HOTTINGER

Hottinger & Co Limited Form ADV Part 2A 20 March 2026 Brochure on Form ADV Part 2A Hottinger & Co Limited 20 March 2026 CRD # 316515 SEC File # 801-122761 London SW1Y SAA United Kingdom TEL: + 44 207 227 3405 admin@hottinger.co.uk www.hottinger.co.uk This Brochure provides information about our qualifications and business practices. If you have questions about the contents of this Brochure, please call or e-mail us at the number or e-mail address above. The information in this Brochure has not been approved or verified by the U.S. Additional information about us is , www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. This Brochure applies only to U.S. persons as this term is defined in Rule 902 of Regulation S under the U.S. Securities Act of 1933. 1  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ITEM 2: Material Changes This is the annual amendment to our Brochure on Form ADV Part 2A. We previously amended our Brochure on 1 August 2025. We have the following material changes to report since the last annual amendment of our Brochure. We began to offer non-discretionary (advisory), non-execution services to our U.S. clients, in addition to our discretionary offering. Edmond de Rothschild Suisse ( ) increased its shareholding in Hottinger Group Limited, our parent company, to 88.2%. This figure is now 89.33%. Tim Sharp became our MLRO. Mark Robertson became Chairman of the Hottinger Group Board, Alastair Hunter became Senior Executive Adviser of Hottinger Group and Penny Lovell became Group Chief Executive Officer, and our Chief Executive Officer. We have the following material changes since our Brochure was amended on 1 August 2025. Conor Byrne, our CFO, left us on 31 December 2025. Rob Cloete became a director on 17 October 2025 We will amend our Brochure annually and when there are material changes. 2  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ITEM 3: Table of Contents ITEM 2: Material Changes ....................................................................................................................... 2 ITEM 3: Table of Contents ....................................................................................................................... 3 ITEM 4: Advisory Business ...................................................................................................................... 4 ITEM 5: Fees and Compensation ............................................................................................................ 5 ITEM 6: Performance-Based Fees and Side-By-Side Management ........................................................ 5 ITEM 7: Types of clients .......................................................................................................................... 5 ITEM 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 6 ITEM 9: Disciplinary Information ............................................................................................................ 9 ITEM 10: Other Financial Industry Activities and Affiliations ................................................................. 9 ITEM 11: Code of Ethics, Participation or Interest in client Transactions and Personal Trading .......... 10 ITEM 12: Brokerage Practices ............................................................................................................... 11 ITEM 13: Review of Accounts................................................................................................................ 12 ITEM 14: Client Referrals and Other Compensation ............................................................................. 12 ITEM 15: Custody .................................................................................................................................. 12 ITEM 16: Investment Discretion............................................................................................................ 12 ITEM 17: Voting Client Securities .......................................................................................................... 12 ITEM 18: Financial Information ............................................................................................................. 13 3  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ITEM 4: Advisory Business Hottinger & Co Limited is a London-based wealth manager. We are licensed and regulated by the UK Financial Conduct Authority. We are registered with the SEC as an investment adviser under the Advisers Act. We are a long-established financial services firm with a deep history in banking, wealth management and asset management. Our history is on our website at www.hottinger.co.uk/history. We have 24 employees. Currently, our directors are Penny Lovell (CEO), Tim Sharp (CCO and MLRO) and Robert Cloete (CIO). We are 97.50% owned by Hottinger Private Office Limited. EdR (Suisse) holds a 89.33% equity interest in Hottinger Group Limited, which owns Hottinger Private Office Limited, our parent company. As we disclosed in Item 2, EdR (Suisse) is our majority shareholder, and two management positions have changed. Our indirect owners are set forth in our Form ADV Part 1 Schedule B. Our Related Persons are identified in our Form ADV Part 1 Schedule D Section 7.A. We are, by nature, conservative managers who aim to preserve capital and income whilst delivering consistent investment performance. Our investment professionals collaborate and provide input to our decision-making process that analyses economic and political issues affecting world markets. We aim to achieve our goal of maximising returns within given guidelines through diversification across asset classes, regions, and currencies, recognising that great investment ideas can come from many different sources. or and non-US clients We offer discretionary investment management services to U.S. Retail Investors (defined based on residence We also offer non-discretionary (advisory), non-execution services that offers a family office invest orientated consultancy service that reviews a family governance charter to frame how decisions are made and assists in running the Family Investment Board comprised of wealth management professionals including family members. We do not execute the transactions in this context. We do not manage or operate any pooled investment vehicles. We do not act as a broker-dealer. We offer a multi-manager strategy for Retail Investors. Our strategies and investments/securities are set forth in Item 8, below. including information about investment experience and knowledge relating to the investment of assets, investment objectives, restrictions, investment time horizon, financial situation, readiness, and capacity to assume risks and losses, and a base reference currency. We complete a Client Risk Assessment to identify the degree of risk involved in the client relationship. We perform anti-money laundering and know your customer verifications, after which we and our client sign an investment management agreement Mandate tment objectives, strategy, restrictions, investments, and fees. A non-discretionary (Advisory) client would complete an Engagement Letter that outlines the advisory services being provided, the Terms of reference for any proposed Family Investment Board, and fees. Each agreement is changed when client circumstances dictate. We do not solicit or accept U.S. client orders to buy or sell securities. We do not participate in wrap fee programs. We manage US$ 1,472,337,208 for our clients as at 31 December 2025 4  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ITEM 5: Fees and Compensation based on assets under management We charge a management fee client and recorded in the contract. We do not charge a performance fee. Fees are negotiable. Portfolio Size (US$) Up to the first 2 million1 2 million to 5 million 5 million to 15 million 15 million to 25 million 25 million to 50 million Over 15 million Asset Management Charges (%) 0.90% per annum 0.70% per annum 0.55% per annum 0.45% per annum 0.35% per annum By negotiation Asset Management Charges (US$) Up to 18,000 14,000 to 35,000 27,500 to 82,500 67,500 to 112,500 87,500 to 175,000 By negotiation Client custodians calculate the value of investments/securities/and cash. We calculate our Fee based on quarter-end valuations produced by us based on data from the custodian which is again reconciled within our systems. Our annual external audit includes a review of the Fee calculation methodology and sample calculations which would mitigate any perceived conflict if interest. Fees lue. the client may invest. All such charges Apart from our Fee, clients pay third-party costs, fees and expenses that include custodian fees, trade commissions, issue or transfer fees in connection with securities transactions, taxes and corporate fees. In addition to the Fee, there are charges applied in relation to units in unaffiliated third-party are taken within the fund structure and will be reflected in a net fund price (after charges) in the quarterly valuation report. Some funds may charge a performance fee as part of their charging structure. Relevant details can be made available to the client on request. Entry/exit fees only apply in certain cases when collective investment providers wish to restrict the flow of investment in and out of a fund for liquidity reasons or to retain the integrity of the investment strategy. Neither we nor our Supervised Persons receive any form of compensation as broker or agent for the sale of investments/securities or other investment products by any client account. ITEM 6: Performance-Based Fees and Side-By-Side Management Because we do not charge a performance fee, we do not engage in side-by-side management. ITEM 7: Types of clients We provide investment advisory services to Retail Investors: HNWIs, families and family offices, foundations, trusts, charities, pensions and corporations. We reserve the right to open accounts with high risk or politically exposed persons, subject to enhanced due diligence requirements. We do not have a minimum amount to open an account; the initial size of a portfolio accepted is at our sole discretion. 1 For this level, we charge a minimum investment account charge of US$ 5,000 per annum. 5  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ITEM 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategies and Securities/Investments , units or Each client discretionary investment strategy is set forth in a Mandate. investment objectives and restrictions, a portfolio will feature investments/securities from developed markets including, but not limited to, direct or indirect holdings of US and non-US equities, government securities, bonds or fixed interest securities, ETFs, shares in regulated or unregulated collective investment schemes and other pooled investment vehicles, non-U.S. commodities, real estate funds or other non-U.S. rights or assets and derivatives. Our discretionary management services have liquidity guidelines that should prevent unexpected illiquid assets surfacing. We offer the following investment strategies. Treasury only: The aim is to preserve the value of assets through direct investment in cash and cash- like instruments and avoid exposure to any higher investment risk asset classes such as equities and commodities. Investments in the portfolio will be limited to fixed term cash deposits, fiduciary deposits, foreign currency instruments and high-quality government and corporate bonds with maturities not exceeding one year. Clients opting for this need to accept that after accounting for inflation the value of assets may not grow in real terms. Defensive: The aim is to protect capital by restricting investment risk in equities in the portfolio by holding a high proportion of fixed interest investments and collective investment vehicles as well as cash instruments. The portfolio will also hold a spread of equities of large cap companies including some exposure to equivalent instruments in overseas markets, but equity allocation will be restricted to 30%. The client accepts that the inclusion of equities and equity funds, while improving the prospects of capital growth, increases the possibility that there may be some loss of capital and that fixed interest investments, while less volatile in price terms, also have number of risk factors resulting from inflation, interest rate changes and potential default of the issuer that may lead to capital loss. Balanced: The aim is to seek to preserve the capital of the portfolio in real terms and contain investment volatility by striking a balance between large, medium and some smaller companies for capital growth and fixed interest and cash instruments for income. Various other asset classes with the potential for capital growth, such as commodities funds, may be included with exposure to overseas markets. The client accepts that such a portfolio bears several risks which could result in high levels of volatility and loss of capital in any one year, which in some years could be significant. primary concerns, and the client recognizes the high Growth: The aim is to seek long-term growth and accumulation of capital by holding in portfolio a high proportion of US and overseas equities of large, medium, and small sized companies and funds with high profit potential. Various asset classes with capital growth potential including commodities funds may well be incorporated. Current income is of little concern. High short-term volatility and lack of liquidity are not downside price risk and the possibility of a major capital loss in any one year, which in some years could be significant. Equity only: The aim is to seek long-term capital growth by holding US and developed market equities of large, medium, and small sized companies with the potential to outperform the wider market over time. Various thematic exchange traded funds with global diversification may well be incorporated. Current income is of little concern whilst high short-term volatility and market 6  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 cyclicality are also not the primary concerns. The client recognises that the high downside price risk and the possibility of a major capital loss in any one year, which in some years could be significant. Special Mandates: We develop and agree a bespoke strategy. Occasionally, we use investments that may be perceived as higher risk to reduce overall portfolio risk. The degree of risk acceptable, as evidenced in the Mandate, shall at all times apply in respect of the portfolio as a whole, i.e., the overall risk presented by the portfolio as a whole is considered and not the risk attached to each individual investment. Non-discretionary (advisory) mandates We offer non-discretionary (advisory), non-execution services. For these clients, we offer a family office consultancy service that reviews a family governance charter to frame how decisions are made. We assist in running the Family Investment Board comprised of wealth management professionals including family members. We provide research, advice and recommendations based upon the investment strategy selected by the Family Investment Board. Each client makes their own investment decision and handles transactions. We do not act as a broker-dealer. Method of Discretionary Investment Management Our Investment Committee lays out a strategic asset allocation, and our investment managers interpret this for our clients, working with an approved list of investments for each. ent research and market available We develop our own research and obtain third-party research using our own funds (we do not have any soft dollar arrangements). Our research and investment analysis helps us build a picture of the investee company so that we can make an informed investment decision on behalf of our clients within their investment objectives, requirements and parameters of risk related to the mandate and our corporate governance. We may undertake detailed analysi governance, strategy, performance, attitude towards risk, capital structures and financial statements, as well as analyses of third- information. All investment decisions are undertaken by our investment management team. All investment decisions are made on a case-by-case basis and in compliance with any specific requirements after Mandate, the investment objectives and restrictions and our duties and responsibilities as set out in the Mandate. Any proxy voting decisions taken will be made in the best interests of our investment clients and will be executed by us with their consent. Furthermore, it is our policy to vote on any corporate actions where our clients have a material interest in the outcome of such a resolution and/or action. holdings are material to the outcome of such a resolution and/or action in conjunction with client instructions. We will always vote in a responsible manner and in accordance with our fiduciary duties to our clients. We hold monthly strategy meetings to discuss economic and market conditions and agree asset allocation guidelines. We make changes to our list of securities/investments to buy or sell. We also review and update our risk register relevant to investing (short-, medium- and long-term). Material Risks Related to Investment Strategies Clients must be prepared to lose some or all their assets when investing. The value of investments and income derived from them will fall and rise and you may not get back the original amount 7  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 invested. There can be no assurance that the investment objective will be achieved. Past performance does not necessarily indicate future performance. It can in no way provide a guarantee of returns that you will receive in future. Investments are subject to market fluctuation and other risks inherent in investing in securities, whether equity securities or debt securities, or in derivatives of these securities. There can be no assurance that any increase in value of investments will occur, and the capital value of your original investment is not guaranteed. to increased volatility and can deliver greater returns but also the loss of capital. It takes into consideration investment objectives over both the long and the short term to assess its suitability. This strategy is bespoke and applies to the portfolio as a whole and not the risk attached to each individual investment combining investments in a manner aimed at reducing the overall portfolio risk and volatility. Such investments could include the introduction of foreign shares for diversification of political, economic and currency risk. It could mean buying alternative strategies with the aim of reducing overall portfolio volatility and smoothing returns. Risk may be measured in lifestyle, specific needs and requirements, or personal commitment. There are risks associated with specific types of investments. Equities: Equities are an asset class suitable for clients with a tolerance for fluctuations in the market value of their investments. The market price of equity securities may be affected by international events or market factors such as economic or industry cycles, broad declines in stock market prices or conditions affecting specific issuers, such as changes in earnings forecasts. Multinational companies earn revenues and incur expenses in multiple currencies. Currency fluctuations affect a inancial performance and/or competitive position. Investing in companies with small- and medium-sized market capitalizations involves greater risk than investing in larger companies, and their share prices can fluctuate dramatically in a short period of time. Small and mid- cap companies may be more susceptible to setbacks or downturns than larger companies and may experience higher rates of bankruptcy or other failures. In addition, the shares of a small or mid-cap company may be thinly traded. Non-U.S. securities and foreign currency exposure: Foreign securities, foreign currencies and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. These factors can make foreign investments, especially those in emerging or frontier markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. A substantial portion of securities in client accounts may be denominated in currencies other than the U.S. dollar and as we do not employ hedging techniques, the value of the account can be significantly affected by currency movements. Debt securities: These include investments such as bonds, debentures, government obligations and commercial paper. The value of debt securities will fluctuate based on changes in interest rates and particularly affected by trends in interest rates and inflation. If interest rates go up, the value of capital will change. Inflation will also decrease the real value of capital. The value of a debt security will fall in the event of the default or reduced credit rating of the issuer. Generally, the higher the rate of interest, the higher the perceived credit risk of the issuer. High yield bonds with lower credit 8  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 ratings (also known as sub-investment grade bonds) are more risky (higher credit risk) than investment grade bonds. A default or concerns in the market about an increase in risk of default would result in losses. Shorter term fixed interest securities entail a lesser price risk than longer term fixed interest securities; however, shorter term fixed interest rates typically offer lower returns than longer term fixed interest securities. An investment in debt securities, in particular in bonds, which include a condition to repay the original sum at a specified date in the future and provide a fixed level of income tend to be less volatile than a pure investment in equity securities. The capital value of a bond fund and the level of its income will still fluctuate. If required, we will conduct transactions on your behalf in securities that are denominated in a wide range of currencies, some of which may not be freely convertible. The value of investments will fluctuate in accordance with changes in the foreign exchange rate between your account base currency and the currencies in which the investments made are denominated. You will be exposed to a foreign exchange risk. ITEM 9: Disciplinary Information We have nothing to report. ITEM 10: Other Financial Industry Activities and Affiliations We and our management persons are not registered as a broker-dealer, a municipal securities dealer, or government securities dealer or broker. We and our management persons are not registered as a commodity pool operator or a commodity trading adviser or have an exemption from one of these. EdR Monaco, owned and controlled by EdR (Suisse), has custody of U.S. client assets. Because EdR Monaco have custody of U.S. client assets, we are deemed to have custody under the Advisers Act custody rule. We believe that we are operationally independent of EdR Monaco and have engaged an independent public accountant to prepare an internal control report. EdR (Suisse) owns 89.33% of Hottinger Group Limited. For purposes of the Advisers Act, EdR (Suisse) indirectly controls us, and for purposes of UK regulation it is a controller. EdR (Suisse) provides us with non-investment advisory services for our non-U.S. clients, and custody and banking for our non- U.S. clients. Cynthia Tobiano and Philippe Cieutat of EdR (Suisse) are members of the Board of Directors of Hottinger Group Limited. We have them declare conflicts of interest at Board of Directors meetings and recuse themselves from discussions and voting concerning EdR (Suisse) matters. - length contractual basis, and we have no business dealing with it. Archimedes Private Office (Suisse) Sarl and Hottinger Capital Partners Limited are Related Persons, due to sharing Supervised Persons with them. We do not engage in any business activity with either of them. Certain of our Supervised Persons have outside activities. We record and monitor these, and where we identify a conflict of interest arising out of one of these, we require in addition to disclosure pre- clearance of the activity, quarterly certification of compliance with policies and procedures and other measures, including recusal. Subject to compliance with our Code of Ethics and our Conflicts of 9  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 Interest policy and its procedures, a Supervised Person may, with pre-clearance and subject to conditions, hold a position in a client investee company. As part of our Advisory services, we may support our non-US clients in the selection of other investment advisers, including affiliations, however, we do not receive direct or indirect compensation from those advisers or affiliates, and, therefore, do not believe it creates a conflict of interest. We manage assets for multiple clients at a time and across multiple custodians and jurisdictions. Because clients do not have identical investment objectives, this involves conflicts of interest. We address this risk by managing assets against the investment objectives and restrictions stated in the Mandate and reviewing portfolio activity. To address the unfair allocation of trades between clients, we operate trade allocation policies and procedures and monitor activities through the daily transaction record log. ITEM 11: Code of Ethics, Participation or Interest in client Transactions and Personal Trading As a fiduciary, we owe a duty to our clients to act in their best interests. We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. Interpretation. Our Supervised Persons are Access Persons, must comply with our Code of Ethics, the U.S. federal securities laws and act in accordance with the standards in the Code of Ethics. as defined in our Code of Ethics, this is non- We develop and use Confidential Client Information public information about research, advice and recommendations used for our clients as well as orders being worked and client holdings. To prevent the misuse of this information (frontrunning, trading with clients, trading using this information or tipping), we treat our Supervised Persons (officers, directors, partners, and employees) as Access Persons and require them to comply with our personal account dealing requirements The Edmond de Rothschild Group Directive for Personal Account Dealing provides the minimum requirements for related persons and their connected parties, including but not limited to, restrictions on investments, disclosure of personal interest, and prohibited transactions, that mitigate the conflicts that may arise from personal account dealing in Reportable Securities. Our Code of Ethics contains policies and procedures reasonably designed to address the conflicts of interest associated with the personal trading activities of Access Persons. These include a personal account transaction policy to address the conflicts of interest presented by personal trading. Transactions in certain investments are prohibited, while others require a pre-clearance. Before Access Persons and their Connected Persons propose to invest, they must submit a dealing request to the CCO for approval to ensure that there is no live research, advice, or recommendation, or dealing activity, taking place in the proposed asset and to prevent trading with or front running. Access Persons will be asked to explain the investment thesis and source of research if there are any questions regarding the request. Additional policies and procedures include: the delivery of the Code of Ethics and a written acknowledgment of its receipt (initial and annual); analysis of Code activity; initial, quarterly, and annual reporting requirements; and a requirement to report promptly any suspected violations of our Code of Ethics. Supervised Persons are required to discuss any perceived risks or concerns with the CCO. We review all activities of our Supervised Person and Access Persons to ensure compliance with our Code of Ethics and all other relevant policies and procedures and will act in the event of issues arising. 10  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 A copy of our Code of Ethics is available upon request. ITEM 12: Brokerage Practices Client accounts are treated in a fair and equal manner. We do not engage in client directed brokerage. We do not solicit or take U.S. client orders to buy or sell securities. We do not recommend broker-dealers to US clients We are required to implement an order and best execution policy. As part of these, we must take sufficient steps to obtain the best possible result for our clients when transmitting their orders for execution. Best execution is the process by which one seeks the most favourable cost under the circumstances in each transaction and does not necessarily mean achieving the lowest or highest possible price or transaction cost. This includes factors such as price, costs, speed, likelihood of execution and settlement, size, nature and/or any other consideration relevant to obtain the best result from the execution of orders. This requirement is of a general and overarching nature. We do not select brokers or counterparties to trade. All trades are placed with and executed by the trading desks of custodian banks. (All commissions and transaction rates are agreed between client and the custodian during account opening.) As such, we require that each trading desk gives us best execution and provides us with data to be able to evaluate whether they have satisfied their best execution obligations. We monitor these to ensure that we are satisfied that their execution policies allow them to deliver the best execution result for our clients. When a decision to invest for two or more clients or accounts is made by our Portfolio Manager -trade allocation between clients is recorded. Before an order is transmitted, our PM checks the market with the custodian trading desk. The time the order is placed is recorded and a note is made of the market price taken. We record the time and the price out or electronic communication. When we trade for one client, we send that order to the custodian bank trading desk. When we trade for more than one client, we reserve the right to aggregate orders by custodian trading desk to help achieve equal treatment of clients and efficiency. When doing this, we allocate and record what each client receives to placing the order. In the interests of achieving the best possible result for our clients, we may only aggregate client orders if it is unlikely that the aggregation will be to the disadvantage of any of our clients. In the event of a partial fill, partial executions will be allocated on a fair and equitable basis (generally, on a pro-rata basis). In the event that we purchase securities in number of shares we transmitted for purchase, we will allocate such number of shares purchased in an IPO to client Account in a fair, proportional manner based on the size of the accounts under management and the size of the orders to purchase for such accounts. Post-trade re-allocations are only permitted where an error has occurred in the intended basis of allocation or the actual allocation, or if a partial allocation results in an uneconomic allocation. A record will be made of the reason for the re-allocation which must be completed within one business day of the error being identified and approved by our CCO or Group CEO. We identify and address trade errors as soon as practicable after they are discovered. If a trade error arises, we will ensure that no client suffers a loss. We document trade errors and act, where possible, to prevent such errors in the future. Clients retain gains. We incur losses. If the trading desk of the custodian makes the trade error, it is responsible for making the client whole. 11  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 We effect cross trades between clients from time-to-time (onboarding and offboarding clients). To address this conflict of interest, we confirm client suitability, require two signatures (i.e., the PM and our CEO), client consent and compliance with our best execution policy and procedures. We generate our own research. We purchase third party research with our own funds. We do not s under Section 28(e) of the U.S. Securities Exchange Act of 1934. We do not accept or offer inducements (fees, commissions or monetary and non-monetary benefits) in relation to the provision of services to clients. ITEM 13: Review of Accounts Clients receive a report from the custodian and a quarterly valuation report prepared and independently reconciled within our systems. Quarterly, our Investment Managers and Relationship Managers check to confirm whether portfolio holdings were selected in accordance with the Investment Profile. Quarterly and annually, managers monitor for asset allocation deviations to see whether the asset allocation is within the agreed asset allocation ranges. Furthermore, a change in the clients circumstances would be considered a trigger event requiring the Relationship Manager to carry out a periodic review. ITEM 14: Client Referrals and Other Compensation We do not have a referral/solicitation agreement in place with respect to U.S. prospective clients. EdR (Suisse) and its branches and subsidiaries will, from time, to time, refer U.S. resident prospects to us. ITEM 15: Custody Because EdR Monaco is a Related Person, and has custody of U.S. client assets, we have custody under Advisers Act Rule 206(4)-(2). We comply with the provisions of this rule. When a client receives account statements from their broker-dealer, bank, or qualified custodian, they should carefully review those statements and we urge them to compare those account statements with those received from us. ITEM 16: Investment Discretion For U.S. clients, we provide discretionary investment advisory services by way of a limited, third party power of attorney. Each Mandate sets out the scope of discretion. Unless otherwise instructed or directed, we have the authority to determine the securities/investments to be bought, held, and sold for the Account (subject to restrictions set forth in the Mandate and any written guidelines). We also offer non-discretionary (advisory), non-execution services for U.S. clients. ITEM 17: Voting Client Securities The Firm does not accept authority to vote client securities and therefore does not have proxy voting responsibility for client accounts. Clients retain the responsibility for receiving and voting proxies for all securities held in their accounts. Accordingly, the Firm does not maintain proxy voting policies and procedures and does not provide advice or recommendations to clients regarding proxy voting matters. Because the Firm does not vote proxies or provide proxy voting advice, it has determined that it does not have material conflicts of interest related to proxy voting. To the extent the Firm may have 12  Hottinger & Co Limited Form ADV Part 2A 20 March 2026 business relationships with issuers of securities held in client accounts, or other economic or reputational interests, such relationships could present a conflict of interest if the Firm were to provide proxy voting advice. However, the Firm mitigates this potential conflict by not participating in proxy voting decisions or providing recommendations on such matters. Clients will receive proxy materials directly from the account custodian in the first instance and are responsible for making their own voting decisions. Some custody relationships may send proxy details to us we will endeavour to pass materials directly to the client as part of our fiduciary responsibility to act in the best interests of the clients but incur no liability for any failure to do so. Clients may contact the Firm with questions about a particular proxy matter; however, the Firm will not provide recommendations or take action with respect to voting such proxies. ITEM 18: Financial Information We have nothing to report. 13