FINAPORT ASSET MANAGEMENT AG

Trigon Investment Advisors AG Gotthardstrasse 55, 8002 Zurich, Switzerland Phone: +41 44 304 2205 ADV Part 2A 25 April 2025 Item 1. Cover Page This brochure (Form ADV Part 2A) provides information about the qualifications and business practices of Trigon Investment Advisors AG (“Trigon”). Trigon is a registered investment advisor (“RIA”) with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). If you have any questions about the contents of this brochure, please contact us at +41 44 304 2205 or info@trigonadvisors.com . The information contained 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. Additional information about Trigon Investment Advisors AG also is available on the SEC website www.adviserinfo.sec.gov. There is no specific level of skill or training required to “register” as an RIA with the SEC. Item 2. Material Changes Since our last annual amendment was filed in March 2025, the following material changes have been made to this disclosure brochure: • As of 24. March 2025 the firm changed its name from Finaport Asset Management AG to Trigon Investment Advisors SA. This change was reflected in the official corporate register of the Canton of Zürich, effective 24. March 2025. • On 31. March 2025, our then shareholder, Finaport Holding AG, in turn owned by Hellmut Schuemperli and Alexei Borissov sold all its shares to our new owner, Wolfgang Klien. • The existing board members have stepped down. New directors have taken office, as shown in Form ADV Part 1, Schedule A. • A new Chief Executive Officer (CEO) and Chief Compliance Officer have taken office, as disclosed in Form ADV Part 1, Schedule A. • There is now one direct owner and no indirect owners of Trigon Investment Advisors SA, Wolfgang Klien, as shown in Form ADV Part 1, Schedule A and B. • The position of the former CEO, Patrick Marty, will be upgraded to Board Member in order to assist Wolfgang Klien with the reorganisation and to ascertain a solid nexus to the former organization. • As an SEC registered investment advisor, we continue to offer our services uninterrupted. No other company was involved with this transaction. We did not close, change our legal status, pass our business to anyone or sell assets or liabilities. As such, this was a change in control. Disclosures have been made to this effect in our Form ADV Part 1 and updated our Form CRS. 1  Since the last brochure was filed on 27. March 2025, we have had the following material changes, reflected in the official Register of Companies of the Canton of Zürich, effective 24 March 2025 • We moved our office from Fraumuensterstrasse 9, 8001 Zurich, to Gotthardstrasse 55, 8002 Zurich • Patrick Marty resigned from his position as CEO as of 31 March 2025 and has been offered to position of a member of the Board to ensure continuity. • Wolfgang Klien became CEO and Chief Compliance Officer (CCO). As disclosed in our last regulatory filing, the application for the Swiss license to act as portfolio manager under Swiss law will be submitted to FINMA, the Swiss Financial Markets Regulator, in 2025. The submission is currently in preparation. As per 1 April, Trigon has no investment advisory clients. In future filings, this section of the brochure will disclose the material changes that have been added since the last amendment to this brochure as filed with the SEC and available on the SEC's public disclosure website ("IAPD"), www.adviserinfo.sec.gov. If you would like a copy of this brochure, you may download it from IAPD or contact us. Item 3. Table of Contents Item 1. Cover Page Item 2. Material Changes Item 3. Table of Contents Item 4. Advisory Business Item 5. Fees and Compensation Item 6. Performance-Based Fees & Side-by-Side Management Item 7. Types of Clients Item 8. Methods of Analysis, Investment Strategies & Risk of Loss Item 9. Disciplinary Information Item 10. Other Financial Industry Activities and Affiliations Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12. Brokerage Practices Item 13. Review of Accounts Item 14. Client Referrals and Other Compensation Item 15. Custody Item 16. Investment Discretion Item 17. Voting Client Securities Item 18. Financial Information 1 1 2 3 4 4 6 6 9 9 11 12 15 15 15 15 15 16 2  Item 4. Advisory Business Firm Description his or her risk tolerance. Generally, client investments are concentrated in non-US securities consistent with most clients’ objective of obtaining jurisdictional diversification from the US. Investment Advisors SA Whilst generally Trigon makes investments with a longer time horizon, Trigon may recommend changes to allocations in an attempt to take advantage of conditions in the current economic environment whilst being sensitive to transaction costs and taxes, as applicable. Such allocation changes may involve short-term underweight or overweight positions to various asset classes designed to capitalize on current economic conditions over the short-term. Trigon's advice is limited to the types of securities and transactions as set forth in Item 8. Trigon does not render any legal or tax advice. Discretionary Asset Management Services Trigon (Trigon) was incorporated in 2007 under Swiss law, in the Canton of Zürich. Trigon is an advisory firm that provides investment management and advisory services to persons and entities who are residents of the United States and United States citizens located overseas (U.S. Persons”). Located in Switzerland, the Firm has been established to give U.S. Persons opportunities to avail themselves of investment management and advisory services that focus on a broad range of international markets and multi-currency alternatives, in addition to U.S. dollar-based investments in the U.S. markets. Trigon also serves US taxpayers or dual citizens living outside the US and in certain cases may work with clients who are not resident in the US or US taxpayers. Principal Owners Trigon is 100% owned by Wolfgang Klien. the authority Services investment management agreement both discretionary Upon receipt of the license from the Swiss regulator to operate as portfolio manager (application pending), Trigon will offer discretionary asset management to services whereby Trigon has supervise and direct the investments of and for each client’s account without prior consultation with the client. Trigon determines the securities that are bought and sold for the client’s account and the total amount of the purchases and sales. Trigon's authority may be subject to conditions or restrictions imposed by individual clients as set forth and agreed upon in the (IMA) entered into between Trigon and the client. For example, a client may restrict or prohibit transactions in certain types of securities. investment advisory Conditional upon receiving the requisite license from FINMA, the Swiss Market Regulator, to act as portfolio manager under Swiss law (The Financial Services Act of 2020), Trigon will provide wealth management solutions to high-net-worth individual clients as well as companies. Trigon will continue to offer asset management (investment management mandates) and non- discretionary services (investment advisory mandates). Client’s assets are to be managed in separately managed accounts ("SMAs" or “account”) maintained at a third-party financial institution. Trigon seeks to obtain a rate of return consistent with each client’s objectives, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Generally, Trigon manages each client’s portfolio in the line with model portfolios constructed by investment committee of the firm. However, these model portfolios serve mainly as a general guide, therefore not every client’s portfolio will replicate the model portfolio as a result in differences in client risk tax ramification, client specifications, tolerance, liquidity and timing. traded Client Accounts following these strategies will be broadly managed in a similar manner. However, differences in portfolios may occur due to portfolio risk size, client-specific investment objectives, As earlier, Trigon client portfolio strategies are diversified across a variety of asset classes, including cash, US dollar and non-US dollar currencies, defensive strategies in marketable securities, growth strategies in marketable securities, and, in certain cases, private investments. Accounts may include, without limitation: equity securities, fixed income securities, limited partnership interests, mutual funds, exchange funds, options, funds, hedge structured product investments, digital assets and other alternative investments consistent with a client’s suitability, his or her overall investment strategy, and TRigo3  time horizon, liquidity needs, tolerance, tax considerations, reference currency, legal restrictions and overall suitability. Non-discretionary Asset Management Services termination of any relationship, accrued, unpaid fees will be due and payable. Trigon may waive, discount and/or negotiate fees at its discretion. Trigon may also charge additional fees for services outside the scope of the services described above. Any additional fees are to be agreed in writing by the client and disclosed accordingly. Trigon generally relies on the custodian bank to value the assets in each client’s account. Trigon typically will arrange with the custodian for the direct payment of its fees from the client’s account. For clients who desire a non-discretionary investment advisory service, Trigon will offer investment advice similarly to its discretionary asset management service in a non-discretionary mandate whereby prior consultation and client approval is required before Trigon purchases or sells any security. Trigon works with its non-discretionary clients to define their investment objectives and consults with each client on a regular basis with investment suggestions in line with the defined objectives. Wrap Fee Programs Trigon is a fee-only investment advisor and does not receive undisclosed remuneration from third parties in connection with its investment advisory services. Discounts, finder’s fees or any other remuneration received by Trigon from third parties will be disclosed to the client and, unless otherwise agreed upon in writing with the client, be credited to the client’s account. Other Fees and Expenses you may incur Trigon does not participate in any wrap fee programs. This means the custodian and Trigon will always invoice separately. The client has full transparency of all fees charged by Trigon. Assets under Management fees for trade As per 22. April 2025, Trigon has no assets under management. Fees charged by Trigon do not include custodian fees, settlement, brokerage commissions, taxes or any other third-party charges. The fees also do not include management or other fees charged by funds or other products that client accounts may be invested in from time to time. Item 5. Fees and Compensation Item 6. Performance-Based Fees & Side-by-Side Management Performance-Based Fees into performance-based Trigon's fees generally are charged as a percentage of the market value of assets under management (“AUM”) or assets under advisement (“AUA”). The asset management fee charged is levied quarterly on the basis of the average assets at the start of the three months of each quarter (e.g. for the first quarter of a year the average assets are the average assets per 1 January, 1 February, 1 March). The fee generally is charged either in the reference currency of the account, or as an equivalent in Swiss Francs. Annual Percentage Fee Schedule investment strategies and As show the tables below, Trigon offers its clients different several management fees for each of them. Trigon does not have a minimum amount of assets to be managed. Trigon may enter fee to arrangements with qualified clients subject individualized agreements with each client. To the extent Trigon may enter into performance or incentive fee arrangements, it will do so in accordance with Section 205(a)(1) of the Advisers Act and Rule 205- 3. Only clients who meet the following requirements may opt for the performance-based fee scheme: (i) clients with at least $ 1,100,000 under management with Trigon; (ii) clients with more than $ 2,200,000 of net worth, excluding the value of the primary residence and certain debt secured by the property; or (iii) clients who are qualified purchasers under Section 2(a)(51) of the Investment Advisors Act of 1940, as amended (which generally is defined to include only individuals with more than $ 5,000,000 in investments or an entity such as corporations, trusts, Accounts initiated or terminated during a calendar quarter will be charged on a pro-rata basis. Upon 4  partnerships, or institutional investor that owns and invests on a discretionary basis at least $ 25 million in investments). Agreement, adjusted for the year, the performance-based fee will be due at the time of the cancellation, calculated as difference between AUM at the beginning of the calendar year and AUM at the time of the cancellation of the Advisory any inflows/outflows of funds during the period. New relationships established during the year will be charged at the respective pro-rated fee. At the time the amount is charged to the account, and upon request by the client, Trigon will notify the client in writing that the fee has been debited and include the its calculation basis. Trigon will generally bill management fee quarterly and its performance fee annually. Side-by-Side Management the adviser will fee which When managing many client accounts and because of differences in the fees charged on various accounts, Trigon has conflicts related to such side-by- side management of different accounts. For example, Trigon may manage more than one account according to the same or a substantially similar investment strategy and yet have a different fee schedule applicable to such account because of the respective clients’ AUM with Trigon. Trigon may therefore offer investment management services on both (i) an annual percentage fee basis, and (ii) on a combined annual percentage fee plus performance fee basis, which includes a reduced fixed annual percentage fee. As previously outlined, when we manage assets on a performance basis, the performance fee we receive in addition to our annual percentage fee is 10% of the annual increase in the AUM, adjusted for asset deposits and withdrawals. When an investment adviser, such as Trigon, manages client assets simultaneously on both a performance fee and non-performance fee basis (commonly referred to as side-by-side management) there is a general perception that certain “conflicts of interest” could exist, which include: (i) the adviser may take additional risks in managing performance based assets because the adviser will share in gains and income generated in performance based accounts, and (ii) the adviser may favor performance based accounts over non-performance based accounts, receive a again, because performance-based increases with enhanced performance. into a performance Trigon may potentially receive higher fees with a performance-based compensation structure than from accounts that pay the asset-based fee schedule as described above. To minimize this conflict, Trigon generally will enter fee arrangement only upon the specific request of a client or in the case of specific investment performance objectives. The performance fee is calculated at the beginning of every year on the basis of the performance of the preceding year. Side-by-side management of different types of accounts may raise conflicts of interest when two or more accounts invest in the same securities or pursue a similar, although not identical, strategy. These potential conflicts include the favorable or preferential treatment of an account or a group of accounts, conflicts related to the allocation of investment opportunities, particularly with respect to securities that have limited availability, such as new bond subscriptions, and transactions in one account that closely follow related transactions in a different account. In addition, the results of the investment activities for one account may differ significantly from the results achieved for other accounts, particularly if Trigon individually tailors’ clients’ accounts. The performance-based fee component is 10% of any positive annual return, which is calculated based upon the difference between the AUM at the beginning of the year (or if a new account, when the account is established) and the AUM at the end of the year, adjusted for any inflows/outflows of funds during the year. The performance-based fee will be paid at the beginning of every calendar year, based on the performance of the previous year. In the event that a client participating in a performance fee program decides to cancel its Investment Advisory Agreement / Asset Management Agreement with our firm during Trigon has policies and procedures in place aimed at ensuring that all client accounts are fairly and equitably treated. Trigon strives to equitably allocate investment opportunities among relevant accounts over time. In addition, investment decisions for each account are made with specific reference to the individual needs and objectives of the account. Accordingly, Trigon may give advice or exercise investment responsibility or take other actions for some clients (including related persons) that may 5  invited to the differ from the advice given, or the timing and nature of actions taken, for other clients. Investment results for different accounts, including accounts that are generally managed in a similar style, also may differ because of these considerations. Some clients may not participate at all in some investments in which other clients participate or may participate to a different degree or at a different time. CEO and other members are Committee. The Committee has a fixed agenda and includes updates about market developments, discussions about markets (USA, Europe, and other markets), an examination of changes in the composition of the mandates that the company offers to its clients, an update about the investment policy of the CIO and other issues on an ad hoc basis, or in accordance with events in the various markets. Item 7. Types of Clients this strategy, there are investment Under predominantly three investment strategies: individual clients, Trigon will offer investment management services to high-net-worth families, corporations, trusts and charities. (i) Conservative Item 8. Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis Our methods of analysis include reviewing the global macro-economic financial environment and political landscape to determine how to best invest via various asset classes, currencies and specific investments. Our conservative portfolios emphasize real-term capital preservation with portfolio earnings obtained primarily through steady income. We focus on making recommendations and investments which are below average risk. When implementing a conservative structure, we focus on liquidity and fixed income securities (bonds) are over weighted compared to equity securities. A typical conservative portfolio will be composed of approximately 80% fixed-income securities and 20% equity securities. The conservative investment strategy • We may use a combination of both fundamental analyses as well as a technical analysis in making investment decisions: • seeks to achieve moderate long-term growth in the value of assets returns are generated from income (interest, dividends) combined with modest capital gains • modest risk, low fluctuations in the value of assets. (ii) Balanced > Fundamental Analysis: In terms of fundamental analysis, we will apply fundamental economic analysis and take into consideration factors such as interest rates, inflation, unemployment, public and foreign debt, trade balances, monetary and fiscal policy, geopolitical developments and many other factors. > Technical Analysis: In terms of technical analysis, we may only use it as a timing tool to make buying and selling decisions, rather than what securities or currencies to buy. The use of technical analysis will be limited. Investment Strategies Clients that select us to provide either investment management or advisory services can select one of the three following investment strategies: 1. Investment Committee strategies Our balanced portfolios are based upon obtaining real-term capital preservation and long-term capital growth, with portfolio earnings through steady income and capital and currency gains. When implementing a balanced portfolio, we focus on making recommendations and investments that have an average risk tolerance, with some fluctuation in asset value We might use derivative instruments to hedge against such fluctuations via hedging. Liquidity and fixed-income securities (bonds) are either slightly over or underweighted compared to equities depending on our view of the markets and relative value considerations. A typical balanced structure will be composed of approximately 50% fixed-income securities and 50% equity securities. The balanced investment strategy • seeks to achieve long-term growth in the value of assets The company's investment committee gathers once a month. The company's Relationship Managers, the 6  income • returns generated from current (interest/dividends) and capital gains medium risk, mid-size fluctuations in the value of assets. (iii) Growth When selecting the satellite holdings of the equity portfolio (approximately 25-50%), we try to identify “trends” (i.e., alternative energy, emerging markets, etc.) and hope to outperform the market in the short term. We realize that with this part of the investment strategy there is a risk that we invest in “trends” that may never materialize in higher equity prices, or in trends’ that may be and remain out of favor and volatility may be higher than in our core holdings. Both the core and satellite holdings carry a risk of possible loss of principal, and/or our investment strategy could underperform other types of investments. Types of Securities Our growth structure is based upon obtaining long- term capital growth primarily through capital and currency gains. When implementing a growth structure, we focus on investments that have an above-average risk tolerance whereby a higher degree of fluctuation in asset value may occur. Derivative investments are used in developing and implementing a dynamic portfolio structure. Equities are overweighted compared to liquidity and fixed- income (bonds) securities. A typical growth structure will be composed of approximately 80% equity securities and 20% fixed-income securities. The growth investment strategy • • seeks to maximize asset growth long-term return generated from capital gains with a lower consideration of generating income (from interests and dividends) • high risk, large fluctuations in the value of foreign exchange assets. In addition to these three main investment strategies Trigon also offers pure Fixed Income or pure Equity Investment Strategies with allocations of up to 100% in the relevant asset class. Trigon offers investment management and advisory services on the following types of securities and transactions: exchange-listed securities, securities traded over-the-counter, securities issued by non-US issuers, corporate debt securities (and other commercial paper), certificates of deposit, investment company securities such as mutual funds, US or traded foreign government securities, exchange funds, transactions, certain derivatives or structured products, digital assets and in certain cases private fund investments. Some of these securities, particularly those issued outside of the US, may not be registered with the SEC. Trigon is able to invest clients on a discretionary basis in securities offered outside the US to non-US investors in reliance on Regulation S under the Securities Act of 1933. to selecting one of 2. Tailored client services In addition the strategies mentioned above, Trigon offers also portfolio structures that are individually tailored to the needs and objectives of each client. Clients may impose further restrictions on investing in certain securities or types of securities. Investments in private funds or structured products may be limited to “accredited investors” or “qualified purchasers,” and may require investors to lock-up their assets for a period of time. These investments may have limited, or no liquidity and they may involve different risks than investing in registered funds and other publicly offered and traded securities. In the context of a discretionary mandate, Trigon may invest client accounts into such securities without client consent. in making Trigon will rely on the accuracy of a client’s representations corresponding representations regarding the investment restrictions on behalf of a client’s account in connection with certain derivative, private fund or other similar investments with qualification restrictions. Trigon types of When selecting the core holdings of the equity portfolio (approximately 50-75%), Trigon focusses its fundamental analysis on factors such as cash flow, Price/Earnings ratio, Price/Book Ratio, Price/Sales Ratio, and generally select securities that are traded at a discount to the market. Even though we believe that purchasing securities at a discount to their intrinsic value provides an investor with an adequate “margin of safety“, we realize that this investment strategy carries a risk of possible loss of capital over shorter time periods, and our investment strategy could underperform investment the strategies. 7  requires notification by the client if the client’s representations become inaccurate. Material Investment Risks rating agencies. Prices are often closely linked with the company’s stock prices. High-yield securities can experience sudden and sharp price swings due to changes in economic conditions, stock market activity, large sales by major investors, default, or other factors. Developments in the credit market may have a substantial impact on the companies Trigon may invest in and will affect the success of such investments. In the event of a default, the investment may suffer a partial or total loss. Clients should bear in mind that investing in securities involves a risk of loss. Clients should be prepared to bear the risk of losing their investment in securities. Past performance is not an indication as to future performance. Among other risks, all investments made by Trigon will be subject to market risk, liquidity risk, and interest rate risk, and may be subject to credit and counterparty risk, risk in fluctuations of commodity pricing, risk of loss due to political and economic developments in foreign markets, and risks involving movements in the currency markets. funds. Each fund and charge level of Market Risk: Market risk refers to the risk of loss arising from general economic and market conditions, such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty, changes in laws and national and international political circumstances. Each account is subject to market risk, which will affect volatility of securities prices and liquidity. Such volatility or illiquidity could impair profitability or result in losses. factors affecting fall Risk Related to Equity Investments: Investments in equity securities generally involve a high degree of risk. Prices are volatile and market movements are difficult to predict. These price movements may result individual companies or from industries. Price changes may be temporary or last for extended periods. The value of specific equity investments generally correlates to the fundamentals of each particular security, but prices of equity regardless of rise or investments may fundamentals due in securities to movements markets. Risks Related to Investments in Funds: For purposes of this discussion, the term “Fund” includes, but is not limited to, a US or non-US unit investment trusts, open-end and closed-end mutual funds, hedge funds, private equity funds, venture capital funds, real estate investment trusts, exchange traded funds (“ETFs”) and any other private alternative or investment fund. Investments in funds carry risks associated with particular its respective its own investment managers will management and other fees, which will result in the client bearing an additional fees and expenses. US mutual funds generally must distribute all gains to investors, including investors who may not have an economic gain from investing in the fund, which can lead to negative tax effects on investors, particularly non-US persons. Investments in certain non-US funds by US persons result in US tax and reporting obligations and failing to comply with such requirements can result in significant penalties. Funds generally have unique risks of loss as described in their offering documents. Funds can make use of leverage to enhance returns, which raise the risk of default, interest rate risk, and increase volatility. Certain funds invest in derivatives, which can raise specific counter-party risks. Funds that are not traded can have illiquidity and valuation risks resulting in the inability to redeem or sell the fund when necessary. See the discussion below relating to risks in structured products and derivatives for more information on the risks of investing in funds. to Fixed Income invest Risks related to Structured Products & Derivatives: Trigon may in structured products or derivatives or invest in funds that hold investments in structured products or derivatives. In addition to the risks that apply to all investments in securities, investing in and engaging in derivative instruments and transactions may involve different types of risk and possibly greater levels of risk. These risks include, but are not limited to the following: Risks Related Investments: Investments in fixed income securities (i.e., bonds) represent numerous risks such as credit, interest rate, reinvestment, and prepayment risk, all of which affect the value of the security and volatility of such value. In general, bonds with longer maturities are more sensitive to price changes. Additionally, the prices of high-yield, fixed-income securities fluctuate more than high-quality debt issues. Prices are especially sensitive to developments affecting the company’s business and to changes in the ratings assigned by 8  conditions; but this liquidity may disappear during times of market instability or severe disruption. leverage may have Less Accurate Valuation: The absence of a liquid market for over-the-counter derivatives increases the likelihood that Trigon will be unable to correctly value these investments. Leverage. Certain investment instruments such as derivatives may use leverage to achieve returns. The the effect of use of disproportionately increasing an account’s exposure to the market for the securities or other assets underlying the derivative position and the sensitivity of an account’s portfolio to changes in market prices increases both the for those assets. Leverage positive impact of successful investment decisions and the negative impact of unsuccessful investment decisions by Trigon on the performance of the investment portfolio. that Risks Relating to Foreign Currency Exposure: Accounts managed by Trigon are routinely subject to foreign exchange risks and bear a potential risk of loss arising from fluctuations in value between the US Dollar and such other currencies. Trigon may decide to invest in securities and instruments which are denominated in currencies other than US Dollars. Some clients’ accounts hold significant foreign cash positions. Accordingly, the value of such assets may be affected favorably or unfavorably by fluctuations in currency rates. Often clients are seeking this foreign currency exposure. Trigon may seek to hedge foreign currency exposure of an investment portfolio. In other situations, Trigon may decide not to hedge the currency exposure outside the reference currency of an investment portfolio. Investments: Investments Counterparty Credit Risk: When a derivative is purchased, a client’s account will be subject to the ability and willingness of the other party to the contract (a “counterparty”) to perform its obligations under the contract. Although exchange traded futures and options contracts are usually backed by a guarantee from a clearing corporation, an account could loose the benefit of a contract in the unlikely event the clearing corporation becomes insolvent. A counterparty’s obligations under a forward contract, over-the-counter option, swap or other over-the-counter derivative contract may not be guaranteed. If the counterparty to an over-the-counter contract fails to perform its obligations, an account may lose the benefit of the contract and may have difficulty reclaiming any collateral that an account may have deposited with the counterparty. Non-US in non-US securities expose the client’s portfolio to risks which are in addition to those risks associated with investments in US securities. Such risks include, amongst others, trade balances and imbalances, economic policies of various foreign governments, exchange control regulations, withholding taxation, potential for nationalization of assets or industries, and political instability of foreign nations. Item 9. Disciplinary Information Trigon has not been involved in any legal or disciplinary events. in Lack of Correlation: The market value of a derivative position may correlate imperfectly with the market price of the asset underlying the derivative position. To the extent that a derivative position is being used to hedge against changes in the value of assets in an account, a lack of price correlation between the derivative position and the hedged asset may result in an account’s assets being incompletely hedged or not completely offsetting price changes the derivative position. Item 10. Other Financial Industry Activities and Affiliations As of the time of this report Trigon is not yet registered with the Swiss financial markets regulatory authority but such is currently in the process of registration with the Swiss Financial Markets Supervisory Authority. Illiquidity: Over-the-counter derivative contracts are usually subject to restrictions on transfer, and there is no liquid market for these instruments. Although it is often possible to negotiate the termination of an over- the-counter contract, or to enter into an offsetting contract, a counterparty may be unable or unwilling to terminate a contract with a party, especially during times of market instability or disruption. The markets for many exchange-traded futures, options and other instruments are quite liquid during normal market Trigon's management personnel are neither registered, nor have an application pending to register as broker-dealers, registered representatives of a broker-dealer, future commission merchants, trading commodity pool operators, commodity 9  advisors, or associated persons of the foregoing entities. 10  Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The Code also provides for Trigon's execution of supervisory policies and procedures, and the review and enforcement processes of such policies and procedures. Trigon has designated a Chief Compliance Officer responsible for maintaining, reviewing and enforcing Trigon's Code of Ethics and corresponding policies and procedures. Trigon seeks to minimize conflicts of interest and resolve those conflicts of interests in favor of its clients to the extent it determines reasonable and necessary in accordance with its Code of Ethics, however, Trigon may receive indirect compensation from time-to-time as a result of its investment advisory activities, and Trigon recognizes that this presents a conflict of interest as described elsewhere in this brochure. Code of Ethics The fundamental position of Trigon is that, in effecting personal securities transactions, personnel of Trigon must always place the interests of clients ahead of its own pecuniary interests. All personal securities transactions by these persons must be conducted in accordance with the Code of Ethics and in a way to avoid any actual or potential conflict of interest or any trust and abuse of any person’s position of responsibility. Further, these persons should not take inappropriate advantage of their positions with or on behalf of a client. restrictions on If a person subject to the Code of Ethics fails to comply with the code, such a person may be subject include warnings, to sanctions, which may disgorgement of profits, future personal trading, and, in the most severe cases, the possibility of dismissal. Trigon treats all clients equitably and has a duty to act in its clients’ best interests. Except as otherwise described in this brochure, the interests of clients will be placed above Trigon's interests in case of any conflict. Trigon has adopted a Code of Ethics (the “Code”) and attendant policies and procedures governing personal securities transactions by Trigon and its personnel. The code also provides guidance and instruction to Trigon and its personnel on their ethical obligations in fulfilling its duties of loyalty, fairness and good faith towards the clients. Trigon will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions take The overriding principle of Trigon's Code of Ethics is that all employees of Trigon owe a fiduciary duty to clients for whom Trigon acts as investment advisor. Accordingly, employees of Trigon are responsible for conducting personal trading activities in a manner that does not interfere with a client’s portfolio transactions or improper advantage of a relationship with any client. Although Trigon does not hold proprietary positions, Trigon's related persons may own, buy, or sell for themselves the same securities that they or Trigon have recommended to its clients. Thus, from time to time, a client account may purchase or hold a security in which a related person of Trigon has financial interest or an ownership position, or a related person may purchase a security that is held in a client account. Also, from time-to-time, Trigon employees or related persons may invest alongside the firm’s clients, both to align the interest of firm and personnel and the firm’s clients and as an expression of confidence in our portfolio management strategies. The Code contains provisions designed to try to: (i) prevent, among other things, improper trading by Trigon's employees; (ii) identify conflicts of interest; and (iii) provide a means to resolve any actual or potential conflicts of interest in favor of the clients. The Code attempts to accomplish these objectives by, among other things: (i) requiring pre-clearance of specific trades, which includes documenting any exceptions to such pre-clearance requirements; (ii) restricting trading in certain securities that may cause a conflict of interest, as well as (iii) periodic reporting regarding transactions and holdings of employees. this conflict of To minimize interest, securities recommended by Trigon are widely held and publicly traded. In addition, in accordance with its fiduciary duty to clients, Trigon and associated persons will place client interests ahead of their own interests. Any The Code contains sections including, but not limited to, the following key areas: (i) restrictions on personal investment activities; (ii) gifts and business entertainment; and (iii) outside business activities. 11  be a registered broker-dealer under the Exchange Act. Client Directed Brokerage transactions must be carried out in a manner that does not work to the disadvantage of clients’ transactions or result in a conflict of interest, or even the appearance of a conflict of interest. To ensure that Trigon personnel never trades ahead of their clients, the firm requires all trading in specific positions for officer and employee accounts to come after the analogous trades are executed for client accounts. Item 12. Brokerage Practices A client may direct Trigon to use a particular broker or dealer who has an existing relationship with, or provides custodial or other services, to a client. Trigon requires any directed brokerage instructions to be in writing unless such arrangement is inferred in the context of the custodian’s brokerage limitations. Consequently, all Swiss custodian banks require the use of its brokers. Trigon treats such arrangements as client-directed brokerage because the client has selected the custodian bank. Trigon's clients primarily open accounts at custodial banks in Switzerland. Each client may select the bank for his or her account and accounts can be booked with US custodians as well. Trigon does not select custodial banks on behalf of the client. Before choosing to enter into a directed brokerage arrangement, clients should be aware of the following disadvantages: Each custodian bank has its own policies and procedures relating to brokerage. Generally, the custodial banks require Trigon to route securities orders through the trading desk of the bank thus not permitting Trigon to select the broker-dealer. As Trigon will not have discretion in selecting the broker- dealer, the client should be aware of the incumbent risks associated with such arrangement. Trigon will select and recommend any brokers, exchanges, or custodians based on several factors, including, but not limited to, ease of administration, quality of execution, commission rates, and pre- existing agreements. Trigon generally seeks to minimize the total price (considering applicable exchange fees) for each transaction. Brokers Selected by the Custodian Bank from aggregated - Trigon will not be able to negotiate commission rates with the designated broker because it will not have the negotiation leverage resulting from the ability to trade away from a designated broker. - Directed brokerage may cost clients more. Directed brokerage clients may pay higher commission rates than those paid by other clients, may receive less favorable trade executions, and may not obtain the best execution on transactions. - Directed brokerage accounts will not be able to participate in aggregated or block transactions with other clients. This will preclude directed from obtaining volume brokerage accounts discounts or more favorable terms that might be available transactions as prescribed by the custodian. - If Trigon is placing orders in the same security for both directed brokerage clients and clients that use other brokers, Trigon usually places orders for directed brokerage clients after it has placed orders for other clients. Trigon Selection of Broker-Dealers When the custodian bank permits Trigon to select the broker-dealer, Trigon will route securities orders to purchase and sell securities for those client accounts held at the bank to independent brokers and dealers. In selecting brokers and dealers to effect client transactions, Trigon attempts to obtain for clients: (i) the prompt execution of client transactions while market conditions still favor the transaction and (ii) the Brokerage for transactions involving assets held at Swiss banks generally must be made through the broker-dealer specified by the custodian bank. In most cases, Swiss custodian banks act as a broker- dealer and/or maintain relationships with designated broker-dealers (including potentially an affiliate of the custodian bank). If required, Trigon effectuates security transactions through the custodian bank, or the broker or dealer designated by the custodian bank selected by the client. In such cases, Trigon cannot guarantee that the client will receive the best execution or the best commissions because these factors are outside the control of Trigon Clients should be aware of the factors outlined below under the heading Directed Brokerage as these factors also apply with respect to assets maintained at Swiss banks. Clients should also be aware of the potential that the broker-dealer used for transactions may not 12  any other issues. Trigon will periodically reconsider as to whether to be placing a client trades’ through particular broker continues to be in the best interest of its clients. execution given the Block Trades As it is Trigon policy not to aggregate client transactions, but to do such transactions on a client- by-client basis through the respective custodial banks, the transaction costs and commissions for each client may differ. most favorable net prices reasonably obtainable. This is referred to as “best execution.” In placing orders to purchase and sell equity securities, Trigon selects brokers that it believes will provide the best overall qualitative particular circumstances. A broker may provide more favorable terms and a higher quality of service to customers who place a higher volume of transactions through that broker. Accordingly, to obtain the benefits of higher volume trading for clients, Trigon may place a large portion of client equity transactions through a limited number of brokers that meet Trigon's quality standards. When selecting a new equity broker, Trigon conducts a due-diligence review of the broker to evaluate as to whether or not the broker is likely to provide best execution. To this end, Trigon may consider any of the following factors: - The ability of the custodian bank to settle transactions with the broker. - The quality of services provided further (including commissions, which may not be the lowest available, but which ordinarily will not be higher than the generally prevailing competitive range). - The extent of coverage of the various markets Trigon trades in. - The broker’s ability to communicate effectively with Trigon. - The broker’s ability to execute and settle difficult trades. fee”, or based on - The broker’s ability to offer transactions at lower cost due to electronic trading. - The broker’s clearance and settlement efficiency. - The broker’s ability to handle Trigon's range of order sizes. - The broker’s ability to maintain confidentiality and Should Trigon combine orders into block trades when purchasing the same security for multiple client accounts, such aggregated orders (“block trades”) will be pre-allocated amongst the participating client accounts. When selecting the participating accounts, a variety of factors such as suitability, investment objectives and strategy, risk tolerance and/or the ability to invest additional funds will be taken into consideration. In determining the portion for each participating account factors such as account’s size, diversification, asset allocation and position weightings as well as any other appropriate factors might be of relevance. Accounts participating in a block trade placed with the same broker or with the same custodian generally receives an average price. Transaction costs will be shared on a proportionate basis and as agreed with the custodian. This can either be a sharing on a pro rata basis, or covered with a “ticket the implemented degressive model, whereas costs decrease in relation to the purchased quantity and include the application of a minimum rate, when shared costs are below a defined amount. Partial fills of transactions will be allocated on a pro-rated share basis. anonymity. - The reputation of the broker. - The stability and financial strength of the broker. Since Trigon is based in Switzerland and many of the securities purchased are non-US securities, the brokers used by Trigon may not be registered with the SEC under the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”). Because Trigon's clients maintain accounts at different custodian banks, and because many of these custodian banks mandate the use of a specific broker (see description above), Trigon may need to place one block trade for the same security with more than one broker. Trigon transmits such block trades to more than one broker in a random pattern (i.e., Trigon does not favor one custodian bank or broker over another with respect to the order in which block trade orders are sent). The average price realized on a securities order placed with different brokers will vary between different brokers, and clients generally receive different average prices and transaction costs the same security order between different for Trigon's Chief Compliance Officer reviews the due diligence performed and approves or rejects the selection of each broker. On a regular basis, Trigon monitors the services provided by the approved brokers, the quality of executions and research, commission rates, overall brokerage relationship, and 13  the practice of the in the custodians and brokers used for such block trades. Also note, since most Swiss custodian banks warehouse securities orders until filled, there may be in settlement between client accounts delays depending on respective custodians and/or brokers. 28(e) of the Exchange Act. Section 28(e) is a “safe harbor” that permits an investment manager to use brokerage commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance investment decision-making process. Decision Making Process; Balancing the Interests of Multiple Client Accounts the adviser-client relationship Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data, certain valuation and pricing data and economic data); and advice from brokers on order execution. In making the decision as to which securities are to be purchased or sold and the amounts thereof, Trigon is guided by the general guidelines set up at the inception of in cooperation with the client and a periodic review of the asset allocation. These general guidelines cover such matters as the relative proportion of debt and equity securities to be held in the portfolio, the degree of risk that the client wishes to assume and the types and amounts of securities held in the portfolio. Trigon's authority may be further limited by specific instructions from the client, which may restrict or prohibit transactions in certain securities. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. Trade Errors is to execute Trigon may manage numerous accounts with similar or identical investment objectives or may manage accounts with different objectives that may trade in the same securities. Despite such similarities, portfolio decisions relating to client investments and the performance resulting from such decisions may differ between clients. Trigon will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible clients, particularly if different clients have selected different investment profiles, have materially different amounts of capital under management with Trigon or different amounts of investable cash available. In certain instances, such as purchases of less liquid publicly traded securities or oversubscribed public offerings, it may not be possible or feasible to allocate a transaction pro rata to all eligible clients, especially if clients have materially differently sized portfolios. Therefore, not all clients will necessarily participate in the same investment opportunities or participate on the same basis. Use of Soft Dollars Although Trigon's goal trades seamlessly in the manner intended by the client and consistent with its investment decisions, Trigon recognizes that errors can occur for a variety of reasons. Trigon's policy in dealing with such errors is to: - Identify any errors in a timely manner. - Correct all errors so that any affected account is placed situation as if the error would not have occurred. Trigon does not currently maintain any soft dollar arrangements. Trigon may however in the future maintain soft dollar arrangements, and to the extent it does, it will only do so in accordance with the conditions of the safe harbor provided by Section - Incur all costs associated with correcting an error or pass on the costs to the broker/ custodian, depending on which party is at fault). Costs from corrective actions are not to be borne by the client. 14  funds in such a product, or for marketing assistance, or for the performance of certain administrative tasks associated with making an investment. - Evaluate how the error occurred and assess if changes in any processes are warranted or if training is required to mitigate such errors going forward. The consequences and the required corrective measures may differ depending on the nature of the error or the account affected. Trigon's employees or associated persons may be invited to attend seminars and meetings with the costs associated with such meetings borne by a sponsoring brokerage firm or other party extending the invitation. Item 13. Review of Accounts Item 15. Custody that Discretionary accounts: All discretionary portfolios are reviewed quarterly to ensure that they remain aligned with the client’s investment strategy, and to ascertain the portfolios are appropriately positioned given current market conditions as part of Trigon’s investment approach. Non-discretionary Non-discretionary accounts: portfolios are reviewed quarterly to make sure investments are consistent with client’s risk profile and investment objectives. Trigon typically is given authority to debit its fees from the clients’ accounts. Consequently, Trigon is deemed to have a fee debit authorization with the custodians. In such cases, Trigon has established procedures to ensure the client’s account is held at a qualified custodian in a separate account for each client. The client establishes the bank account directly and thus is aware of the qualified custodian’s name, address and the way investments are maintained. Account statements are prepared by the custodian bank. Generally, these statements include a listing of all valuations and all transactions occurring during the period. Item 16. Investment Discretion Annual review: The relationship managers are responsible for the periodic review (at least annually) of client portfolios. The annual review covers all key aspects of the client relationship, including, among other things, any changes in the client’s personal and financial situation, risk profile and the suitability of the chosen investment strategy. Item 14. Client Referrals and Other Compensation for Trigon accepts discretionary authority to manage client accounts as described above. Clients rarely restrict the authority by which Trigon may act; however, each client can communicate any form of limitation in writing. In the context of a discretionary mandate, Trigon makes investment decisions without consulting the client by utilizing its limited power of attorney the account the management of maintained at the custodian bank selected by the client. Trigon may pay fees for client referrals. Such arrangements comply with the conditions and requirements of Rule 206(4)-1 under the Investment Advisers Act of 1940. In the context of a non-discretionary mandate, Trigon's investment discretion is limited to an advisory role and Trigon does not implement investment decisions without the approval of the client. Trigon does not have the discretionary authority to select a qualified custodian for a client’s account. Item 17. Voting Client Securities Proxy Voting Trigon is a fee-only adviser. Trigon's policy is not to accept compensation from third parties relating to the investment advice it gives to its clients. To the extent that Trigon receives a referral fee for an investment, recommended by Trigon, it will either reduce the fees owed by the respective client to Trigon, or credit the respective client’s Account for the applicable amount. For these purposes, referral fees include marketing fees, discounts, finder’s fees, service fees, including shareholder service fees, referral fees, 12b-1 fees or bonus commissions paid by mutual funds, privately offered funds, insurance products, variable annuities or other investment products paid to Trigon for recommending an investment, for investing client Trigon generally does not have the authority to vote client proxies. Clients make arrangements directly 15  with their custodian to vote proxies for securities, or where proxy or other solicitation materials have to be sent to. If Trigon inadvertently receives any proxy materials on behalf of a client, Trigon will promptly forward such materials to the client. Trigon exercises investment authority for certain corporate actions (such as, but not limited to tenders, in connection with rights offerings, splits etc.) discretionary accounts. For advisory clients, corporate actions are discussed with them prior to the event taking place. Clients who have questions about proxies may contact Trigon for further information. Class Actions inadvertently received Trigon does not directly participate in class action lawsuits. Trigon will determine whether to return any regarding documentation clients’ participation in class actions to the sender, or to forward such information to the affected clients. Trigon will not advise or act on behalf of clients in any legal proceeding, including bankruptcies or securities shareholder class action litigation involving securities held or previously held in client accounts. Accordingly, Trigon is not responsible for responding to, or forwarding to clients any class action settlement offers relating to securities currently or previously held in the client account. Item 18. Financial Information Trigon has not been the subject of a bankruptcy petition at any time. As of the date of this brochure, Trigon does not believe that it is reasonably likely that any future liability will impact its ability to meet our contractual commitments towards its clients. 16