KRISTAL.AI

Item 1 – Cover Page Kristal Advisors (SG) Pte. Ltd. Form ADV Part 2A (“Brochure”) 16 Raffles Quay, #09-01 Hong Leong Building Singapore 048581 www.kristal.ai April 12, 2026 This Brochure provides information about the qualifications and business practices of Kristal Advisors (SG) Pte. Ltd. (“KASG”). If you have any questions about the contents of this Brochure, please contact us at +65-83030874 or shruthi@kristal.ai. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Kristal Advisors (SG) Pte. Ltd. is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #341175 Please note that the term "registered investment adviser" and the description of KASG’s firm and its associates as "registered" do not imply a certain level of skill or training. i  Item 2 - Material Changes Kristal Advisors (SG) Pte. Ltd. (“KASG”) acknowledges that this Brochure is its first official document outlining its services, products, and other relevant information. From time to time, KASG may amend this Brochure to reflect changes in business practices, regulatory developments, or routine annual updates as required by the securities regulators. This complete Brochure or summary of material changes shall be provided annually if a material change occurs in KASG's business practices. ii  Item 3 – Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 - Material Changes ............................................................................................................................. ii Item 3 – Table of Contents ............................................................................................................................ 1 Item 4 – Advisory Business ........................................................................................................................... 2 Item 5 – Fees and Compensation ................................................................................................................. 4 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 7 Item 7 – Types of Clients ............................................................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9 Item 9 – Disciplinary Information ............................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 14 Item 12 – Brokerage Practices .................................................................................................................... 15 Item 13 – Review of Accounts..................................................................................................................... 18 Item 14 – Client Referrals and Other Compensation .................................................................................. 20 Item 15 – Custody ....................................................................................................................................... 21 Item 16 – Investment Discretion ................................................................................................................ 22 Item 17 – Voting Client Securities ............................................................................................................... 23 Item 18 – Financial Information .................................................................................................................. 24 1  Item 4 – Advisory Business Kristal Advisors (SG) Pte. Ltd. (“KASG”) is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940 (“Advisers Act”). KASG is a private company limited by shares incorporated in Singapore. KASG currently has clients located in India, Hong Kong, Singapore, United Arab Emirates, and United Kingdom. KASG is regulated by the Monetary Authority of Singapore holding a Capital Market Service License (License No. CMS1000614) to conduct fund management, dealing in capital market products and financial adviser activities since April 24, 2017. KASG’s principal shareholders. (i.e., those individuals and entities controlling 25% or more of KASG) are: Kristal.AI Holdings PTE. LTD – 100% Overview of Advisory Services KASG provides Artificial Intelligence (AI) driven financial planning and portfolio management services on a discretionary and non-discretionary basis to accredited investors, qualified purchasers, family offices, and Variable Capital Companies (“VCCs”) in Singapore (each a “Fund”, collectively, the “Funds”). KASG does hold itself out as specializing in any particular type of advisory service or investment. KASG’s advice is based on a broad range of securities and investment strategies in order to meet each client’s objectives, risk tolerance, and liquidity needs, and investment mandate of each Fund. These may include constructing globally diversified portfolios using a curated universe of listed securities and funds, including ETFs, listed equities, bonds, and mutual funds, accessed through KASG’s digital platform. KASG also provides access, for eligible clients, including Funds, to structured products, selected alternative funds, and private market opportunities (such as hedge funds, private equity/venture capital funds, and pre-IPO deals). In all cases, KASG combines product-level education with ongoing portfolio monitoring and rebalancing, supported by its proprietary algorithms and investment committee. KASG tailors its AI driven advisory services to each client’s individual circumstances, objectives, and risk tolerance. At onboarding, clients complete an interactive risk-profiling questionnaire (Investor Profile) that gathers information on their financial situation (number of dependents, borrowing history, expected income changes, liquid net worth, and recent losses), investment knowledge and experience (education or profession, prior use of products such as stocks/ETFs, bonds, derivatives, alternatives), investment horizon, and preferred risk/return profile. Clients’ responses are translated into a numerical risk score and mapped to a risk category (e.g., Cautious, Balanced, Opportunistic, Aggressive, Sophisticated). Using the Investor Profile, KASG constructs and manages portfolios that align with the client’s time horizon, liquidity needs, and overall financial goals, and will periodically reassess the profile if the client’s circumstances change or if they retake the assessment. Clients may impose reasonable restrictions on investing in specific securities, industries, asset classes, or strategies (for example, bans on leverage or derivatives, or avoidance of particular sectors); such restrictions are recorded as part of the onboarding process and incorporated into portfolio construction and ongoing monitoring. Where a requested restriction would materially conflict with the agreed investment objectives and risk profile, KASG discusses the implications with the client and may decline or adjust the mandate if it cannot be managed appropriately. Additionally, based on these factors and client input, KASG also advises clients on their existing portfolios and provides recommendations for proposed portfolio adjustments. 2  Client Assets Under Management: As of February 28, 2026, KASG managed the following client assets: Non-Discretionary Client Assets: Discretionary Client Assets: Total Assets under Management: $0 $1,269,350,088 $1,269,350,088 3  Item 5 – Fees and Compensation Advisory Fee KASG charges clients an annual asset-based advisory fee calculated as a percentage of assets under management (“AUM”). The standard advisory fee is typically 0.50% (50 bps) per year. KASG’s standard advisory fee schedule is summarized below and applies uniformly across asset types unless otherwise agreed with the client: Asset Type Fees 0.50% 0.50% 0.50% 0.50% 0.50% 0.00% Exchange-Traded Equity Securities Non-Exchange-Traded Securities U.S. Government/Agency Bonds Mutual Funds Securities Issued by Pooled Investment Vehicles (i.e. Hedge Funds, Venture Capital Funds, and Private Equity Funds) Cash and Cash equivalents (including Money Market Funds) Advisory fees are negotiable and may vary among clients. As a result, similarly situated clients may pay different fees depending on factors such as the size of the overall client relationship, the complexity of the services provided, the type of investment strategy, anticipated trading activity, and other relevant considerations. Accordingly, certain clients may pay fees that are higher or lower than those paid by other clients for similar services. Advisory fees are calculated daily based on the value of assets in the client’s account and are billed monthly in arrears. For each billing period, KASG calculates the advisory fees using the daily asset values in the account during the period. Fees are pro-rated for accounts opened or closed during a billing period. KASG will issue an invoice for advisory fees. Pursuant to the client’s written authorization in the investment management agreement, advisory fees are deducted directly from available cash balance in the client’s account approximately two business days after the invoice date. If sufficient cash is not available in the account, KASG will liquidate securities in the account, as authorized under the investment management agreement, to satisfy the fee. Because KASG has the authority to deduct fees directly from client accounts, KASG is deemed to have limited custody of client assets. Clients should review the account statements they receive from their custodian to verify deduction of advisory fees. Other Fees and Expenses The advisory fees described above do not include brokerage commissions, transaction fees, custody fees, or other charges imposed by the executing broker or custodian. Clients are responsible for these additional fees and expenses. 4  Client accounts are maintained with independent custodians such as Pershing LLC or Interactive Brokers LLC. These firms may charge brokerage commissions, transaction charges, custody fees, or other account- related expenses. Such charges are separate from and in addition to KASG’s advisory fee. In addition, clients who invest in mutual funds, collective investment schemes, hedge funds, structured products or other pooled investment vehicles will bear their proportionate share of the fees and expenses charged by those investment products. These expenses are disclosed in the relevant offering documents and are separate from KASG’s advisory fee. Additional information regarding KASG’s brokerage practices, including factors considered when recommending or selecting brokers and custodians, is provided in Item 12 (Brokerage Practices) of this Brochure. Third-Party Compensation and Conflicts of Interest KASG may receive rebates, commissions, or other forms of compensation from fund managers, product issuers, distributors, or other third parties in connection with client investments in mutual funds, collective investment schemes, hedge funds, structured products, or similar investment products recommended or selected for client accounts. These payments may include upfront commissions, ongoing trailer or servicing fees, and other revenue- sharing or marketing-support payments that are based on the amount of client assets invested in those products. In certain cases, such payments may be as high as 2.5% per year of the assets invested in the applicable product. Because KASG may receive such compensation, KASG has financial incentive to recommend or allocate client assets to those products, or to maintain investments in those products, rather than recommending other investments that do not provide such payments or that provide lower levels of compensation. This creates a conflict of interest. KASG seeks to address these conflicts through policies, procedures, and oversight designed to ensure that investment recommendations remain consistent with its fiduciary duty to clients. These measures include:  Policy and algorithmic separation: KASG’s internal policies and product recommendation tools are designed so that retrocessions and other compensation arrangements do not influence investment recommendations. Product selection is based on investment merit, client objectives, and risk tolerance.  Product Approval Committee oversight: KASG maintains a Product Approval Committee that evaluates investment products for inclusion in KASG’s investment universe based on investment characteristics and client suitability rather than the compensation received by KASG.  Disclosure: KASG discloses to clients, in client agreements and other disclosures, whether certain products may pay KASG retrocessions or other compensation.  Supervisory review: KASG supervises and reviews investment recommendations to ensure they remain consistent with its fiduciary duty and client objectives.  Periodic review: KASG periodically reviews its compensation arrangements and product selection practices to identify and address potential conflicts of interest. 5  Clients may request additional information at any time regarding the compensation KASG receives from third parties and KASG’s practices for managing related conflicts of interest. Compensation KASG’s financial professionals receive a combination of fixed and performance-based compensation. KASG pays the fixed portion as a salary, and awards performance-based compensation in the form of an employee stock ownership plan (ESOP). The performance-based compensation creates a potential conflict of interest, because it provides an incentive for KASG’s financial professionals to take actions that may increase the overall profitability or valuation of KASG. This could, in certain circumstances, influence recommendations regarding investment strategies. KASG addresses this potential conflict of interest through its policies and procedures, which it has designed to ensure that financial professionals act in the best interest of clients and adhere to KASG’s fiduciary duties. 6  Item 6 – Performance-Based Fees and Side-By-Side Management KASG manages client accounts that pay asset-based fees as well as Funds for which KASG and their affiliates receive performance-based compensation. In addition, as described in Item 5, certain investment professionals receive compensation that is tied, directly or indirectly, to the performance of accounts that pay performance-based compensation. This includes ESOPs linked to the revenues or profitability of KASG and its affiliates, including revenues derived from performance-based fees. The management of accounts with different fee structures, combined with employee compensation tied to performance-based compensation, creates conflicts of interest. KASG and its personnel have an incentive to favor accounts that pay performance-based compensation over those that pay only asset- based fees. KASG seeks to mitigate these conflicts through the implementation of written policies and procedures designed to ensure that all client accounts receive fair and equitable treatment. These policies include trade allocation procedures that require fair and equitable allocation of investment opportunities among similarly situated client accounts. KASG also conducts pre-trade and post-trade reviews by its trading and compliance personnel, periodic testing of account performance and trade allocations, and supervisory reviews designed to monitor whether any accounts, including those that pay performance-based fees, receive preferential treatment over other client accounts. 7  Item 7 – Types of Clients KASG clients include private funds (including VCCs), high-net-worth individuals, family offices, and institutional investors. U.S. investors in the Funds are typically “accredited investors” and, where applicable, “qualified purchasers.” KASG offers interests in the Funds in the United States in reliance on exemptions from registration under the Securities Act of 1933 and the Investment Company Act of 1940. The Funds are not registered U.S. investment companies. The Funds are organized as VCCs under Singapore law and supervised by the Monetary Authority of Singapore. Legal, regulatory and investor protections regimes in Singapore differ from those in the United States. Account Minimums KASG generally requires a minimum account size; however, the minimum may vary depending on the executing broker or custodian and the services provided. For example, the minimum account size for an account cleared through Pershing LLC is $100,000. This minimum is influenced in part by the fee schedules and operational requirements of executing brokers and custodian and may change from time to time. KASG may, at its discretion, accept accounts with smaller asset levels, aggregate related household accounts to meet minimum requirements, or establish higher minimums where required by a particular investment strategy, broker, or platform. Each Fund’s Private Placement Memorandum describes the minimum account requirements for the Fund. 8  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss KASG provides goals-based, risk-aware investment advice using a structured client-discovery process, a quantitative risk-profiling framework, model-driven and AI-enabled portfolio construction, and ongoing monitoring with human oversight. Investing in securities involves risk of loss that clients should be prepared to bear, and no strategy, model or algorithm can guarantee that any target return or objective will be achieved. Principal methods of analysis and investment strategies KASG begins with detailed client discovery to understand each client’s financial situation, investment experience, risk tolerance, time horizon, liquidity needs and life goals (such as retirement or education funding). KASG will then administer a Risk Profile and Investment Criteria questionnaire in which each response is assigned points and converted into a Sophistication Level (SL) score from 1 to 10; this SL score maps to risk profiles such as Cautious, Balanced, Opportunistic, Aggressive and Sophisticated and determines the level of risk and product complexity. Lower scores reflect cautious investors, and higher scores reflect sophisticated investors. Using this information, KASG establishes a risk-optimized target return for the client, focusing on the lowest level of risk likely to achieve their goals rather than simply maximizing return. KASG maintains a suite of long-term strategic model portfolios, each calibrated to a specific risk/return and SL profile, diversified across major asset classes (such as equities, fixed income, cash and, where appropriate, alternatives) and geographies. implied-volatility information to introduce a forward-looking element KASG creates strategic model portfolios by using a systematic optimization process that combines human views with quantitative methods. KASG starts by using a set of reference indices representing the asset classes and regions KASG invests in, calculates historical returns, volatility and correlations, and then adjusts the expected returns using forward-looking views provided by KASG’s Investment Committee (IC) on a defined rating scale. KASG also builds a covariance matrix from historical data and refine the risk into the estimates with optimization. KASG employs advanced optimization techniques, including Bayesian optimization and KASG’s proprietary Iterative Optimizer, to search across target volatility ranges and identify portfolios that offer attractive trade-offs between expected return and risk for different risk levels. The resulting asset-class allocations form the strategic “core” portfolios, which are then used as templates for client portfolios according to each client’s SL profile and objectives. On top of the strategic core, KASG may make tactical asset-allocation adjustments and security-selection decisions within predefined bands. The Iterative Optimizer evaluates a broad universe of eligible investments using multiple metrics (such as return, volatility, drawdown, risk-adjusted performance and diversification characteristics), ranks assets, identifies potential candidates to reduce or sell, and suggests replacements or additions that are expected to improve the portfolio’s risk-adjusted returns and diversification. All recommendations are subject to strict constraints on position size, sector and geographic concentration, correlation, maximum drawdown, liquidity, and product-specific exposure (for example, caps on higher-risk asset classes). 9  The SL-based Investment Criteria matrix further constrains which product categories may be used for each client. For clients with lower SL scores, KASG generally will restrict portfolios to simpler instruments such as diversified funds, ETFs and high-quality bonds. For clients with higher SL scores, KASG may, where suitable, include more complex instruments such as derivatives, structured notes, hedge-fund strategies or crypto-related exposures, and in some cases, KASG require explicit client consent before using certain products. The portfolios are monitored on an ongoing basis. KASG’s systems continuously track performance, risk and diversification metrics for each model and client portfolio, and flag material deviations from target allocations or risk parameters. KASG uses threshold-based rebalancing, rather than purely calendar-based rebalancing, to bring portfolios back toward their strategic targets and to implement tactical changes where appropriate, considering transaction costs, liquidity and, where relevant, tax considerations. KASG also conducts regular review meetings with clients to ensure that portfolios remain aligned with their evolving circumstances, objectives and constraints, and update risk profiles and SL scores as needed. Throughout the process, AI and quantitative tools play a critical but bounded role. These tools will analyze data, rank assets, generate portfolio and rebalancing suggestions, and test the impact of potential changes. They operate within strict parameters and constraints established by KASG’s Investment Committee and risk framework and do not execute trades or make final investment decisions autonomously. Experienced portfolio managers review all recommendations generated by these tools and must approve them internally before implementation. Material risks of KASG’s methods and strategies All investment strategies involve risk of loss, and clients may lose money. Market, interest-rate, credit, inflation, currency and liquidity risks can affect portfolio values, and adverse market conditions can lead to significant volatility and drawdowns, including losses exceeding recent historical experience. Diversification and asset allocation may reduce risk but do not guarantee profits or prevent losses, and in periods of market stress different asset classes may become more correlated, reducing diversification benefits. KASG’s use of models, optimization techniques and AI tools introduces additional risks. These systems rely on historical data, statistical assumptions and forward-looking views that may prove inaccurate or incomplete, and relationships observed in the past may not persist in the future. Model errors, data errors or inappropriate assumptions may lead to sub-optimal portfolios or unexpected losses. KASG seeks to mitigate these risks by validating models, using conservative constraints, subjecting outputs to human review, and adjusting models and parameters. There is also a risk that a client’s goals, financial circumstances or risk tolerance may be misstated, misunderstood or may change over time, which could make a previously suitable strategy inappropriate. KASG addresses this by using structured questionnaires, documenting key assumptions, mapping clients to SL-based profiles, applying product-eligibility rules, and conducting periodic reviews. Implementation and operational risks include transaction costs, bid-ask spreads, market impact, delays in execution, errors in trading or settlement, and, where applicable, tax consequences of transactions. KASG applies internal controls, monitoring, and supervision, and aims to rebalance using threshold-based triggers to limit unnecessary trading. 10  Finally, the use of more complex products (such as derivatives, structured notes, hedge-fund strategies or crypto-related instruments) may involve additional risks, including leverage, counterparty risk, liquidity constraints, valuation uncertainty and higher volatility. KASG attempts to manage these risks by limiting such products to clients whose SL profiles and objectives justify their use, imposing exposure limits and consent requirements, and subjecting all such positions to enhanced monitoring. KASG services rely heavily on digital systems, cloud infrastructure, third-party service providers and online channels, which expose clients to operational and cybersecurity risks. These risks include unauthorized access to systems or data, phishing or malware attacks, denial-of-service incidents, system outages, data corruption or loss, and delays in trading or reporting. KASG seeks to manage these risks through a documented information-security framework that includes network and endpoint protection, strong access controls, multi-factor authentication for critical systems, encryption of data at rest and in transit, regular security patching, cyber-hygiene standards for employees, monitoring and logging of critical systems, and annual penetration testing and disaster-recovery exercises. KASG also maintains an incident- management process with frequent monitoring of production systems, predefined thresholds for alerts, and procedures for incident response, root-cause analysis and escalation, including use of backup and disaster-recovery environments where necessary. Despite these measures, no cybersecurity or technology system is completely secure. Clients should consider these technological and cybersecurity risks, in addition to market and investment risks, when evaluating KASG’s services. Tax Considerations U.S. law may treat a Fund organized as a non-U.S. corporation as a Passive Foreign Investment Company (“PFIC”) for U.S. federal income tax purposes. PFIC status can result in adverse tax consequences and additional reporting obligations. Prospective investors should consult their tax advisers. 11  Item 9 – Disciplinary Information KASG must disclose any legal or disciplinary event that could significantly impact clients' assessment of KASG or the trustworthiness of its management. KASG affirms that there are no legal or disciplinary events to report. 12  Item 10 – Other Financial Industry Activities and Affiliations KASG is affiliated with certain entities that are registered with foreign financial regulatory authorities to provide investment advisory services in their respective jurisdictions.  Kristal Advisors Pvt. Ltd is a registered investment adviser with the Securities and Exchange Board of India.  Kristal Advisors (HK) Ltd holds Type 4 (advising on securities) and Type 9 (asset management) licenses from the Securities and Futures Commission in Hong Kong.  Kristal.AI Middle East Limited holds a Category 3A license from the Financial Services Regulatory Authority of Abu Dhabi Global Market that permits it to act as a matched-principal dealer in investments, deal in investments as agent, provide and arrange custody, manage assets, arrange deals in investments, advise on investments or credit, and arrange credit. These relationships may give rise to potential conflicts of interest. However, each affiliate provides investment advisory services solely to individuals located in its jurisdiction and does not provide advisory services to U.S. clients. As a result, KASG believes the potential for conflicts arising from these relationships is limited. 13  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading KASG has adopted a written Code of Ethics/Conduct (the “Code”) in accordance with the SEC Rule 204A- 1 under the Advisers Act. The Code sets forth the standard of business conduct that KASG expects all team members to follow, ensuring that they act with due skills, care, and diligence in a client’s best interest. The Code also restricts trading in any security about which KASG may be privy to material non-public information. It restricts personal trading activities to prevent any conflict of interest between personal and client interests. KASG tries to avoid conflicts of interest as much as possible. In unavoidable cases, it ensures appropriate disclosures to the client. The Code also restricts the exchange of gifts and extends entertainment activities to avoid conflicts of interest. Adherence to the Code maintains the confidentiality of client information and provides adequate information to clients when required. Employees must disclose any information necessary that may create a potential conflict of interest. Employees must also maintain an arms-length relationship between professional and personal activities. The Code also limits the political contributions of KASG’s managers and employees to prevent any potential conflicts in that area. When joining KASG, an employee must disclose any relevant information, accept the Code in writing, and certify adherence to the Code. Clients or prospective clients can request a copy of the Code by contacting the Chief Compliance Officer at the telephone number or via email specified on the cover page of the Brochure. 14  Item 12 – Brokerage Practices KASG follows a formal Vendor Onboarding Framework for all financial counterparties, including brokers and bond dealers, with additional broker-specific due diligence. When selecting brokers, KASG applies the following criteria: ● Regulatory status and licensing in the relevant markets, including review of licenses, regulatory authority, and any penalties, fines or restrictions over the last 7 years. ● Financial strength and stability, assessed via market capitalization, assets under management, audited financial statements, and external credit ratings where available. ● Organizational quality and governance, including ownership and organization charts, senior management profiles, auditors, and legal counsel. ● Range and quality of services and products: markets covered, instruments offered, execution facilities, and best-execution capabilities, strategies supported, custody and margin arrangements. ● Operational resilience and controls: internal control environment, AML/CFT policies and Wolfsberg questionnaire, data-security policies, asset segregation arrangements, and business- continuity/contingency policies. ● Quality of client service: responsiveness of key contacts, customer-support arrangements, and incident-handling processes. ● Pricing and commercial terms: fee schedules and other commercial conditions, compared across at least three vendors for critical relationships, unless an exception is approved by senior management. ● Overall risk assessment and criticality: classification as strategic/critical vs incidental based on impact on operations, access to confidential data, and potential strategic, operational or regulatory risk. New brokers are only onboarded after completion of the due diligence questionnaire, collection and review of supporting documents (e.g., incorporation documents, licenses, policies, financials), preparation of a business case, risk will conduct a suitability assessment, management approval, and legal review and execution of written contracts. Additionally, KASG selects and periodically reviews (on an annual basis) brokers under its formal vendor and counterparty suitability-assessment framework, which includes initial financial, regulatory and operational due diligence and ongoing monitoring. Number of brokers Equity transactions: KASG expects to maintain relationships with approximately 4-5 equity brokers globally, to ensure sufficient market access, competitive pricing and contingency options while allowing effective ongoing monitoring under its Vendor Onboarding Framework. 15  Fixed-income transactions: KASG expects to maintain relationships with approximately 4-5 fixed-income brokers/dealers, focusing on those with strong balance sheets, robust execution capabilities and proven expertise. KASG does not have any soft dollar arrangements. KASG does not typically aggregate client orders except where aggregation is required to execute the trades or is otherwise necessary to achieve a better result for clients. For example, without aggregation it would not be possible to execute certain trades in Alternative Funds or Private Assets, where transactions are typically placed as a single bulk order with the underlying provider or counterparty. In any circumstance where orders are aggregated, all affected clients are allocated the securities on the same economic terms, with no distinction in cost or execution terms between them. KASG is committed to treating all client accounts fairly and equitably in the allocation of investment opportunities, and to complying with the Monetary Authority of Singapore’s requirements on best execution and fair dealing in the handling of customers’ orders. KASG maintains and follows written trade allocation procedures designed to promote the fair and equitable allocation of investment opportunities so that no client or group of clients is systematically advantaged over time. Trade allocation policies KASG is committed to treating all client accounts fairly and equitably in the allocation of investment opportunities, supported by written allocation procedures that apply consistently across all strategies and client types. These procedures govern how KASG determines which accounts participate in a trade, how orders are sized, how executions are allocated, and how KASG handles exceptions, with ongoing oversight from the ops team. Pre-trade procedures Before executing any order involving multiple client accounts, KASG determines and documents the intended allocation methodology in advance of trade execution. The allocation basis is established using factors such as each account’s investment objectives, available cash, existing holdings and target portfolio weights, as well as any mandate or regulatory constraints. For aggregated orders, KASG maintains records of the intended allocation, the list of participating accounts and the investment rationale before the order is placed. Allocation methodology When orders are aggregated across multiple accounts, executed shares are generally allocated on a pro-rata basis according to each account’s proportionate share of the total order. All participating accounts in an aggregated order receive the same average execution price, and transaction costs (such as commissions and fees) are allocated proportionally so that no account bears a disproportionate share of costs. No account – including any account of employees, affiliates or related persons – receives preferential treatment in the allocation process, and all accounts are treated equally under the policy. Handling partially filled and multi-tranche trades When an aggregated order is only partially filled, filled shares are allocated pro-rata based on each participating account’s original intended order size. Where a strict pro-rata allocation would result in fractional shares or odd-lot positions, allocations are rounded to the nearest whole share in a manner that does not systematically favor any account over time, for example by rotating which accounts receive rounded-up shares. If a partial fill is so small that pro-rata allocation would create de minimis or 16  operationally inefficient positions, KASG may allocate the entire fill to a subset of accounts on a rotating basis, with the rationale and rotation documented. When an order is executed in multiple tranches over time, each tranche is allocated pro-rata, and all participating accounts ultimately receive the same average price for the aggregated order. Exceptions, deviations, and keeping Any deviation from the predetermined allocation methodology is permitted only where it does not disadvantage any client, the reasons for the deviation are clearly documented, and the revised allocation is reviewed and approved by Compliance. KASG maintains comprehensive records of pre-trade allocation determinations, executed allocations and any deviations together with their justifications, to facilitate ongoing monitoring and regulatory review. Trade-by-trade execution and aggregation criteria For highly liquid securities such as listed equities and ETFs traded through our automated systems, client orders are typically executed on an individual, trade-by-trade basis rather than aggregated. In these cases, orders are processed sequentially based on time of receipt, and each account receives its own execution and associated price. KASG aggregates orders only where aggregation is necessary for execution (for example, alternative funds or private assets with minimum subscription sizes) or where it is expected to benefit all participating clients, such as to achieve better pricing or market access on bond or fund platforms, so that all clients in the aggregated order receive identical terms and average pricing. 17  Item 13 – Review of Accounts KASG reviews client accounts through a structured, technology-enabled process that combines continuous system monitoring with periodic human oversight (at least on a quarterly basis) and approval. Review process and frequency Client portfolios are monitored on an ongoing basis by KASG’s proprietary Iterative Optimizer (IO), which tracks more than 50 performance, risk, risk-adjusted return, and diversification indicators in real time to flag any material deviation from expected behavior. In addition to this continuous monitoring, formal reviews (during monthly Investment Committee meeting or following significant market movements) are conducted on a regular basis aligned to each model portfolio’s risk profile, and whenever significant market events or changes in a client’s circumstances occur (for example, major drawdowns or changes in objectives or risk tolerance). These formal reviews assess performance over different periods, risk and drawdown behavior, and diversification versus benchmarks, and result in documented recommendations where action is required. Persons responsible for reviews ● Strategic portfolio reviews, approval of model portfolios, and any material rebalancing actions are carried out and signed off by the Investment Committee, comprising senior investment professionals (e.g. Chief Investment Officer, senior advisors). Human oversight is the final step before any recommendations are implemented in client accounts. ● Day-to-day implementation and recording of approved changes in client accounts are handled by the Advisory Team, under the supervision of the Chief Investment Officer and in accordance with internal policies and regulatory requirements. All reports are provided in written form through our secure online client portal. Reports are system- generated (computerized), may be viewed online or downloaded, and do not require signatures. ● On a monthly basis, (1) clients receive a consolidated written account report showing portfolio value at period start and end, cash balance, net cash and asset transfers, earnings, and returns for the period, year-to-date and lifetime, together with detailed sections for holdings, transactions, cash transfers (including inter-account transfers), dividends and coupons, fees and rebates (such as investment advisory fees), and definitions of key terms; (2) They also receive a monthly portfolio snapshot that summarizes current value, asset allocation and detailed asset statements, including invested amount, current value and unrealized returns for each holding. ● In addition, for advisory clients KASG provides written monthly portfolio review reports that summarize investment objectives and risk profile, current and recommended asset allocation, performance (including returns month-to-date, year-to-date and since inception), key holdings and contributors/detractors, and recommended trades or allocation changes. ● Further, advisory clients can generate a detailed written cash ledger showing all cash transactions in their accounts, including deposits, withdrawals, security purchases and sales, dividends and other income, interest and margin charges, taxes, FX trade fees and other charges, together with running cash balances in each currency. 18  ● Clients can also generate a holdings report providing an as-of-date view of each position (quantity, trade price, invested amount, current value, valuation date and unrealized returns) and a user- metrics report that summarizes portfolio performance and cash flows month-to-date, year-to- date and since inception (including XIRR, earnings and net cash transferred). ● Fee-related items (including investment advisory fees and other charges) are itemized within these written reports and are available for clients to download at any time through the client portal. 19  Item 14 – Client Referrals and Other Compensation KASG does not utilize solicitors to promote its investment advisory services. Compensation that KASG receive is based on a percentage of asset under management as described in Item 5 (Fees and Expenses). KASG does not receive any economic benefit, including sales awards and other prizes, from non-clients for providing investment advice or other advisory services to its advisory clients. 20  Item 15 – Custody KASG does not maintain physical custody of client funds or securities. Client assets are held with independent qualified custodians. KASG generally recommends that clients maintain custody of their assets with Pershing LLC or Interactive Brokers LLC. These firms act as qualified custodians and hold client funds and securities in accounts established in the client’s name. Although KASG does not take physical custody of client assets, KASG is deemed to have custody because it has the authority to deduct advisory fees directly from client accounts. KASG also has limited authority to place trades in client accounts pursuant to the client’s investment management agreement. KASG’s authority is limited to trading and fee deduction and does not permit KASG to withdraw client funds or securities for any other purpose. The qualified custodian maintains custody of client assets and sends account statements directly to clients, typically on a monthly or quarterly basis. These statements reflect all transactions in the account, including the deduction of advisory fees. KASG has custody of client assets held in the Funds because it serves as the general manager of each Fund. Financial institutions outside the United States hold each Fund’s assets and typically provide custodial services in the relevant jurisdictions. Although these institutions may not meet the definition of a “qualified custodian” under Rule 206(4)-2 of the Investment Advisers Act of 1940 in every case, KASG believes they provide substantially similar custodial protections. Clients should carefully review the account statements they receive from the custodian and compare them with any reports or statements they receive from KASG. Any discrepancies should be reported promptly to KASG or the custodian. 21  Item 16 – Investment Discretion KASG has discretionary authority to manage client assets, but always within pre-agreed parameters that reflect each client’s documented risk profile, sophistication level, and investment objectives. Discretion is exercised primarily through the construction and ongoing management of model portfolios and bespoke portfolios, where allocations and rebalancing are implemented without seeking trade-by-trade consent, provided they remain within those agreed limits. Typical limits and conditions clients place on this discretionary authority include: ● Risk and return bounds: portfolios are managed to a target return range and corresponding downside/volatility tolerance, consistent with the client’s risk rating (1–10) and profile (e.g., Cautious, Balanced, Opportunistic, Aggressive, Sophisticated). Higher-risk clients (e.g., Sophisticated / High Risk, 10–12% return targets) permit broader use of higher-volatility and alternative strategies, while lower-risk clients permit only more conservative exposures. ● Product and asset-class restrictions: use of certain complex, illiquid or higher-risk instruments (e.g., hedge funds, structured products, high-volatility alternatives, cryptocurrencies, privates) is allowed only where it is compatible with the client’s risk profile and, in some cases, only with explicit consent or within pre-set percentage caps. ● Diversification and concentration limits: hard-coded rules and internal policies limit concentration by single issuer, geography, or sub-category, and may cap exposures to specific themes or strategies so that no individual asset or narrow segment dominates portfolio risk. ● Risk-control constraints: the optimization engine and portfolio review process operate under constraints such as maximum drawdown thresholds, correlation limits, and minimum diversification requirements, so discretionary changes cannot breach these risk-management parameters. Within these client-specific and policy-driven limits, AI-enabled tools are used to generate data-driven allocation and rebalancing proposals, but they do not execute trades autonomously. All discretionary actions are ultimately reviewed and approved by human portfolio managers/advisors and the Investment Committee, who ensure that each portfolio remains aligned with the client’s mandate and any stated restrictions before implementation. 22  Item 17 – Voting Client Securities KASG generally does not accept proxy voting authority on behalf of clients. However, KASG may accept such authority on a limited basis upon a client’s specific request. When a client delegates proxy voting authority to KASG in writing (for example, through the client agreement or other written instruction), KASG votes proxies in accordance with its written policies and procedures and in a manner that KASG believes is in the best interests of the client. Clients that do not delegate proxy voting authority to KASG retain responsibility for receiving and voting proxies for securities in held in their accounts. Client may obtain a copy of KASG’s proxy voting policies and procedures upon request. Clients may also request information about how KASG voted proxies on their behalf for securities held in their accounts. 23  Item 18 – Financial Information KASG has no financial condition that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 24