EAST CAPITAL FINANCIAL SERVICES AB

EAST CAPITAL FINANCIAL SERVICES AB (“ECFS”) FORM ADV PART 2A May 5, 2025 East Capital Financial Services AB Kungsgatan 28, P.O. Box 1364, SE-111 93, Stockholm Sweden | Corporate identity no. 556988-2086 | Registered office: Stockholm Phone +46 (0)8 505 885 00 | ecfs@eastcapital.com www.eastcapital.com 1 323207651.4  Item 1: Cover Page Company name: East Capital Financial Services AB CRD number: 335426 Business address: Kungsgatan 28, 111 56 Stockholm, Sweden Chief Compliance Officer: jean-christophe.esteve@eastcapital.com Company’s email address: ecfs@eastcapital.com Website: www.eastcapital.group of this Brochure, contact us by email This Brochure provides information about the qualifications and business practices of East Capital Financial Services AB (“ECFS” or the “Adviser”). If you have any questions about the at: please contents jean-christophe.esteve@eastcapital.com. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or any state securities authority. the Adviser’s Form ADV Part 1A, is also available on ECFS is a registered investment adviser with the SEC. Additional information about ECFS, including a copy of the SEC’s website at www.advisersinfo.sec.gov. Registration does not imply a certain level of skill or training. In this Brochure, the words “we,” “our,” and “us” refer to ECFS. Date of Brochure: May 5, 2025 2 323207651.4  Item 2: Material Changes Not applicable. This is the original Brochure prepared by ECFS in connection with its registration as an investment adviser. 3 323207651.4  Item 3: Table of Contents Item 1: Cover Page ...................................................................................................................................................2 Item 2: Material Changes ..........................................................................................................................................3 Item 3: Table of Contents .........................................................................................................................................4 Item 4: Advisory Business ........................................................................................................................................5 Item 5: Fees and Compensation ...............................................................................................................................6 Item 6: Performance-Based Fees and Side-By-Side Management ..........................................................................7 Item 7: Types of Clients ............................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................9 Item 9: Disciplinary Information .............................................................................................................................. 15 Item 10: Other Financial Industry Activities and Affiliations .................................................................................... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................. 17 Item 12: Brokerage Practices ................................................................................................................................. 18 Item 13: Review of Accounts .................................................................................................................................. 19 Item 14: Client Referrals and Other Compensation ................................................................................................ 20 Item 15: Custody .................................................................................................................................................... 21 Item 16: Investment Discretion ............................................................................................................................... 22 Item 17: Voting Client Securities ............................................................................................................................. 23 Item 18: Financial Information ................................................................................................................................ 24 Item 19: Requirements for State-Registered Advisers ............................................................................................ 25 4 323207651.4  Item 4: Advisory Business 4.A. Description of Advisory Firm East Capital Financial Services AB (“ECFS”), based in Stockholm, Sweden, is a securities company under the supervision of the Swedish Financial Supervisory Authority (“Finansinspektionen” or “FI”). ECFS was founded in 2014 and is a part of East Capital Group, founded in 1997, focused on asset management (collectively, “East Capital”). East Capital is an independent asset manager specialized in emerging and frontier markets, with offices in Hong Kong, Luxembourg, Stockholm and Tallinn. East Capital manages public equity funds and separate accounts for a broad international client base. East Capital is indirectly owned by Peter Elam Håkansson (56% owner), along with the other minority shareholders. Five of six shareholders are partners and hold senior positions within the firm: • Peter Elam Håkansson (Swedish), Chairman & Chief Investment Officer East Capital Group, based in Stockholm. Mr. Håkansson holds the majority of East Capital Holding AB (holding company of ECFS) Jacob Grapengiesser (Swedish), East Capital CIO, based in Hong Kong • • Karine Hirn (French), Chief Sustainability Officer, based in Hong Kong • Albin Rosengren (Swedish), Managing Partner, Head of Real Estate, based in Stockholm • Nikodemus Dahlgren (Swedish), Head of Sales, based in Stockholm Further, a selected number of managers, investment and investor relations professionals participate in an employee-ownership program. 4.B. Advisory Services Offered in the United States ECFS has been selected and retained by a third-party trustee (the “Trustee”) of a collective investment trust to provide investment advisory services with respect to funds established within the trust (collectively referred to as the “CIT” or the “CIT Funds”) pursuant to an investment services agreement (the “IMA”). The CIT is maintained by the trustee for investment of assets of U.S. employee benefit trusts (i.e., trusts holding the assets of employee benefit plans). ECFS does not currently offer its advisory services to clients in the United States other than the CIT. 4.C. Tailoring of Advisory Services The Adviser’s services with respect to the CIT Funds are provided subject to, and in accordance with, conditions set forth in a written investment policy statement (“IPS”) that is subject to prior approval by the Trustee. The IPS may only be amended as provided in the IMA. 4.D. Wrap Programs The Adviser does not participate in any wrap fee programs. 4. E. Management of Assets for U.S. Clients ECFS will manage the assets of the CIT Funds on a discretionary basis. As of the date of this Brochure, the CIT Funds had not yet launched; consequently, the assets under management for U.S. clients are currently US$0. 5 323207651.4  Item 5: Fees and Compensation The fee schedule for the CIT Funds will be negotiated between the Adviser and the Trustee. In consideration of the services provided by the Adviser with respect to the CIT Funds, the Trustee has agreed to cause the CIT Funds to pay the Adviser fees and expenses as set forth in the IMA. Such fees and expenses will be deducted from the CIT Funds’ assets. It is expected that fees will be paid by the CIT on a quarterly basis in arrears, although the Adviser and the Trustee may agree to a different arrangement. Participating trusts holding units of the CIT will bear ongoing costs and expenses of the CIT, including brokerage and transaction costs. See Item 12 for a description of the Adviser’s brokerage practices. 6 323207651.4  Item 6: Performance-Based Fees and Side-By-Side Management ECFS will not receive performance-based fees from the CIT. With respect to its non-U.S. clients, ECFS typically receives only a fixed or asset-based management fee from each client portfolio, and, as a rule, does not receive any performance fees from such clients. 7 323207651.4  Item 7: Types of Clients The CIT is a collective investment trust maintained by the Trustee for investment of assets of U.S. employee benefit trusts (i.e., trusts holding the assets of employee benefit plans). ECFS does not currently offer its advisory services to clients in the United States other than the CIT. 8 323207651.4  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 8.A. Methods of analysis and investment strategies ECFS anticipates that the CIT Funds will primarily pursue the Adviser’s Global Emerging Markets Sustainable strategy. The investment objective of the Global Emerging Markets Sustainable strategy is to provide long-term capital growth through exposure to companies in “emerging markets,” which are defined by the Adviser for this purpose as countries not classified as developed by the recognized major indices, or which are considered as low-or middle-income countries by the World Bank. The Adviser defines “sustainable investing” as recognizing that, environmental, social and governance factors may directly influence the long-term business profitability of companies. The Adviser will seek exposure to companies that manage sustainability risks and/or contribute to sustainable development in emerging markets. Environmental, social and governance factors are fully integrated into the investment process. The CIT Funds may also pursue the Adviser’s Global Frontier Markets strategy. The investment objective of the Global Frontier Markets strategy is to provide long-term capital growth through exposure to companies located in frontier markets throughout the world. For this purpose, frontier markets are defined as less advanced and less accessible emerging market countries that are included in frontier markets-related indices. ECFS believes in highly active management combined with a dynamic and clear investment process. The CIT Funds’ portfolios are expected to be comprised of high conviction companies offering strong structural growth at reasonable prices. The key pillars of our investment philosophy, which drive our investment process, are as follows: 1. Emerging markets remain imperfect: patchy sell-side coverage, poor disclosure, and nuanced political and geopolitical backdrops. This creates opportunities for active managers; 2. Stock performance is driven by much more than fundamental company quality; global sentiment, flows, the economic cycle and other macro factors play an important role; 3. Active managers underperform because of the various cognitive and behavioral biases that impede rational decision making. As a part of the overall investment process, we run a quantitative screen on a semi-annual basis based on key growth, valuation and quality metrics. Generally, our investment ideas are generated through our wide networks and frequent company visits and meetings. To identify whether a company represents a suitable investment opportunity for a CIT Fund, we employ several key criteria: 1. Access to structural growth, 2. Long term competitive position and strong management, 3. Strong free cash flow (FCF) or highly profitable investments, 4. Areas where there is difference from consensus, 5. Reasonable valuation or significant upside, and 6. High governance standards based on ECFS’s proprietary assessment 8.B. Material Risks The following are material risks that could have an impact on the value of the CIT Funds. Market risk Market risk is the risk that the value of an investment will increase or decrease due to changes in market factors. Investments by the Adviser on behalf of the CIT in Eastern European, Central European, Eastern Asian, African, Middle Eastern and Latin American markets entail the risk of substantial fluctuations in exchange rates and share prices. The Eastern European, Central European and Eastern Asian, African, Middle Eastern and Latin American financial markets are relatively new, and many are associated with high market risks. Market risks are divided into: equity risk (i.e., the risk that stock prices and/or the implied volatility will rise or fall) and currency risk (i.e., the risk that foreign exchange rates will rise or fall). Liquidity risk 9 323207651.4  Liquidity risk is one of the most important risks to the CIT since the CIT must have sufficient liquidity to meet payment obligations at all times. The Adviser invests primarily in countries with relatively new equity markets. Some equities in those countries are less liquid than in Western European markets, which might affect both the price and timing when holdings are to be sold. Liquidity risks are divided into: asset liquidity risk (i.e., the risk of decreased market value of the portfolio and individual holdings due to a stressed liquidity in the market) and funding liquidity risk (i.e., the risk that the CIT cannot meet its payment obligations without considerable costs or, in the worst case, does not have sufficient liquid resources to meet redemptions or other payment obligations). Sustainability risk Sustainability risk refers to the risk that environmental, social and governance (ESG) factors may directly or indirectly influence and may cause actual or potential negative impact on the value of an investment. Investment processes integrating ESG factors in the selection of the investment universe aim to identify such risks and in turn may or may not lead to a decision to invest. If the decision is to invest, an integral part of the investment process is to manage and where possible mitigate any potentially identified sustainability risk through different methods of influence, such as, among others, company engagement and/or exercising our voting rights at shareholders ’ meetings. Sustainability risks may not always be directly influenced by the invested companies based on decisions they make but are also influenced by externalities such as, but not limited to, physical risk aspect resulting from climate change. ESG investment risk ESG investment risk refers to the risk that investment and/or divestment decisions which are based not only on financial metrics, may result in performance differences as compared to the general market due to consideration of ESG factors in the investment decision process. Unavailability, inaccuracy, or incompleteness of data provided by third parties (where applicable) used as part of proprietary ESG scoring may lead to incorrectly assessing an investment opportunity. Credit and counterparty risk Credit risk can be divided into: Issuer risk arises when investments are in assets that are guaranteed by an issuer (typically • certificates or bonds). In the event of the bankruptcy or a downgrade in the rating of an issuer, all or part of the asset’s value may be lost. Counterparty risk is the risk that the counterparty will not meet its obligations with respect to • transactions, whether due to insolvency, bankruptcy or other causes. Settlement risk arises in a market where settlements are made delivery versus payment • (DVP). The risk entails a replacement cost where the transaction must be performed with a different counterparty if the first counterparty could not meet its payment obligation. In a market where settlement is made free of payment (FoP), the risk entails the loss of the full value of the asset if the counterparty cannot meet its commitments. Other the counter (“OTC”) instruments involve the risk that the full positive market value of the OTC instrument with regard to received collateral is lost if the counterparty cannot meet its commitments. Operational risk • Operational risks are connected to the Adviser’s risk management process, including different features and quality of the trading settlement and valuation procedures operated by the Adviser, which may increase the chances of losses due to human or technical errors. Operational risk also covers external factors such as legal risks, political risks and risks related to documentation. Settlement Risk • It may be that a settlement through a payment system does not take place as expected because payment or delivery of financial instruments by a counterparty did not, or not in time, take place as expected. The securities markets in some countries lack the liquidity, efficiency and regulatory 10 323207651.4  controls of more developed markets. Lack of liquidity may adversely affect the ease of disposal of assets. The absence of reliable pricing information in a particular security held by a CIT Fund may make it difficult to assess reliably the market value of assets. Political Risks The countries in which the CIT may invest have undergone dramatic changes in a short period of time, particularly due to the transition from planned to market economies. Democratization is still in its early stage. There is no guarantee that economic liberalization will continue. Military, social, religious or ethnic conflicts could reverse the process, leading to major detrimental consequences for shareholders. Political risks in the countries that the CIT may invest in are continuously monitored. Accounting policies Many of the local companies still follow accounting principles that differ from those of Western countries. Reliability, accessibility and quality are often poorer than for Western companies. Thus, the countries where the CIT may invest in are less transparent, as well as more difficult to analyze and value, than their Western counterparts. The lower transparency is not only a risk but also offers opportunities for the Adviser, which through research can identify interesting companies to invest in on behalf of the CIT. Legal Risks The legal systems in the countries where the CIT may invest are relatively underdeveloped. Legislation is inadequate when it comes to both tangible and intangible property rights. The courts may interpret the law inconsistently and arbitrarily. There is less respect for the law than in Western countries, and judicial rulings are often ignored. Legal risk is continuously monitored by the Adviser. Administrative Risks As opposed to Western stock markets, there is no guarantee that shares will be entered in the relevant CIT Fund’s name shortly after the transaction date, or that transactions can be securely settled. The countries may lack comprehensive legislation to protect the interests of shareholders. Minority Protection The existing protection of minority shareholders is limited in some of the markets in which the CIT may invest. Equal rights for shareholders cannot be assured, which, among other things, means that the right to information and possibility to exert influence over company management can be limited. The Adviser reduces the risk in the countries where this is a problem by means of diversification. Delta-one securities In countries where, either because of local regulations restricting direct investment by foreigners or for efficiency, the CIT may use depository receipts (tradable certificates issued by the actual owner of the underlying securities), participatory notes or similar instruments to gain investment exposure, the CIT Fund would take on risks that are not present with direct investment. These instruments involve counterparty risk (since they depend on the creditworthiness of the issuer) and liquidity risk, may trade at prices that are below the value of their underlying securities, and may fail to pass along to the CIT Fund some of the rights (such as voting rights) it would have if it owned the underlying securities directly. Participatory Notes Risks Participatory notes also known as “p-notes” are financial instruments that may be used to gain exposure to an equity or equity-related investment in a local market where direct ownership is not allowed or not easily accessible for the CIT. The CIT can gain exposure to investments through p- notes, which are issued by banks, broker-dealers or other counterparties. P-notes are treated as transferrable securities if they are listed for trading on a regulated exchange; however, the listing 11 323207651.4  does not guarantee any actual liquidity. P-notes may carry exposure to both liquid and illiquid securities and may trade at prices that are below the value of their underlying securities. P-notes may carry exposure to securities suspended from trading which may adversely affect the CIT’s ability to exit its investment in p-notes at a favorable price. A CIT Fund investing in p-notes may lack some of the rights (such as voting rights) it would have if it owned the underlying securities directly. If the issuer of the p-notes becomes unable or unwilling to honor its obligations to the relevant CIT Fund, the CIT Fund may lose money. Therefore, investments in p-notes involve counterparty risk towards the issuer of the p-notes. A CIT Fund investing in p-notes is thus exposed not only to movements in the value of the underlying security, but also to the risk of counterparty default, which may, in the event of counterparty default, result in the loss of the full market value of the investment. Debt Securities The CIT may invest in fixed income securities which may be unrated by a recognized credit-rating agency or below investment grade and which are subject to greater risk of loss of principal and interest than higher-rated debt securities. The CIT may invest in debt securities which rank junior to other outstanding securities and obligations of the issuer, all or a significant portion of which may be secured on substantially all of that issuer’s assets. The CIT may invest in debt securities which are not protected by financial covenants or limitations on additional indebtedness. The CIT will therefore be subject to credit, liquidity and interest rate risks. In addition, evaluating credit risk for debt securities involves uncertainty because credit rating agencies throughout the world have different standards, making comparison across countries difficult. Also, the market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. Downgrading Risk Investment grade bonds may be subject to the risk of being downgraded to non-investment grade bonds. In the event of downgrading in the credit ratings of a security or an issuer relating to a security, the CIT Fund’s investment value in such security may be adversely affected. The Adviser may or may not dispose of the securities, subject to the investment objective and policy of the relevant CIT Fund. High yield corporate bonds Corporate bonds rated below investment grade, or unrated securities that are determined by the Adviser to be of comparable quality, are high yield, high risk corporate bonds, commonly known as “junk bonds”. These bonds are predominantly speculative. They are usually issued by companies without long track records of sales and earnings, or by companies with questionable credit strength. These bonds have a higher degree of default risk and may be less liquid than higher-rated bonds. These securities may be subject to a greater price volatility due to such factors as specific corporate developments, interest rate sensitivity, negative perceptions of junk bonds generally, and less secondary market liquidity. This potential lack of liquidity may make it more difficult for a CIT Fund to accurately value these securities. Interest rate risk A CIT Fund that has exposure to bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, whilst their prices fall when interest rates rise. Longer term debt securities are usually more sensitive to interest rate changes. Currency hedging risk A CIT Fund may enter into foreign exchange hedging transactions, the aim of which is to protect against adverse currency fluctuations between the relevant reference currency. Such hedging transactions may consist of foreign exchange forward contracts or other types of derivative contracts which reflect a foreign exchange hedging exposure. Investors should note that there may be costs associated with the use of foreign exchange hedging transactions which will be borne by investors 12 323207651.4  Volatility of financial derivative instruments The price of a financial derivative instrument can be very volatile. This is because a small movement in the price of the underlying security, index, interest rate or currency may result in a substantial movement in the price of the financial derivative instrument. Investment in financial derivative instruments may result in losses in excess of the amount invested. Futures and options Under certain conditions, the CIT may use options and futures on securities, indices and interest rates for different purposes. Also, where appropriate, the CIT may hedge market and currency risks using futures, options or forward foreign exchange contracts. Transactions in futures carry a high degree of risk. The amount of the initial margin is small relative to the value of the futures contract so that transactions are “leveraged” or “geared”. A relatively small market movement will have a proportionately larger impact which may work for or against the investor. The placing of certain orders which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. Transactions in options also carry a high degree of risk. Selling (“writing” or “granting”) an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is “covered” by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. OTC financial derivative transactions In general, there is less governmental regulation and supervision of transactions in the OTC markets (in which currencies, forward, spot and option contracts, credit default swaps and certain options on currencies are generally traded) than of transactions entered into on organized exchanges. In addition, many of the protections afforded to participants on some organized exchanges, such as the performance guarantee of an exchange clearing house, may not be available in connection with OTC financial derivative transactions. Therefore, a CIT Fund entering into OTC financ ial derivative transactions will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and that the CIT Fund will sustain losses. The CIT will only enter into transactions with counterparties which it believes to be creditworthy, and may reduce the exposure incurred in connection with such transactions. Regardless of the measures the CIT Fund may seek to implement to reduce counterparty credit risk, however, there can be no assurance that a counterparty will not default or that the CIT will not sustain losses as a result. Swaps In a standard swap transaction, two parties agree to exchange the returns (or differentials in rates of return) earned or realized on particular pre-determined investments or instruments. Swaps contracts can be individually traded and structured to include exposure to different types of investment or market factors. Depending on their structure, these swap operations can increase or decrease the exposure of the CIT Fund to strategies, shares, short- or long-term interest rates, foreign currency values, borrowing rates or other factors. Swaps can be of different forms, and are known under different names; they can increase or decrease the overall volatility of the CIT Fund, depending on how they are used. The main factor that determines the performance of a swap contract is the movement in the price of the underlying investment, specific interest rates, currencies and other factors used to calculate the payment due by and to the counterparty. If a swap contract requires payment by the CIT Fund, the latter must at all times be able to honor said payment. Moreover, if the counterparty loses its creditworthiness, the value of the swap contract entered into with this counterparty can be expected to fall, entailing potential losses for the CIT Fund. Specific risks linked to securities lending In relation to securities lending transactions, investors must notably be aware that: 13 323207651.4  (A) if the borrower of securities lent by the CIT fail to return these there is a risk that the collateral received may realize less than the value of the securities lent out, whether due to inaccurate pricing, adverse market movements, a deterioration in the credit rating of issuers of the collateral, or the illiquidity of the market in which the collateral is traded; (B) in case of reinvestment of cash collateral such reinvestment may (i) create leverage with corresponding risks and risk of losses and volatility, (ii) introduce market exposures inconsistent with the objectives of a CIT Fund, or (iii) yield a sum less than the amount of collateral to be returned; (C) delays in the return of securities on loans may restrict the ability of the CIT to meet delivery obligations under security sales; (D) deficiencies from inadequate internal processes and from human error or system failures at service providers, the CIT, the Adviser or a counterparty can result in an unexpected loss. The costs can be related to either a loss of a fraction or the whole value of a transaction, or to penalties imposed on the institution by a counterparty; the CIT is subject to liquidity risk which arises when a particular instrument is difficult to (E) dispose of; (F) the risk of loss of securities held with a custodian as a result of insolvency, negligence or fraudulent action by the custodian may occur. Custody risk is influenced by a variety of factors including the legal status of the securities, the accounting practices and safekeeping procedures employed by the custodian, the custodian’s choice of sub-custodians and other intermediaries, and the law governing the custody relationship; and that (G) legal risks can bear the risk of loss because of the unexpected application of a law or regulation or because a contract cannot be enforced. A securities lending contract may be invalid or unenforceable. Even if the collateral arrangement has been set up correctly, there is the risk that the relevant insolvency law may impose a stay that prevents the collateral taker from liquidating the collateral. Securities lending transactions also entail operational risks such as the non-settlement or delay in settlement of instructions and legal risks related to the documentation used in respect of such transactions. The fee arrangements in relation to securities lending can give raise to conflicts of interest where the risks generally are borne by the CIT Fund lending securities, but the revenues are shared by the lender and its securities lending agent and where the agent may compromise on the quality of the collateral and the counterparty. Specific risk factors linked to emerging markets and frontier markets To the extent a CIT Fund invests in securities of issuers of frontier and/or emerging countries, investors should be aware that such investments are more speculative and subject to greater risk than those in securities of issuers of developed countries. Frontier/emerging markets may be volatile and illiquid and the investments of the CIT in such markets may be subject to significant delays in settlement. The risk of significant fluctuations in the net asset value and of the suspension of redemptions in a CIT Fund investing in emerging/frontier markets may be higher than for a CIT Fund investing in major world markets. In addition, there may be a higher than usual risk of political, economic, social and religious instability and adverse changes in government regulations and laws in less developed or frontier/emerging markets. The assets of the CIT, as well as the income derived therefrom, may also be affected unfavorably by fluctuations in currency rates and exchange control and tax regulations and consequently the net asset value of such CIT Fund’s units may be subject to significant volatility. Some of these frontier/emerging markets may not be subject to accounting, auditing and financial reporting standards and practices comparable to those of more developed countries and the securities markets of such markets may be subject to unexpected closure. In addition, there may be less government supervision, legal regulation and less well defined tax laws and procedures than in countries with more developed securities markets. 14 323207651.4  Item 9: Disciplinary Information As of the date of this Brochure, there are no legal or disciplinary events to report that are material to a client’s or prospective client’s evaluation of ECFS’s advisory business or the integrity of its management. 15 323207651.4  Item 10: Other Financial Industry Activities and Affiliations ECFS is a part of East Capital Group, having offices in Hong Kong, Luxembourg, Stockholm and Tallinn. ECFS is a portfolio manager under the investment management agreement to its sister company, East Capital Asset Management SA (“ECAM”). ECAM is authorized by the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg, with registration number S 940, as a management company under Chapter 15 of the 2010 Law and as an AIFM, with registration number A 545 under article 5 (2) of the AIFM Law. The corporate identification number is B136 364. ECAM is dual-licensed under the UCITS and AIFMD regulatory frameworks. It manages East Capital SICAV and Espiria SICAV, UCITS platforms for investment strategies focusing on emerging/frontier markets and global equities/ fixed income respectively and acts as AIFM for real estate AIFs (and managed within the East Capital Group). 16 323207651.4  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ECFS has adopted a Code of Ethics pursuant to SEC rule 204A-1 that includes: the ethical foundation • Standards of business conduct that ECFS requires of its supervised persons, which reflect ECFS’s fiduciary obligations and those of its supervised persons. ECFS’s Code of Ethics establishes for all supervised persons of ECFS, emphasizing professionalism, integrity, and respect, aiming to maintain trust in both the company and the financial markets in which it operates; • Provisions requiring its supervised persons to comply with applicable U.S. federal securities laws, including policies designed to prevent conflicts of interest and insider trading; and • Provisions that require all ECFS “access persons” (as defined in rule 204A-1) to report, and ECFS to review, their personal securities transactions and holdings. As required pursuant to SEC Rule 204A-1, ECFS will provide each of its supervised persons with a copy of the Code of Ethics and any amendments and will require its supervised persons to provide a written acknowledgment of their receipt. Supervised persons are required to report any violations of the Code of Ethics promptly to ECFS’s chief compliance officer or its designee. ECFS has adopted a personal trading policy that ensures that all personal trading activities by supervised persons are conducted with integrity, transparency, and full compliance with regulatory and ethical standards. This policy is designed to prevent conflicts of interest and insider trading, especially given the Group’s investment operations in markets with limited transparency and liquidity. It applies to employees and related persons (e.g., close family members and entities under their influence), and addresses trading in financial instruments, including public and OTC securities. Under this policy, transactions involving instruments in the East Capital Group Universe (i.e., securities held or likely to be held in managed portfolios) are prohibited unless explicitly approved. Covered persons with access to non-public, price-sensitive information are prohibited from trading the related securities and must not influence others to trade in restricted instruments on their behalf. Compliance Officers and a dedicated personal trading team oversee compliance, maintain transaction logs, and perform regular audits. Officers and employees of ECFS, as well as those of our affiliated advisory entities, may not buy or sell securities for their own accounts that are also recommended or executed within client portfolios without prior authorization and disclosure. ECFS does not currently engage in principal transactions (where we would trade securities directly with client accounts) or in cross trades (transactions between two client accounts). Should either practice be adopted in the future, it will be conducted strictly in accordance with applicable securities laws and regulations, with full disclosure to affected clients and, where required, prior written consent. 17 323207651.4  Item 12: Brokerage Practices ECFS is in contact with approximately 50 brokers throughout the investment universe, with approximately 20 brokers in frequent contact and approximately 80% of transactions executed through 15 brokers. New brokers are considered if they offer a better proposition than existing brokers in regard to cost of trading, execution capacity, market share, overall quality, coverage (specific stocks or certain regions) and services provided (research and conferences). Best execution is maintained through the application of the Adviser’s Best Execution Policy. Brokers are, through the application of these policies, evaluated based on their skills at executing orders, their availability and general professionalism and their financial stability and compliance with regulations governing their business. For instance, the financial status is evaluated before any trades are performed through a broker and subsequently followed-up annually by questions to the broker and acquirement of financial information. Financial status is also used for determining exposure limits towards the brokers. Commission rates are likewise considered a key component in execution of orders. ECFS does not have soft dollar arrangements with any broker-dealers or third parties in connection with securities transactions on behalf of the CIT. As a general matter, because ECFS is regulated under the EU MiFID II Directive, it must comply with strict “unbundling” rules. These rules require ECFS to clearly separate payments for execution services (trade execution) and research services (investment research). Research cannot be received for free or bundled implicitly into brokerage commissions. Instead, research must be paid either by ECFS directly out of its own resources or a separate, client- funded research payment account under strict transparency rules. ECFS will generally follow its own policies in selecting which brokers to utilize on behalf of the CIT; however, the Trustee may direct ECFS not to utilize certain broker-dealers or transaction counterparties (including, for example, affiliates of the Trustee). Aggregation of orders ECFS may aggregate orders for different portfolios, including the CIT, in a so-called bulk trade, in accordance with our policy on best execution and when we believe that such aggregation will result in overall benefit to our clients No client will receive preferential treatment in any aggregated transaction. Accounts included in an aggregated order will typically receive the average execution price of the transaction and will bear a pro-rata share of the associated transaction costs. Any portfolio that is part of a bulk trade will be given allocation based on its participation in the trade and be given the same price, splitting commissions and fees. Where an aggregated order is executed in full, allocations will be effected in accordance with ECFS’s pre-trade allocation determinations. In instances of partial execution, allocations will be made as decided by portfolio manager in the best interests of the clients. Any such decision must be justified and documented. 18 323207651.4  Item 13: Review of Accounts Pursuant to the IMA, ECFS will review and at least annually make recommendations to the Trustee regarding updates to the IPS for the CIT Funds and compliance rules. In addition, ECFS will provide the Trustee with quarterly compliance and performance-related reports with respect to the CIT Funds. 19 323207651.4  Item 14: Client Referrals and Other Compensation In connection with the services the ECFS provides to the CIT, the ECFS will compensate the distributor pursuant to the terms of a direct agreement to be entered into between the ECFS and such distributor. ECFS does not, either directly or indirectly, compensate anyone else for client referrals. 20 323207651.4  Item 15: Custody The Trustee will at all times hold CIT assets as custodian of each CIT Fund. ECFS does not have custody of the assets of the CIT Funds. 21 323207651.4  Item 16: Investment Discretion The Adviser will have discretionary authority over the assets of the CIT Funds, subject to, and in accordance with conditions set forth in the IPS for each CIT Fund that is subject to prior approval by the Trustee. The IPS may only be amended as provided in the IMA. 22 323207651.4  Item 17: Voting Client Securities ECFS is responsible for voting (or abstaining from voting, if appropriate) all proxies on behalf of each CIT Fund unless instructed not to do so by the Trustee. ECFS will vote proxies in accordance with its proxy voting policies, guidelines and procedures in effect from time to time, a current copy of which has been provided to the Trustee and a copy or summary of which will be available upon request to participating trusts investing in the CIT. Voting rights are exercised in line with ECFS’s Proxy Voting Policy, ensuring that decisions are made in the best interest of the CIT Funds and their investors. ECFS makes its own independent voting decisions and does not rely on advisory recommendations from third-party proxy voting firms. The portfolio managers within the ECFS are responsible for monitoring corporate events and voting according to the firm’s policy and the investment objectives of each CIT Fund. Voting is conducted via proxy or through a power of attorney, with all decisions carefully documented. Additionally, ECFS conducts ongoing oversight of voting execution, reviewing portfolio managers’ voting actions to ensure alignment with the firm’s governance standards. Investment managers are responsible for handling voting via proxy or power of attorney. Voting decisions must be well- documented and justified as being in the client’s best interests. Voting is strictly prohibited if it would breach direct or implicit sanctions, or if it would support sanctioned entities. ECFS will communicate proxy reports to the Trustee at quarterly intervals or as otherwise agreed between ECFS and the Trustee. 23 323207651.4  Item 18: Financial Information ECFS does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this Brochure. Additionally, we are not currently aware of any financial condition that would be reasonably likely to impair our ability to meet our contractual commitments to any client. 24 323207651.4  Item 19: Requirements for State-Registered Advisers ECFS is not currently registered with any state securities authorities. 25 323207651.4