreement has been terminated. Investment Management – Sub advisory Services The investment advisory fees that we receive as a service provider to the SICAV under UCITS directives are described in the registration statements and/or financial filings of the UCITS which are available upon request. Fees are not negotiable. AIA is compensated for the services performed and the facilities furnished by us: An annual Management Fee based on the net assets of the fund(s). This fee is payable monthly in arrears on the first business day of each calendar month, calculated on the total net asset value as of the last business day of the preceding month, before giving effect to subscriptions and redemptions, if any, accepted as of such day. Item 6 – Performance-Based Fees and Side by Side Management In some cases, AIA has entered performance fee arrangements with qualified clients that are in addition to the regular management fees mentioned previously. Performance based fees are subject to individualized negotiation with each such client. AIA will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the Investment Advisers Act of 1940 (the “Advisers Act”), as amended, in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3. In measuring clients' assets for the calculation of performance-based Performance-based fee arrangements create a conflict of interest as there is an incentive for AIA to recommend investments which could be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. AIA has procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. Please note that AIA does not receive any performance-based fees for its sub advisory services to the Fund. COMBINATON OF ASSETS UNDER MANAGEMENT AND PERFORMANCE FEES For some discretionary accounts, total compensation for account management can be a combination of assets under management and performance-based fees. Azimut Investment Advisors LLC  Item 7 – Types of Clients AIA provides investment advisory services to the following, but is not limited to: (cid:0) Individuals (cid:0) High Net Worth Individuals (cid:0) Corporations (cid:0) Trusts (cid:0) Offshore Investment Companies Each client account must have a minimum of $500,000, unless waived by AIA, and AIA can impose a minimum fee for managing smaller accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss METHOD OF ANALYSIS AND SOURCES OF INFORMATION Generally, the methods of analysis, sources of information and investment strategies employed by AIA are: (cid:0) Fundamental (cid:0) Technical Additionally, the main sources of information and software tools AIA uses include, but are not limited to: (cid:0) Research Materials Prepared by Others (cid:0) Electronic Financial Data delivery services such as Bloomberg LP (cid:0) Portfolio Management Systems such as Addepar software (cid:0) Corporate Rating Services (cid:0) Annual Reports, Prospectuses, Filings with the SEC (cid:0) Company Press Releases (cid:0) Financial Newspapers and Magazines INVESTMENT STRATEGIES AIA can implement, but is not limited to, the following types of strategies: (cid:0) Long-Term Purchases (securities held at least one year) (cid:0) Short-Term Purchases (securities sold within one year) Azimut Investment Advisors LLC  (cid:0) Trading (securities sold within 30 days) (cid:0) Short sales (cid:0) Margin Transactions (cid:0) Option Writing, Including Covered Options, Uncovered Options or spreading Strategies. (cid:0) Hedging through Forwards and Futures transactions RISK OF LOSS As part of its investment strategy, AIA can invest in non-US bonds, non-US equities, noninvestment grade securities, Eurobonds or similar securities, including Emerging Markets securities. Some of these securities could be illiquid and not have a readily available market. Risks Of High Yield Investing Accounts can be invested in debt securities which are rated below investment grade (“lower-rated securities”, sometimes referred to as “high yield” or “junk bonds”) or which are unrated but deemed equivalent to those rated below investment grade by AIA. The lower the ratings of such debt securities, the greater their risks. These debt instruments generally offer a higher current yield than that available from higher-grade issues but typically involve greater risk. The yields on high yield/high risk bonds will fluctuate over time. In general, prices of all bonds rise when interest rates fall and fall when interest rates rise. Lower- rated and unrated securities are especially subject to adverse changes in general economic conditions and to changes in the financial condition of their issuers. During periods of economic downturn or rising interest rates, issuers of these instruments can experience financial stress that could adversely affect their ability to make payment of principal and interest and increase the possibility of default. AIA can have difficulty disposing of certain high yield bonds because there could be a thin trading market for such securities. To the extent that a secondary trading market for high yield bonds does exist, it is generally not as liquid as the secondary market for higher-rated securities. Reduced secondary market liquidity can have an adverse effect on market price and AIA’s ability to dispose of issues. Adverse publicity and investor perceptions, whether based on fundamental analysis, could also decrease the values and liquidity of these securities, especially in a market characterized by only a small amount of trading. Risks Of Global Investing Global Investing involves special economic and political considerations. Such considerations include changes in exchange rates and exchange rate controls (which can include suspension of the ability to transfer currency from a given country), currency devaluations, costs incurred in conversions between currencies, non-negotiable brokerage commissions, less publicly available information, different Azimut Investment Advisors LLC  accounting standards, lower trading volume and greater market volatility, the difficulty of enforcing obligations in other countries, less securities regulation, different tax provisions (including withholding on dividends and interest paid to an account), war, expropriation, political and social instability, and diplomatic developments. Risks Of Emerging Markets Investing Emerging market countries are those countries defined as “emerging markets” by certain entities such as the World Bank or the United Nations. Securities of many issuers in emerging markets could be less liquid and more volatile than domestic issuers. Emerging markets also have different clearance and settlement procedures, and in certain markets there have been times when settlements have been unable to keep pace with the volume of securities transactions, making it difficult to conduct such transactions. Delays in settlement could result in temporary periods when a portion of the assets of an account are uninvested, and no return is earned thereon. The inability of an account to make intended security purchases due to settlement problems could cause an account to miss attractive investment opportunities. Inability to dispose of portfolio securities due to settlement problems could result either in losses to an account due to subsequent declines in value of the account securities or, if an account has entered a contract to sell the security, possible liability to the purchaser. Costs associated with transactions in foreign securities are generally higher than costs associated with transactions in US securities. Such transactions also involve additional costs for the purchase or sale of foreign currency. Foreign investment in certain emerging market debt obligations is restricted or controlled to varying degrees. These restrictions or controls can at times limit or preclude foreign investment in certain emerging market debt obligations and increase the costs and expenses of an account. Certain emerging markets require prior governmental approval of investments by foreign persons, and/or impose additional taxes on foreign investors. These markets could also restrict investment opportunities in issuers in industries deemed important to national interests. Certain emerging markets can require governmental approval for the repatriation of investment income, capital, or the proceeds of sales of securities by foreign investors. In addition, if deterioration occurs in an emerging market’s balance of payments or for other reasons, a country could impose temporary restrictions on foreign capital remittances. An account could be adversely affected by delays in, or a refusal to grant, any required governmental approval for repatriation of capital, as well as by the application to an account of any restrictions on investments. Many emerging markets have experienced, and continue to experience, high rates of inflation. In certain countries, inflation has at times accelerated rapidly to hyperinflationary levels, creating a negative interest rate environment, and sharply eroding the value of outstanding financial assets in those countries. Increases in inflation could have an adverse effect on an account’s non-dollar denominated securities and on the issuers of debt obligations generally. Azimut Investment Advisors LLC  Individual foreign economies can differ favorably or unfavorably from the US economy in such respects as growth of gross domestic product, rate of inflation, capital reinvestment, resources, self-sufficiency, and balance of payments position. The securities markets, values of securities, yields and risks associated with securities markets in different countries can change independently of each other. Investment in sovereign debt can involve a high degree of risk. Holders of sovereign debt (including an account) could be requested to participate in the rescheduling of such debt and to extend further loans to governmental entities. There is no bankruptcy proceeding by which sovereign debt on which governmental entities have defaulted can be collected in whole or in part. Additionally, there can be no assurance that an account's investment in Emerging Markets will not be expropriated, nationalized, or otherwise confiscated. Leveraged Trading Securities can be traded on a leveraged or margined basis. Accordingly, a relatively small price movement could result in immediate and substantial loss to the investor. Although the use of leverage can substantially improve the return on invested capital, it also could increase any adverse impact to which the hedge fund’s investment portfolio can be subject. Short Selling Short sales strategies can be used in which a security not owned will be sold in the hope of purchasing the same security later at a lower price. A loss will be incurred because of a short sale if the price of the security increases between the date of the short sale and the date when the position is covered (i.e., purchases the security to replace the borrowed security.) A gain will be realized if the security declines in price between these dates. A short sale involves the theoretically unlimited risk of an increase in the market price of the security. Exchange Traded Fund Risks ETF shareholders are subject to risks like those of holders of other portfolios, such as mutual funds. In addition to these general risks, there are risks specific to each ETF, which are described in the relevant prospectus. Risks can include the following: • The general value of securities held can decline, thus adversely affecting the value of an ETF that represents an interest in those securities. This could occur with equities, commodities, fixed income, futures, or other investments the fund can hold on to behalf of the shareholders. • For ETFs for which the stated investment objective is to track a particular industry or asset sector, the fund could be adversely affected by the performance of that specific industry or sector. Azimut Investment Advisors LLC  • Fund holdings of international investments can involve the risk of capital loss from unfavorable fluctuations in currency exchange rates, differences in generally accepted accounting principles, or economic or political instability in other nations. • Although ETFs are designed to provide investment results that generally correspond to the price and yield performance of their respective underlying indexes, the funds may not be able to exactly replicate that performance because of trust expenses and other factors. This is sometimes referred to as “tracking error.” Investment Risks Markets are speculative, prices are volatile, and movements are difficult to predict. Supply and demand change rapidly and are affected by a variety of factors, including interest rates, merger activities and general trends in the overall economy or industry or other economic sectors. A variety of factors that are inherently difficult to predict, such as domestic and international political developments, governmental trade and fiscal policies, patterns of trade and war or other military conflict also can have significant effects on the market. There could be limited ability to vary an investment portfolio in response to changing economic, financial and investment conditions. Those risks can be enhanced significantly by the concentration of investments, a consequent lack of diversification and the potential that it creates for volatility. No assurance can be given as to when or whether adverse events might occur that could cause significant and immediate loss in the value of a portfolio. Even in the absence of such events, large losses could be acquired. Risk of Investing in Funds Investing in Funds in general can have the following risks associated: Market Risk: The value of the underlying investments could decline because of unavoidable risks that affect the entire market. Liquidity Risk: There is the risk that underlying investments in a fund cannot be sold because there are no buyers in the market. As a result, the value of underlying securities could decline to zero in the case of illiquidity in the market. Credit Risk: Funds that invest in fixed income securities (bonds) have the risk of the bond issuer. Credit risk exists if the bond issuer is unable to repay a bond upon maturity and/or interest payments of a bond. This could result in the bond being worthless. Interest Rate Risk: Funds that invest in fixed income securities (bonds) have the risk of the value of the security declining during periods of rising interest rates. Country Risk: Political or instability of a country can negatively affect the value of a security which could result in declining values. Azimut Investment Advisors LLC  Currency Risk: Investments that are denominated in other currencies have the risk of devaluation based on the foreign exchange value rates compared against the US dollar. Risk of Hedge Fund Investing Hedge funds present special risks and disadvantages to the investor and in general carry a high degree of risk. A non-exhaustive discussion of the potential risks and disadvantages associated with hedge funds includes engagement in leveraging and other speculative investment practices that could increase the risk of investment loss; a high level of illiquidity; the lack of required periodic pricing or valuation information; potential for complex tax structures and delays in the distribution of important tax information; potentially high fees; and the lack of regulatory requirements imposed upon mutual funds. Further, no person should consider investing in a hedge fund more than he can comfortably afford to lose and there can be no assurance that any investment in a hedge fund will be successful or that its objectives will be attained. By nature, investment in a hedge fund is speculative and suitable only for the investor who is aware of the risks involved. The following are certain risks discussed within the context of hedge fund investing but can also be applied to AIA’s overall investment strategy and should be carefully digested with that in mind. Hedge Fund Trading is Speculative and Volatile - Prices are highly volatile and a hedge fund’s trades are purely speculative. No assurance can be made that such speculative trading will result in a profit or will not incur substantial losses. Leveraged Trading by Hedge Funds - A hedge fund can trade securities on a leveraged or margined basis. Accordingly, a relatively small price movement could result in immediate and substantial loss to the investor. Although the use of leverage can substantially improve the return on invested capital, it also can increase any adverse impact to which the hedge fund’s investment portfolio could be subject. Short Sales by Hedge Funds - At times, a hedge fund can engage in short sales in which it will sell a security it does not owns in the hope of purchasing the same security later at a lower price. The hedge fund will incur a loss because of a short sale if the price of the security increases between the date of the short sale and the date on which the hedge fund covers its short position (i.e., purchases the security to replace the borrowed security.) A hedge fund will realize a gain if the security declines in price between these dates. A short sale involves the theoretically unlimited risk of an increase in the market price of the security. Markets and Securities Traded Could be Illiquid - At various times, the markets for securities purchased or sold could be illiquid, making purchase or sale of securities at desired prices or in desired quantities difficult or impossible. Azimut Investment Advisors LLC  Spread Trading and Arbitrage Trading Can Involve Potential Risks - Investment operations can involve spread positions between two or more securities positions. To the extent the price relationships between such positions remain constant, no gain or loss on the positions will occur. Such positions, however, entail a substantial risk that the price differential could change unfavorably causing a loss to the spread position. The trading operations also could involve arbitrage between a security and its announced buy-out price or other forms or “risk arbitrage” between various securities. To the extent the price relationships between such positions remain constant, no gain or loss on the positions will occur. These offsetting positions entail substantial risk that the price differential could change unfavorably causing a loss to the position. Currency and Exchange Rate Risks - Changes in currency exchange rates can affect the value of a hedge fund’s portfolio and the unrealized appreciation or depreciation of investments. Further, a hedge fund can incur higher brokerage commissions in connection with conversions between currencies as brokers are subject to risks during the conversion process. A hedge fund can seek to protect the value of some portion or all its portfolio holdings against currency risks by engaging in hedging transactions, if available, cost effective and practicable. A hedge fund can enter forward contracts on currencies as well as purchase put and call options on currencies. There is no certainty that instruments suitable for hedging currency shifts will be available as a hedge fund wishes to use them or that even if available the hedge fund will elect to utilize a hedging strategy. Additional risks as discussed in greater detail in the topics Risks of High Yield Investing, Risks of Global Investing, Risks of Emerging Markets Investing and Special Risks Relating to Certain Investment Instruments can also be applied to hedge fund investing and should be reviewed within that potential context also. Special Risks Relating to Certain Investment Instruments Currency Forwards - Currency forwards can be purchased or sold to hedge the decline in value of securities or to invest in the currency of an Emerging Market country. AIA may enter contractual obligations to purchase a specific currency at an agreed upon price for a specific date with a known counterparty. There is the risk that the counterparty will not be able to fulfil its obligation (counterparty risk). Certificates of Deposit - AIA may purchase certificates of deposit (CDs) issued by commercial banks that can be domiciled in an Emerging Market country, or through an offshore branch of such a bank. CDs can settle domestically with a local custodian or sub custodian or can settle via "Euroclear" (EuroCDs). CDs can be denominated in local currency or in a major currency such as the U.S. dollar or Japanese Yen or be linked to hard currency. CDs could be rated or unrated. Commercial Paper/Medium Term Notes – AIA may purchase commercial paper (CP) or medium-term notes (MTNs) issued by a private sector enterprise domiciled in an Emerging Market country or through its offshore entity via a special purpose vehicle or note program. CP/MTNs can settle either domestically with a local custodian, in "Euroclear" (EuroCP or EuroMTNs), or in other major markets (such as Asian Azimut Investment Advisors LLC  currency notes). CP/MTNs can be denominated in local currency or in a major currency such as the U.S. dollar or be linked to a hard currency. CP/MTNs could be rated or unrated. If a Foreign Currency Constraint Event happens where under certain circumstances an Issuer is restricted or prevented from paying the Specified Currency for amounts owing under the CDs, holders of CDs can elect to receive payment in the lawful currency of the pertinent country, i.e., Brazil. If a holder does not elect to receive payments in the lawful currency of the pertinent country, i.e., Brazil, after the termination of the Foreign Currency Constraint Event such holder will receive any payments in respect of the CDs in such Specified Currency. A Foreign Currency Constraint Event will not be deemed to be an event of default and holders of CDs containing a Foreign Currency Constraint provision shall have no recourse against the Issuer’s assets and operations outside the pertinent country, i.e., Brazil, including, without limitation its assets and operations in another jurisdiction or country. Structured Products – AIA may purchase structured products in various forms, consistent with the client’s profile and strategy. Illiquid and Restricted Securities - The absence of a trading market can make it difficult to ascertain a market value for illiquid securities. Disposing of illiquid securities can involve time-consuming negotiation and legal expenses, and it can be difficult or impossible for an account to sell them promptly at an acceptable price. Convertible Securities - While convertible securities generally offer lower yields than non-convertible debt securities of similar quality, their prices can reflect changes in the value of the underlying common stock. Convertible securities generally entail less credit risk than the issuer’s common stock. An account can be required to permit the issuer of a convertible security to redeem the security and convert it into the underlying common stock or the cash value of the underlying common stock. Thus, an account is not able to control whether the issuer of a convertible security chooses to convert that security. If the issuer chooses to do so, this action could have an adverse effect on an account’s ability to achieve its investment objectives. Zero Coupon Securities - Zero coupon securities are subject to greater market value fluctuations from changing interest rates than debt obligations of comparable maturities that make current cash distributions of interest. Derivatives - This includes, without limitation, forward currency contracts, swap contracts, financial futures, index options, etc. The risks of derivatives include the possible default by the other party to the transaction, illiquidity and, to the extent AIA view as to certain market movements is incorrect, the risk that the use of such derivatives could result in losses greater than if they had not been used. Use of put and call options can result in losses to an account, force the sale or purchase of account securities at inopportune times or for prices higher than (in the case of put options) or lower than (in the case of call options) current Azimut Investment Advisors LLC  market values, limit the amount of appreciation an account can realize on its investments or cause an account to hold a security it might otherwise sell. The use of currency transactions can result in an account incurring a loss because of several factors including the imposition of exchange controls, suspension of settlements or the inability to deliver or receive a specified currency. The use of options and futures transactions entails certain other risks. In particular, the variable degree of correlation between price movements of futures contracts and price movements in the related account position of an account creates the possibility that losses on the hedging instrument could be greater than gains in the value of an account’s position. In addition, futures and options markets are not always liquid in all circumstances and certain over-the-counter options could have no markets. As a result, in certain markets, an account might not be able to close out a transaction without incurring substantial losses, if at all. Although the use of futures contracts and options transactions for hedging should tend to minimize the risk of loss due to a decline in the value of the hedged position, at the same time they tend to limit any potential gain which might result from an increase in value of such a position. Finally, the daily variation margin requirements for futures contracts would create a greater ongoing potential financial risk than would purchases of options, where the exposure is limited to the cost of the initial premium. Losses resulting from the use of derivatives would reduce net asset value, and possibly income, and such losses could be greater than if the derivatives had not been utilized. Risk of Default In parallel to the general trends prevailing in the financial markets, the particular changes in the circumstances of each issuer may have an effect on the price of an investment. Even a careful selection of securities or other financial assets cannot exclude the risk of losses generated by the depreciation of the issuers' situation. Cybersecurity AIA and its clients are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and unintentional damage or interruption in service. A cybersecurity breach could expose the AIA to substantial costs, civil liability, and regulatory inquiry and/or action. In addition, as the AIA does not directly control the cybersecurity systems of third- party service providers, there can be no assurance that the cybersecurity practices of these providers will protect the Firm or the clients. Investing in securities involves the risk of loss that clients should be prepared to bear. Azimut Investment Advisors LLC  Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of AIA or the integrity of AIA’s management. AIA has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations OTHER FINANCIAL INDUSTRY ACIVITIES A. Registration as a Broker/Dealer or Broker/Dealer Representative In addition to their roles with AIA, certain personnel within AIA are currently also registered with Sanctuary Securities, Inc., a related FINRA broker/dealer. As such, they can introduce accounts via Sanctuary Securities to Pershing LLC and be the broker of record and execute transactions for these clients as their broker. This is conflict of interest as they may recommend that the client uses Pershing, LLC as their custodian and Sanctuary Securities as their broker dealer to benefit an affiliate. We mitigate this conflict by not allowing our dually registered representatives to collect any brokerage-related fee, commission, sales credit markup/markdown or incentive for effecting transactions or opening accounts through Sanctuary Securities. B. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests AIA, Sanctuary Securities, Inc. and Sanctuary Advisors, LLC are affiliates and related persons by virtue of common ownership by Azimut US Holdings, a holding company. Also, as stated previously, some of AIA’s Advisors registered representatives are brokerage registered representatives for Sanctuary Securities, Inc. (dually registered). This relationship creates a conflict of interest because if a client uses Pershing LLC as their custodian and Sanctuary Securities as their broker dealer it may benefit an affiliate. Sanctuary Securities, our affiliate, may receive benefits for increasing their brokerage assets under management. We mitigate this conflict by ensuring that we only recommend that clients use Sanctuary Securities and Pershing LLC when it is in their best interest. In addition, we mitigate this conflict by not receiving any payment, incentive or any compensation as a result of a client opening an account with Sanctuary or Pershing, LLC. AIA may advise clients to invest in fund(s) advised by any of its affiliated companies, including Azimut Group. Clients should be aware that this is a conflict of interest as investing in a fund managed by a related company would benefit AIA by generating additional revenues for both of them. AIA mitigates this conflict of interest by only advising on strategies and products that are only in the best interest of the client based Azimut Investment Advisors LLC  on the client’s financial goals, investment objectives and risk tolerance. Some of AIA representatives are also registered at related advisors with the same conflicts noted. C. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AIA has the ability to enter into agreements where it contracts other advisors to serve and assist in managing client relationships. In these specific instances, AIA would be hiring a sub-advisor. AIA currently does not have any advisory or sub-advisor agreement. Item 11 – Code of Ethics, Participation or Interest in client Transactions and Personal Trading CODE OF ETHICS It is our policy of that all investment advisory services and related activities comply fully with the provisions of the Advisers Act and the rules and regulations thereunder, and other applicable federal and state laws. AIA has a fiduciary duty to its clients. It is of great importance that our clients never have reason to doubt their decision to place their faith and confidence in us. Any action that can cause that decision to be questioned jeopardizes the future of AIA and its employees. If an employee becomes aware of any activities that he/she believes could be in violation of the law or the policies of AIA, it is their responsibility to pass this information on to his/her supervisor or the Chief Compliance Officer. AIA’s Code of Ethics is available to all clients upon request. All AIA’s employees acknowledge the terms of the Code of Ethics and Personal Securities Transactions Policy Statement at the beginning of their employment and annually thereafter. AIA anticipates that, in certain circumstances, consistent with clients’ investment objectives, it will cause accounts over which it has management authority to effect and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which AIA, its affiliates and/or clients, directly or indirectly, may have a position of interest. AIA’s employees and people associated with the Firm are required to follow AIA’s Code of Ethics. Subject to complying with AIA’s compliance policies and applicable laws, officers, directors and employees of AIA are allowed to trade for their own accounts in securities which are recommended to and/or purchased for AIA’s clients. The Code of Ethics is designed to assure that the personal securities transactions and interests of the employees of AIA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interests of AIA’s clients. In addition, the Code requires pre-clearance of many transactions and restricts trading near client trading Azimut Investment Advisors LLC  activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between AIA and its clients. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis when consistent with AIA’s obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. AIA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rate basis. Any exceptions will be explained on the Order. It is AIA’s policy that the firm will not affect any principal or agency cross-securities transactions for client accounts. AIA will also not cross-trade on an agency basis between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. Such transactions also include a cross-trade involving any account that was 25% or more owned by an adviser and its controlling persons and securities crossed between an affiliated fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions can arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices RESEARCH AND OTHER SOFT DOLLAR BENEFITS Soft dollar practices are arrangements under which products or services other than execution of securities transactions are obtained by an adviser from or through a broker-dealer in exchange for the direction by the adviser of client brokerage transactions to the broker-dealer. Soft dollars create a conflict of interest as it incentivizes the advisor to direct transactions to a specific broker/dealer. AIA has a soft dollar arrangement with one broker/dealer where it receives credits to be used to offset costs for access to research and execution services. AIA mitigates the risks associated with this conflict of interest by ensuring, in good faith, that any commission charged by this broker/dealer is reasonable in comparison to other counter parties. In addition, when AIA believes that the commissions or costs are not in the best interest of the client it may use a different counterparty for trade execution. Azimut Investment Advisors LLC  FACTORS CONSIDERED WHEN SELECTING BROKER DEALER AIA’s clients can select their custodian or broker/dealer of their choice for custody and transaction execution. If a client selects their custodian/broker-dealer AIA will use this broker/dealer for transaction execution. As such and because most broker dealers do not allow clients to trade away, AIA may be limited in its ability to seek other trading counterparties. On these instances, AIA will rely on the broker/dealer’s best execution policies and procedures. There may be instances where the client requests that AIA select a broker/dealer for transaction execution, on these instances AIA uses its best judgment to choose the broker/dealer most capable of providing the services necessary to obtain the best available price and most favorable execution. The full range of brokerage and research services applicable to a particular transaction will be considered when making this judgment. When more than one broker can offer brokerage services needed to obtain the best available price and most favorable execution, AIA can consider selecting those brokers that also supply research services of assistance to AIA. Nevertheless, consistent with Section 28(e) of The Securities Exchange Act of 1934, AIA can pay commissions to such brokers at a level that could be higher than those charged by other qualified brokers if AIA determines in good faith that the amount of commission is reasonable in relation to the value of the brokerage and research services provided by the executing broker viewed in terms of AIA’s responsibilities to its clients. To a limited extent, AIA can also obtain research and research-related services or products on a soft dollar basis outside of the conditions of Section 28(e) which cover discretionary advisory client relationships and brokerage arrangements, among other conditions. In these instances, AIA can direct brokerage transactions for non-discretionary client relationships to broker/dealers providing or making available research services through others, i.e., third party research. Any such brokerage arrangements are also subject to AIA’s good faith determination that the commission amount is reasonable in relation to the value of the research services obtained consistent with AIA’s responsibilities to its clients. These research services and products provided by brokers to AIA can include information on the economy, industries, political, tax and legal developments affecting portfolio management, credit and risk analysis, asset classes and individual securities and quotation equipment, i.e., Bloomberg. Research obtained from such brokers can be used in servicing all or a portion of AIA’s accounts. Not all such research can be used in connection with transactions with the broker providing such research. Additionally, for any “soft dollar” arrangements, AIA periodically and regularly tracks, monitors, and checks all transactions and commissions generated. The investment approach of AIA is that excellent analytical research is available outside of many reliable sources. The resulting diversification of research sources allows AIA to access a larger quantity of information than it could possibly analyze with its own resources. To the extent that brokerage and research services of value are provided by broker/dealers, AIA can be relieved of some expenses that it might otherwise bear, and it can better contain its costs. AIA is under no obligation to direct a specific level of Azimut Investment Advisors LLC  securities trades to broker/dealers in exchange for research; however, AIA can enter into agreements with brokers to use commission dollars generated during business transactions for payment of research services and products. It should be noted that the receipt of research is a function of maintaining an active relationship with broker/dealers furnishing such research. CLIENT REFERRALS IN EXCHANGE FOR BROKER DEALER SERVICES In selecting or recommending broker dealers AIA does not consider whether a broker dealer can provide AIA or a related person with client referrals. Currently, AIA does not have any agreements with broker dealers, either written or oral, relating to client referrals with any broker dealer. CONFLICTS It is important to note that a general concept behind the use of soft dollars is that the use of client brokerage commissions to obtain research or other products or services benefits AIA because we do not have to produce or pay for the research, products, or services. Also, inherent in the use of soft dollars is the principle that there is an incentive for investment advisors, in general, including AIA, to select or recommend a broker dealer based on the interest in receiving the research and other products or services, rather than on the clients’ interest in receiving the most favorable execution. ITEMS PAID FOR BY SOFT DOLLARS The only product or service aside from research that AIA pays for via soft dollars is the Bloomberg service. Currently, AIA “soft dollars” 1 Bloomberg system and allowable fees associated with them. Note that the terminals fall outside of Section 28(e). The Bloomberg terminal is a computer system provided by Bloomberg L.P. that enables financial professionals to access the Bloomberg Professional service through which users can monitor and analyze real-time financial market data movements and place trades. The system also provides news, price quotes, and messaging across its proprietary security network. DIRECTED BROKERAGE AIA does not recommend, request, or require that clients direct us to execute transactions through a specified party. BUNCHED/AGGREGATED TRANSACTIONS Consistent with its duty of best execution, AIA, from time to time, buys and sells securities on a “bunched” basis, allocating the securities among multiple client accounts. The procedures used by AIA in effecting Azimut Investment Advisors LLC  trades, particularly when on a “bunched” basis, are intended to ensure that AIA does not favor one account over any other account and that investment opportunities are allocated, over time, in a fair and equitable manner. AIA maintains “omnibus” accounts at various broker/dealers and custodian banks for the purpose of executing, clearing, and settling transactions that are “bunched,” where appropriate, on a best execution basis. Please note that any omnibus account used is purely as a pass-through account and client securities do not settle there. Allocation of securities, including IPOs, is done equitably among suitable accounts, with a rotational basis and consideration of investment guidelines and fund availability. AIA uses an allocation form to document order quantities for each account, allocating filled orders accordingly or pro-rata if partially filled. The Firm maintains flexibility to adjust allocations for specific circumstances while ensuring fair and equitable treatment for all clients. AIA receives no additional compensation for bunching transactions and maintains separate records for each client account. Client funds and securities are held with Qualified Custodians, and the firm adheres to its fiduciary duty to avoid disadvantaging one client account for the benefit of another. Item 13 – Review of Accounts AIA has an account review process whereby discretionary relationships, and non-discretionary relationships are reviewed regularly to ensure updated client profiles, adequacy of advice being given and compliance with investment strategy parameters. Item 14 – Client Referrals and Other Compensation AIA compensates unaffiliated third parties for referring clients (i.e., Promotors). Such compensation can consist of a percentage of the annual management fees earned by AIA on assets under management of referred clients or other amounts. Such arrangements are fully disclosed to clients in accordance with, and otherwise comply with, Rule 206(4)-1 under the Advisers Act. Fees paid to said Promotors, as described above, range from 25% to 75% of the advisory fees for each solicited client per annum. Each arrangement between AIA and a soliciting party is formally maintained in a written agreement. Such agreement: (i) describes the solicitor’s solicitation activities and the associated compensation, (ii) contains an undertaking by the solicitor to perform his or her duties consistently with AIA’s instructions and the Advisers Act and associated rules, and (iii) requires the solicitor, at the time of Azimut Investment Advisors LLC  any solicitation, to provide the solicited client with a current copy of Part 2 of AIA’s Form ADV and a solicitor’s separate disclosure document. Item 15 – Custody AIA does not have custody of client accounts. Clients have given their custodians authorization to pay AIA’s management fees. Clients should receive at least quarterly statements from the broker/dealer, bank or other qualified custodian that holds and maintains client’s investment assets. AIA will make reasonable efforts to ensure that its clients are receiving their account statements from their custodians. AIA urges its clients to carefully review such statements and compare such official custodial records to the account statements that AIA can provide to you. Our statements can vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Should a client’s agreement with their bank or custodian indicate or give AIA undue and unrequested authorization over a client’s account that can give AIA ‘custody’ of the client’s assets; the agreements have been stated between the client and their custodian, and AIA has not requested custody over said assets. AIA will inform custodians that they do not require additional access to the client’s assets that can give the firm custody. Item 16 – Investment Discretion AIA usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and number of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the client account. When selecting securities and determining amounts, AIA observes the investment policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions are provided to AIA in writing via the Investment Management Agreement between the client and AIA. Item 17 – Voting Client Securities/Class Actions/ Claims/Settlements/Proof of Claims VOTING CLIENT SECURITIES Unless the parties agree in writing, AIA does not have proxy voting authority and does not vote proxies. However, from time to time, at a client’s request and as a courtesy, AIA can advise client on how to vote Azimut Investment Advisors LLC  proxies. Should AIA provide advice on voting proxies, it shall disclose any material conflict to the clients receiving the advice. CLASS ACTIONS/CLAIMS/SETTLEMENTS/PROOF OF CLAIMS Unless the parties agree in writing, AIA shall have no obligation or authority to take any action or render any advice to clients with respect to 1) class action claims, 2) settlements or 3) proofs of claims. AIA does not provide legal services or advice. Item 18 – Financial Information AIA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings. Azimut Investment Advisors LLC