PALLAS CAPITAL ADVISORS, LLC

Pallas Capital Advisors LLC Form ADV Part 2A – Disclosure Brochure Effective: September 8, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Pallas Capital Advisors LLC (“Pallas” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (781) 971-5052. Pallas is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Pallas to assist you in determining whether to retain the Advisor. information about Pallas and its Advisory Persons is available on the SEC’s website at Additional www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310327. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 | https://pallascapitaladvisors.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Pallas. Pallas believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Pallas encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on March 5th, 2025: • Effective May 30, 2025, Gaurav Mallik is no longer the Advisor’s Chief Investment Officer. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310327. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (781) 971-5052. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 7 D. Wrap Fee Programs ........................................................................................................................................................ 7 E. Assets Under Management ............................................................................................................................................. 8 Item 5 – Fees and Compensation ......................................................................................................................... 8 B. Fee Billing ....................................................................................................................................................................... 9 C. Other Fees and Expenses .............................................................................................................................................. 9 D. Advance Payment of Fees and Termination ................................................................................................................. 10 E. Compensation for Sales of Securities ........................................................................................................................... 11 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 11 Item 7 – Types of Clients ..................................................................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 11 A. Methods of Analysis ...................................................................................................................................................... 11 B. Risk of Loss ................................................................................................................................................................... 12 Item 9 – Disciplinary Information ....................................................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 14 A. Code of Ethics ............................................................................................................................................................... 14 B. Personal Trading with Material Interest ......................................................................................................................... 14 C. Personal Trading in Same Securities as Clients ........................................................................................................... 14 D. Personal Trading at Same Time as Client .................................................................................................................... 15 Item 12 – Brokerage Practices ............................................................................................................................ 15 A. Recommendation of Custodian[s] ................................................................................................................................. 15 B. Aggregating and Allocating Trades ............................................................................................................................... 16 Item 13 – Review of Accounts ............................................................................................................................ 16 A. Frequency of Reviews ................................................................................................................................................... 16 B. Causes for Reviews ...................................................................................................................................................... 16 C. Review Reports ............................................................................................................................................................. 16 Item 14 – Client Referrals and Other Compensation ........................................................................................ 17 A. Compensation Received by Pallas ............................................................................................................................... 17 B. Client Referrals from Solicitors ...................................................................................................................................... 18 Item 15 – Custody ................................................................................................................................................ 18 Item 16 – Investment Discretion ......................................................................................................................... 18 Item 17 – Voting Client Securities ...................................................................................................................... 18 Item 18 – Financial Information .......................................................................................................................... 18 Form ADV Part 2A – Appendix 1 ........................................................................................................................ 19 Privacy Policy ....................................................................................................................................................... 28 Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 3  Item 4 – Advisory Services A. Firm Information Pallas Capital Advisors LLC (“Pallas” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the Delaware in March 2019 and became a registered investment advisor in November 2020. Pallas is a wholly-owned subsidiary of MBE, LLC. In 2021, the owners of Pallas contributed 100% of their ownership interests to MBE, LLC. MBE, LLC is owned by Richard S. Mullen (Managing Member), Charles C. Evangelakos (Managing Member), and Gregory E. Boyle (Managing Member). The Advisors is managed by Richard S. Mullen (Founding Partner & Chief Executive Officer), Charles C. Evangelakos (Managing Director & Co-Founder), and Gregory E. Boyle (Founding Partner & Chief Growth Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Pallas. For information regarding this Disclosure Brochure, please contact James C. Landry (President / Chief Operating Officer & Director of Planning / Chief Compliance Officer) at (781) 971-5052. B. Advisory Services Offered Pallas offers wealth management services which include investment management, financial planning and/or other advisory services to individuals, high net worth individuals, trusts, estates and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Pallas's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Pallas provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management, financial planning, and related advisory services as described below. Investment Management – Pallas works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Pallas will then construct an investment portfolio, consisting exchange-traded funds (“ETFs”), open-end mutual funds, individual stocks, individual bonds, and closed-end mutual funds. The Advisor may also utilize covered options, alternative investments, limited partnerships, and/or other types in investments, as appropriate, to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Pallas’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Pallas will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Pallas evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Pallas may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Pallas may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Pallas may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 4  Pallas will provide investment management services and related services. Pallas accepts custody of a Clients funds or securities, through the deduction of management fees from the Client’s account[s] at the Custodian, and in certain situations where a Supervised Person of Pallas may act as trustee or power of attorney for client accounts. For more information see Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – Pallas may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosure Participant Account Management- As part of the Advisor’s Wealth Management Services, when appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. The Advisor is not affiliated with the platform in any way and do not receive compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance, and changes in allocations will take into account current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce certain Clients to a non- purpose loan program made available through the recommended custodian. In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Digital Assets – As a courtesy to Clients, the Advisor will provide interested Clients with access to establish digital currency accounts through Fidelity Digital Asset Services, LLC (“FDAS”). “Digital Asset” shall mean a digital asset (also called a “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as bitcoin, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value. The Advisor does not manage, nor will the Advisor bill on any digital asset accounts. Additionally, Clients will be provided with a disclosure document detailing the risks associated with digital assets. Financial Planning Services – Pallas will typically provide a variety of financial planning and consulting services to Clients as part of a wealth management engagement. Certain Clients may be offered financial planning and consulting services Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 5  as a separate engagement, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and/or other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Pallas may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor. However, Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Family Office Services The Advisor also provides Family Office Services. Family Office Service Clients are generally ultra-high net worth families. This high-touch service offering begins with the Advisor assisting Clients in establishing a team of advisors to oversee many facets of a Client's’ financial situation. The Advisor’s specific services generally include, strategic and tactical planning in addition to investment management services. Strategic planning may include, but is not limited to: • Family Values Identification and Alignment • Family Communication Planning & Implementation • Family Education and Leadership Development • Family Governance & Role Clarification • Family and Business History • Retreats and Education • Philanthropy Tactical planning may include, but is not limited to: • Family Enterprise Administration, Consulting and Succession Planning • Net Worth Management • Estate and Tax Planning • Risk Management and Insurance • Strategic and Thematic Investing Impact Investing and Philanthropy • Retirement Plan Advisory Services Pallas provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 6  ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● Investment Policy Statement (“IPS”) Design and Monitoring ● Non-discretionary Investment Oversight Services (ERISA 3(21)) ● Discretionary Investment Management Services (ERISA 3(38)) ● Performance Reporting ● Ongoing Investment Recommendation and Assistance These services are provided by Pallas serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Pallas’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Investment Consulting Services The Advisor provides investment consulting services to certain third party registered investment advisors (herein “Third Party”). In such instances, the Advisor shall provide recommendations to Third Parties regarding the investment and reinvestment of the Third Party’s client accounts in accordance with the investment objectives, guidelines, restrictions, and investment strategy set forth in the information provided to the Advisor by the Third Party. The Third Party will determine, in its sole discretion, the securities to be purchased or sold or exchanged and what portion, if any, of the assets shall be held un-invested for that portion of the Third Party’s client account’s. The Third Party is not obligated to implement the Advisor’s recommendations. The Advisor does not have trading authorization for any of the Third Party’s client accounts. C. Client Account Management Prior to engaging Pallas to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Pallas, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Pallas will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Pallas will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Pallas will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs In certain instances, Pallas includes securities transaction fees, custodial costs, and other fees and expenses (herein “Covered Costs”) together with its investment advisory fees as a single, bundled fee. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients and does not provide different services for Clients in the Wrap Fee Program. The Advisor does not charge a higher fee for inclusion in its Wrap Fee Program. The Advisor sponsors the Pallas Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client will pay more or less in total fees than if the Client had paid its own transaction fees. To mitigate conflicts of interest, Pallas has negotiated a fixed rate with Fidelity Investments, Inc. for Covered Costs, which are based on assets under management in the Client’s account[s]. Charles Schwab & Co., Inc. may charge individual securities transactions costs to the Advisor, depending on the type on investments traded. Please see Item 5.C. as well as Item 12 and Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 7  E. Assets Under Management As of December 31, 2024, Pallas manages $3,195,166,308 in Client assets, $3,189,518,125 of which are managed on a discretionary basis and $5,648,183 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the average daily balance of assets under management with the Advisor during the prior calendar quarter. Wealth management fees range from 0.25% to 2.00% annually. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed rate fee schedule. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Pallas will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable account opening paperwork. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning Services Pallas offers financial planning services either on an hourly basis or for a fixed fee. Hourly fees range from $300 to $500 based on the complexity of the engagement and the resources provided by the Advisor. Fixed fees range from $1,500 to $20,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Family Office Services Family office service fees range from $5,000 to $30,000 per annum paid quarterly in advance. Depending on the needs and preferences of the Client, the fees may be asset-based or paid on a retainer basis. In certain circumstances, the Advisor may determine to pass on fees associated with the use a third-party portfolio management platform. Such fees are determined based upon the value of billable assets and ranges up to 0.04% annually. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50% and are billed in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. Investment Consulting Services The Advisor will receive a fee from each Third-Party advisor for which it provides investment consulting services at the end of each quarter. The fee for each account will equal (on an annualized basis) up to 0.30% (30 basis points) of the Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 8  client advisory fee that is charged by the Third-Party advisor, pursuant to the terms of the investment consulting agreement. B. Fee Billing Wealth Management Services Generally, wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the year, multiplied by the number of days in the quarter) to the average daily balance of assets under management with the Advisor during the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Pallas to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Certain Clients may pay advisory fees via direct invoice utilizing credit card processing systems. Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Advisor and the Independent Manager will each assume the responsibility for calculating and deducting their respective fees from the Client’s account[s]. Financial Planning Services Financial planning fees may be invoiced up to 100% of the expected total fee upon execution of the financial planning agreement. The balance, if applicable, shall be invoiced upon completion of the agreed upon deliverable[s]. The Advisor completes financial planning engagements in six (6) months or less. The Advisor will not collect an advance fee of $1,200 or more for services that will not be completed in under six (6) months. Family Office Services Family office service fees are payable quarterly in advance and will be calculated by the Advisor or its delegate and either invoiced directly to the Client or deducted from the Client’s account[s] at the Custodian. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Investment Consulting Services Fees will be paid from the respective Third Party to the Advisor, pursuant to the terms of the investment consulting agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Pallas, in connection with investments made on behalf of the Client’s account[s]. For Clients with accounts at Fidelity Investments, Pallas typically includes securities transactions costs as part of its overall investment advisory fee through the Pallas Wrap Fee Program. Pallas has negotiated a fixed rate with Fidelity for Covered Costs, which are based on assets under management in the Client’s account[s]. Certain accounts or investments may be excluded from this fixed rate arrangement, and will be outlined in the Client’s agreement with the Advisor. Clients in the Pallas Wrap Fee Program that have engaged Charles Schwab & Co., Inc. as the Custodian will not be charged securities transactions costs. Schwab typically does not charge securities transaction fees for ETF and equity trades in a Client’s account[s], provided that the account meets the terms and conditions of the Schwab’s brokerage requirements. However, the Schwab typically charges for mutual funds and other types of investments. The Pallas Wrap Fee Program covers these costs, if any. Pallas may have an incentive to select investments with no securities transaction fees over other investments. Pallas, in its fiduciary duty, will select the investments most appropriate for the Client’s Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 9  investment portfolio[s], regardless of securities transaction costs. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D above as well as Appendix 1 – Wrap Fee Program Brochure. In addition, all fees paid to Pallas for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Pallas, but would not receive the services provided by Pallas which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Pallas to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Pallas may be compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers – In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set forth in the respective agreements between the Advisor and the Independent Managers. Financial Planning Services Pallas requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Family Office Services Pallas is compensated for its services in advance of the quarter in which family office services are rendered. Either party may terminate the family office services agreement with the Advisor, at any time, by providing advance written notice to the other party. The Client shall be responsible for family office services fees up to and including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s family office services agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Pallas is compensated for its services at the beginning of the quarter before advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 10  Investment Consulting Services Pallas is compensated for its services after investment consulting services are rendered. Either party may terminate the investment consulting agreement, at any time, by providing advance written notice to the other party. The Third Party may also terminate the investment consulting agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Third Party. After the five-day period, the Third Party will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment consulting agreement with the Advisor is non-transferable without the Third-Party’s prior consent. E. Compensation for Sales of Securities Pallas does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc (CRD# 35747, “PKS”). PKS is a registered broker-dealer and member of FINRA/SIPC. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person will implement securities transactions under PKS and not through Pallas. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because the Advisory Person who is a Registered Representative has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor nor Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 below. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Any commissions generated by insurance sales do not offset regular advisory fees. Accordingly, this practice presents a conflict of interest in that the Advisor may be further compensated if the client purchases insurance products. However, clients are under no obligation to implement any recommendations made by any Advisory Persons or the Advisor, and furthermore, if the client decides to purchase insurance products, he or she is under no obligation to purchase the insurance product through the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Pallas does not charge performance-based fees for its investment advisory services. The fees charged by Pallas are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Pallas does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Pallas offers investment advisory services to individuals, high net worth individuals, trusts, estates and retirement plans. Pallas generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Pallas primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Pallas are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 11  Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Pallas will be able to accurately predict such a reoccurrence. As noted above, Pallas generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Pallas will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Pallas may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Pallas will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies. Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 12  and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Fixed Income Risks Fixed Income Securities are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with a high-risk tolerance. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 13  Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Pallas or its management persons. Pallas values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310327. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also a Registered Representatives of PKS. In one’s separate capacity as a Registered Representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person in one’s separate capacity as a Registered Representative. Neither the Advisor nor the Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Pallas. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Any commissions generated by insurance sales do not offset regular advisory fees. Accordingly, this practice presents a conflict of interest in that the Advisor may be further compensated if the client purchases insurance products. However, clients are under no obligation to implement any recommendations made by any Advisory Persons or the Advisor, and furthermore, if the client decides to purchase insurance products, he or she is under no obligation to purchase the insurance product through the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Pallas has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Pallas (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Pallas and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Pallas’ Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (781) 971-5052. B. Personal Trading with Material Interest Pallas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Pallas does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Pallas does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Pallas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 14  by trading based on material non-public information. This risk is mitigated by Pallas requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Pallas allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Pallas, or any Supervised Person of Pallas, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Pallas does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Pallas to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Pallas does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Pallas does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Pallas. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. As certain Advisory Persons of Pallas are also Registered Representatives of PKS, this broker-dealer must also approve any broker-dealer or custodian for use by the Advisor. Pallas may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. Pallas will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), and Charles Schwab & Co, Inc. (“Schwab”)(each a “Custodian” and collectively the “Custodians”). The Custodians are each a FINRA-registered broker-dealer and member SIPC. The Custodians will serve as the Client’s “qualified custodian”. Pallas maintains an institutional relationship with the Custodians, whereby the Advisor receives certain support and economic benefits. Pallas has established an institutional relationship with the Custodians to assist the Advisor in managing Client account[s]. Access to the Custodians’ platforms are provided at no charge to the Advisor. The platforms include brokerage, custody, administrative support, recordkeeping, technology and related services designed to support registered investment advisors like Pallas in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. The Custodians may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. The Custodians enable the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. Commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by the Custodians may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Pallas does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodians. Please see Item 14 below. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 15  2. Brokerage Referrals - Pallas does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Pallas will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Pallas will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. A Client may pay a commission that is higher than another qualified custodian might charge to effect the same transaction. The Advisor has determined in good faith that the commissions charged by Fidelity are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not necessarily the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Custodian’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although the Advisor will seek competitive rates, to the benefit of all Clients, it may not necessarily obtain the lowest possible commission rates for specific Client account transactions. Although the investment research products and services that may be obtained by the Advisor will generally be used to service all of the Advisor’s Clients, they may not equally benefit all Clients. Please also see Item 14. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Pallas will execute its transactions through the Custodian as authorized by the Client. Pallas may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Chief Compliance Officer of Pallas. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Pallas if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 16  Item 14 – Client Referrals and Other Compensation A. Compensation Received by Pallas Pallas is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Pallas does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Pallas may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Pallas may receive non- compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform (Fidelity) As noted in item 12, Pallas has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also make available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity’s services. The Advisor examined this conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Participation in Institutional Advisor Platform (Schwab) Pallas has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Pallas. As a registered investment advisor participating on the Schwab Advisor Services platform, Pallas receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and support to Pallas that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 17  a potential conflict of interest. Pallas believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Pallas does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Pallas exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Pallas to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Pallas to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize Pallas to move funds between their accounts, Pallas and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Pallas generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Pallas. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Pallas will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Pallas may assume the authority for proxy voting, pursuant to the terms of the Client’s agreement with the Advisor and the account set up at the Custodian. The Client shall typcically maintain exclusive responsibility for all legal proceedings or other type events pertaining to the account assets, including, but not limited to, class action lawsuits. The Advisor shall vote proxies and to do so in the best interest of its Clients. Any material conflicts of interest between the Advisor’s interests and those of our Clients with regard to proxy voting must be resolved before proxies are voted. The Advisor subscribes to a nationally-recognized proxy monitor and voting agent service and will follow the recommendations offered by that service. Clients may request a copy of the Advisor’s written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting the Advisor’s CCO. Item 18 – Financial Information Neither Pallas, nor its management, have any adverse financial situations that would reasonably impair the ability of Pallas to meet all obligations to its Clients. Neither Pallas, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Pallas is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 18  Pallas Capital Advisors LLC Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) Effective: September 8, 2025 This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Pallas Capital Advisors LLC (“Pallas” or the “Advisor”) when offering services pursuant to a wrap fee program. This Wrap Fee Program Brochure shall always be accompanied by the Pallas Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Pallas Disclosure Brochure or you have any questions about the content of this Wrap Fee Program Brochure or the Pallas Disclosure Brochure, please contact the Advisor at (781) 971-5052. Pallas is a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about Pallas to assist Clients in determining whether to retain the Advisor. information about Pallas and its Advisory Persons the SEC’s website at Additional is available on http://www.adviserinfo.sec.gov/ by searching with the Advisor’s firm name or CRD# 310327. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 19  Item 2 – Material Changes This Wrap Fee Program Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs offered by the Advisor. Material Changes The following material changes have been made to this Wrap Fee Program Brochure since the annual amendment filing on March 5th, 2025: • Effective May 30, 2025, Gaurav Mallik is no longer the Advisor’s Chief Investment Officer. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Brochure (along with the complete Pallas Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Pallas. You may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov/ by searching with the Advisor’s firm name or CRD# 165516. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (781) 971- 5052. Item 1 – Cover Page ............................................................................................................................................. 17 Item 2 – Material Changes ................................................................................................................................... 20 Item 4 – Services, Fees and Compensation ...................................................................................................... 21 Item 5 – Account Requirements and Types of Clients ..................................................................................... 22 Item 6 – Portfolio Manager Selection and Evaluation ...................................................................................... 22 Item 7 – Client Information Provided to Portfolio Managers ........................................................................... 25 Item 8 – Client Contact with Portfolio Managers .............................................................................................. 25 Item 9 – Additional Information .......................................................................................................................... 25 Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 20  Item 4 – Services, Fees and Compensation A. Services Pallas Capital Advisors LLC (“Pallas” or the “Advisor”) provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Pallas Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting Pallas as your investment advisor. As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, Pallas includes, in addition to securities transaction fees, custodial costs, and other fees and expenses (herein “Covered Costs”) as part of its wealth management fee through this Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s recommended Custodian does not charge securities transaction fees for exchange-traded fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of investments. The Advisor sponsors the Pallas Wrap Fee Program. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back to the Pallas Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Pallas’ investment philosophy and related services. B. Program Costs Advisory services provided by Pallas are offered in a wrap fee structure whereby Covered Costs are included in the overall wealth management fee paid to Pallas. Pallas has negotiated a fixed rate with Fidelity for Covered Costs, which are based on assets under management in the Client’s account[s]. Certain accounts or investments may be excluded from this fixed rate arrangement with Fidelity and in such instances those accounts will be subject to securities transaction fees. These accounts or investments will be outlined in the Client’s agreement with the Advisor. Accounts with Charles Schwab & Co., Inc. as the Custodian will be charged securities transactions costs, however Schwab typically does not charge securities transaction fees for ETFs and equity trades in a Client’s account[s], provided that the account meets the terms and conditions of the Schwab’s brokerage requirements. The Pallas Wrap Fee Program covers these costs, if any. Pallas may have an incentive to select investments with no securities transaction fees over other investments. Pallas, in its fiduciary duty, will select the investments most appropriate for the Client’s investment portfolio[s], regardless of securities transaction costs. Securities transaction fees for Client-directed trades may be charged back to the Client. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 21  fees. The Advisor has negotiated a fixed rate with its recommended Custodian for Covered Costs, which is based on assets under management in the Client’s account[s]. Certain accounts may be excluded from this fixed rate arrangement. In such instances, the Advisor may utilize certain investments that the Custodian provides with no-transaction fee (“NTF Investments”). Advisory Persons of the Advisor, in their fiduciary duty, will always seek the most appropriate investments for inclusion in a Client’s portfolio. As such, the Advisor has an incentive to utilize NTF Investments to limit the overall cost to the Advisor. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the average daily balance of assets under management with the Advisor during the prior calendar quarter. Management fees range from 0.25% to 2.00% annually. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed rate fee schedule. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Pallas will be independently valued by the Custodian. Pallas will conduct periodic reviews of the Custodian’s valuations. As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary investment management services provided by Pallas. Securities transaction fees for Client-directed trades may be charged back to the Client. Under this Wrap Fee Program, Pallas includes Covered Costs as part of its overall investment advisory fee. The Advisor has negotiated a fixed rate with its recommended Custodian for securities transaction fees, which is based on assets under management in the Client’s account[s]. Certain accounts may be excluded from this fixed rate arrangement. In such instances, the Advisor may utilize certain investments that the Custodian provides with no-transaction fee (“NTF Investments”). Advisory Persons of the Advisor, in their fiduciary duty, will always seek the most appropriate investments for inclusion in a Client’s portfolio. As such, the Advisor has an incentive to utilize NTF Investments to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Free Program when it is believed to be in the Client’s best interest. The Advisor, in its fiduciary duty, will select the investments most appropriate for the Client’s investment portfolio[s], regardless of securities transaction costs. Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. In addition, all fees paid to Pallas for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses may include, but are not limited to fund management fees, fund expenses, account administration (e.g., custody, brokerage and account reporting), distribution fees, short-term redemption fees and/or alternative investment brokerage fee. A Client may be able to invest in these products directly, without the services of Pallas, but would not receive the services provided by Pallas which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Pallas to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Pallas is the sponsor and portfolio manager of this Wrap Fee Program. Pallas receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients Pallas offers investment advisory services to individuals, high net worth individuals, trusts, estates and retirement plans. Pallas generally does not impose a minimum relationship size. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 22  Pallas serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons Pallas personnel serve as portfolio managers for this Wrap Fee Program. Pallas does not serve as a portfolio manager for any third-party wrap fee programs. Performance-Based Fees Pallas does not charge performance-based fees. Supervised Persons Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Brochure) for details on the research and analysis methods employed by the Advisor. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Pallas will assist Clients in determining an appropriate strategy based on their risk tolerance and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, risk tolerance and other factors to develop an appropriate strategy for managing a Client's account[s]. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Fixed Income Risks Fixed income securities are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 23  obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Non-Purpose Loans and Lines of Credit Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s]. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with a high-risk tolerance. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Pallas may assume the authority for proxy voting, pursuant to the terms of the Client’s agreement with the Advisor and the account set up at the Custodian. The Client shall typcically maintain exclusive responsibility for all legal proceedings or other type events pertaining to the account assets, including, but not limited to, class action lawsuits. The Advisor shall vote proxies and to do so in the best interest of its Clients. Any material conflicts of interest between the Advisor’s interests and those of our Clients with regard to proxy voting must be resolved before proxies are voted. The Advisor subscribes to a nationally-recognized proxy monitor and voting agent service and will follow the recommendations offered by that service. Clients may request a copy of the Advisor’s written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting the Advisor’s CCO. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 24  Item 7 – Client Information Provided to Portfolio Managers Pallas is the sponsor and sole portfolio manager for the Wrap Fee Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the Pallas Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Pallas is a full-service investment management advisory firm. Clients always have direct access to the Advisory Persons at Pallas. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations There are no legal, regulatory or disciplinary events involving Pallas or its management persons. Pallas and its Supervised Persons value the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisor Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310327. Please see Item 9 of the Pallas Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Broker-Dealer Affiliation – As noted in Item 10 of the Disclosure Brochure, certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc (CRD# 35747, “PKS”). In one’s separate capacity as a Registered Representative of PKS, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person in one’s separate capacity as a Registered Representative. Neither the Advisor nor the Advisory Person will earn ongoing investment advisory fees in connection with any products or services implemented in an Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations – As noted in Item 10 of the Disclosure Brochure, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Pallas. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Persons or the Advisor. Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Pallas has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Pallas’ compliance program (our “Supervised Persons”). Complete details on the Pallas Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Review of Accounts Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Pallas and periodically by the Chief Compliance Officer (“CCO”). Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 25  Other Compensation Institutional Advisor Platform (Fidelity) – Pallas has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also make available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity’s services. The Advisor examined this conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Participation in Institutional Advisor Platform (Schwab) – Pallas has established an institutional relationship with Charles Schwab & Co, Inc. (“Schwab”). Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Pallas. As a registered investment advisor participating on the Schwab Advisor Services platform, Pallas receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and support to Pallas that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Pallas believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Brochure) for details on additional compensation that may be received by Pallas or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Brochure) provides details on any outside business activities and the associated compensation. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 26  such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Financial Information Neither Pallas, nor its management has any adverse financial situations that would reasonably impair the ability of Pallas to meet all obligations to its Clients. Neither Pallas, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Pallas is not required to deliver a balance sheet along with this Disclosure Brochure, as the firm does not collect advance fees of $1,200 or more for services to be performed six months or more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 27  Privacy Policy Effective: September 8, 2025 Our Commitment to You Pallas Capital Advisors LLC (“Pallas” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Pallas (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Pallas does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 28  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Pallas shares Client information with Purshe Kaplan Sterling Investments, Inc. (“PKS”) due to the oversight PKS has over certain supervised persons of the Advisor. You may also contact us at any time for a copy of the PKS Privacy Policy. Marketing Purposes Pallas does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Pallas or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Pallas does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 29  Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (781) 971-5052. Pallas Capital Advisors LLC 45 Braintree Hill Office Park, Suite 201, Braintree, MA 02184 Phone: (781) 971-5052 | Fax: (781) 971-5103 https://pallascapitaladvisors.com Page 30