SC ASESORES EN INVERSIONES INDEPENDIENTES SA DE CV

SC ASSET MANAGEMENT ASESORES EN INVERSIONES INDEPENDIENTES, S.A. DE C.V. Av Paseo de los Tamarindos 90 Torre 2 Piso 6 Mexico City, Mexico 05120 Telephone: 55 525 19309 E-mail: jvilla@summa-coporation.com This Brochure provides information about the qualifications and business practices of SC Asset Management Asesores en Inversiones Independientes, S.A. de C.V. If you have any questions about the contents of this Brochure, please contact us at telephone number 55 525 19309 and/or by email at jvilla@summa-coporation.com. The information in this Brochure has not been approved or verified by any state or federal securities authority. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications received from an adviser provide you with information about which to utilize in determining to hire or retain an investment adviser. Additional information about SC Asset Management Asesores en Inversiones Independientes, S.A. de C.V is also available on the SEC’s website at www.adviserinfo.sec.gov. March 2026  Item 3 - Table of Contents Item 2 – Material Changes ................................................................................................................................. 3 Item 4 – Advisory Services ............................................................................................................................... 3 Item 5 – Fees and Compensation .................................................................................................................... 6 Item 6 - Performance-Based Fees and side-by-side management ...................................................... 8 Item 7 - Types of Clients .................................................................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 8 Item 9 - Disciplinary Information ................................................................................................................ 11 Item 10 - Other Financial Industry Activities and Affiliations ......................................................... 12 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................................... 13 Item 12 - Brokerage Practices ....................................................................................................................... 18 Item 13 - Review of Accounts ....................................................................................................................... 20 Item 14 - Client Referrals and Other Compensation ............................................................................ 20 Item 15 - Custody ............................................................................................................................................... 21 Item 16 - Investment Discretion ................................................................................................................... 21 Item 17 - Voting Client Securities ............................................................................................................... 21 Item 18 - Financial Information .................................................................................................................... 21 P a g e | 2  Item 2 – Material Changes This Brochure provides information about the qualifications and business practices of SC Asset Management Asesores en Inversiones Independientes, S.A. de C.V referred to as (“SC Asesores” or the “Adviser,” or “we,” or “us,” or “our”). The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. You will receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year, which is December 31 of each year. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting us at phone number 55 525 19309 and/or by email at jvilla@summa-coporation.com information about SC Asesores is also available via Additional the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the Adviser who are registered, or are required to be registered, as Investment Adviser Representatives (“IARs”) of SC Asesores. SC Asesores is newly established Foreign Registered Investment Advisory Firm, as such, there are no materials changes as of the date of this Brochure. P a g e | 3  Item 4 – Advisory Services General SC Asesores is a company organized under the laws of Mexico and is an SEC-registered investment adviser (a non-U.S. investment adviser) with its principal office and place of business in Mexico. SC Asesores is directly owned by: ▪ I Kapital Advisor S.A.P.I de C.V. ▪ Alejandro Gonzalez Luna Mallet ▪ Valex Fondos S.A.P.I de C.V. ▪ Francisco Javier Villa Roiz ▪ Maria Alejandra Guillermo Lara I Kapital Advisor S.A.P.I de C.V. is primarily owned by IPG Investmetn Advisors, LLC, and Valex Fondos S.A.P.I de C.V. is majority owned by Jorge Eulalio Gutiérrez, and Bertha Sofia Pablos. Description of Advisory Services SC Asesores provides asset/portfolio management and financial advice to individuals, institutions, and corporations. SC Asesores’ investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in SC Asesores’ investment advisory agreement. The Adviser’s investment management services include the design and implementation of personalized investment strategies for managed Accounts. Investment activities may focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies, restrictions, time horizon, and risk profile as described by each client and documented through the account opening process and/or the client’s Investment Policy Statement (“IPS”). The overall advisory services offered by SC Asesores generally fall within the following categories: ➢ Customized Discretionary Portfolios SC Asesores offers discretionary separately managed accounts that are customized to each client. Managed Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies, and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to, or may vary from, the strategies typically utilized by the Adviser, or may be customized for each client based upon varying factors. Clients may set targets for these Accounts and may restrict the types of investments made in such Accounts. SC Asesores tailors’ investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation and/or the managed account agreement and, where applicable, reflected in the client’s IPS. SC Asesores’ clients are allowed to impose reasonable restrictions on the investments in their account. All limitations and restrictions placed on Accounts must be presented to SC Asesores in writing and accepted by SC Asesores. P a g e | 4  Fees for customized discretionary portfolio management are described in the “Fees and Compensation” section of this brochure and/or in the client’s advisory agreement. ➢ Sub-Advisory and Co-Managed Services SC Asesores provides investment advisory services and may coordinate with its affiliated U.S. registered investment adviser, IPG Investment Advisors, LLC (“IPG-IA”) (CRD No. 152990), in connection with certain client relationships. For clients seeking portfolio management with assets invested in Mexico and/or denominated in Mexican pesos (MXN), SC Asesores and IPG-IA may enter into arrangements under which IPG-IA will act as a sub-adviser to SC Asesores, or the firms will co-manage the client’s account pursuant to written agreements and the client’s advisory contract. Under a sub-advisory arrangement, SC Asesores typically serves as the primary adviser to the client and retains overall responsibility for the relationship, including client onboarding, suitability, and ongoing supervision, while IPG-IA, as sub-adviser, will provide investment management and related services as agreed. Under a co-managed arrangement, SC Asesores and IPG-IA may each have responsibility for designated portions of the portfolio or for different aspects of the advisory services, as set forth in the applicable agreement(s). The scope of discretion, authority to place trades, and responsibility for implementation will be defined in the client’s advisory agreement and the applicable sub-advisory or co-management documentation. Unless otherwise agreed and disclosed, SC Asesores retains primary responsibility for oversight of the Account and supervision of any sub-adviser or co-manager. Fees and related compensation. The client’s total advisory fee and the party responsible for billing will be disclosed in the “Fees and Compensation” section of this brochure and/or in the client’s advisory agreement. Unless otherwise disclosed and agreed in writing, the client will not pay an additional advisory fee solely as a result of a sub-advisory or co-managed arrangement; any sub-advisory compensation payable to IPG-IA is paid by SC Asesores from its advisory fee. If a different fee structure applies such as a separate fee billed to the client for sub-advisory services, a different fee schedule for MXN- denominated strategies, or any fee-sharing arrangement, SC Asesores will disclose the applicable arrangement to the client in advance and obtain the client’s consent. ➢ Promoter - Referral Arrangements SC Asesores may also enter into promoter/referral arrangements, including arrangements involving IPG- IA, pursuant to which a promoter introduces prospective clients to the firm in exchange for compensation. Any such arrangement will be structured to comply with applicable law and will be disclosed to the client in writing, including the nature of the affiliation (if any), the services provided, and the terms of compensation. Unless specifically disclosed and agreed, promoter compensation is paid by SC Asesores (or the adviser party to the arrangement) and does not increase the advisory fee the client pays; however, promoter compensation creates an incentive for the promoter to recommend SC Asesores. Clients are not charged higher advisory fees solely because a promoter is compensated, unless specifically disclosed and agreed. Since SC Asesores and IPG-IA are affiliates, these arrangements may create conflicts of interest, including an incentive to recommend or select an affiliate and, where applicable, to allocate services in a manner P a g e | 5  that benefits the affiliate. SC Asesores seeks to mitigate these conflicts through written disclosures, supervision, and policies designed to ensure that recommendations are made in the client’s best interest. ➢ Other Non-Discretionary Advisory Services SC Asesores also provides non-discretionary advisory services to all types of clients in accordance with a non-discretionary advisory agreement between SC Asesores and the client. Each agreement typically defines the services to be provided and, if a fee is charged, the fees will be agreed to in the advisory agreement and/or described in the “Fees and Compensation” section of this brochure. SC Asesores also provides recommendations and research regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs and such advice may be provided to Accounts with assets maintained at various third parties. Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. SC Asesores investment advisory agreements will not be assigned without client consent. Wrap Program SC Asesores does not currently participate in any Wrap Fee Programs. Wrap Fee Programs are inclusive of most transaction costs and fees; therefore, the costs incurred will include brokerage costs and portfolio management whether on a discretionary or non-discretionary capacity. Assets Under Management SC Asesores is registered as an investment adviser in Mexico and is newly registered with the SEC. As of January 1, 2026, SC Asesores manages approximately $553,392,757 in client assets on a discretionary and non-discretionary basis. These amounts include assets managed for non-U.S. clients by SC Asesores as a Mexican registered investment adviser, prior to its registration with the SEC. Item 5 – Fees and Compensation Basic fee Schedule The specific manner in which fees are charged by SC Asesores) is established in each client’s written investment advisory agreement. Generally, fees for the management of Accounts are based upon a percentage of the total assets in the Account (including, where applicable, assets purchased on margin). The Adviser typically receives an annual management fee for advisory services ranging between 0.30% and 1.50% of the Account value (as further described below), or a fixed (flat) fee agreed between the parties prior to execution of the advisory agreement, whether the Account is managed on a discretionary or non-discretionary basis. All fees are negotiable. P a g e | 6  Sub-advisory/co-management arrangements. For Accounts that maintain a sub-advisory or co- managed arrangement with the Adviser’s affiliated U.S. registered investment adviser, IPG-IA, the client will not incur a separate advisory fee charged by IPG-IA unless specifically disclosed and agreed in writing. Instead, unless otherwise agreed, the Adviser pays any sub-advisory compensation to IPG-IA from the advisory fee the Adviser receives from the client, as described in the client’s advisory agreement and any related disclosure. Any material fee exclusions, fee-sharing arrangements, or other terms applicable to affiliated sub-advisory/co-management services will be disclosed to the client and documented in the client’s advisory agreement and/or related disclosures. Calculation and Deduction of Advisory Fees With respect to Accounts the Adviser manages on a discretionary or non-discretionary basis, clients are generally required to pre-authorize the Adviser and/or the client’s qualified custodian to directly deduct advisory fees from the client’s Account monthly in arrears, as described in the client’s advisory agreement. Unless otherwise agreed, fees are calculated based on the Account value as of a specified valuation date (e.g., month-end) set forth in the advisory agreement. Should the calculation method, valuation date, billing frequency, or payment structure related to advisory fees differ from the process described herein, the applicable fee arrangements will be outlined in the client’s advisory agreement. A client may pay more or less than similar clients depending on the particular circumstances of the client, including Account size, additional or differing levels of servicing, complexity of the engagement, or as otherwise agreed with specific clients. Clients that negotiate fees, including a flat fee, may end up paying a higher effective fee than that set forth above as a result of fluctuations in the client’s assets under management and Account performance. Clients may terminate their contracts without penalty, for a full refund, within 30 business days of signing the advisory contract, as described in the advisory agreement. Advisory fees are withdrawn directly from the client’s Account with the client’s written authorization, if applicable. Additional Fee Information Proration. Accounts initiated or terminated during a billing period will be charged a prorated fee for the portion of the billing period during which advisory services were provided, consistent with the client’s advisory agreement. Contributions and withdrawals may affect the advisory fee, and the treatment of such additions and withdrawals (including any proration methodology, if applicable) will be described in the client’s advisory agreement. Invoicing. In some instances, clients may receive an invoice for advisory fees and may choose to pay SC Asesores directly for fees billed for the relevant period, as agreed in the client’s advisory agreement. Implementation and brokerage-related costs. Client fees and expenses may differ based on where transactions are executed (e.g., Mexico vs offshore markets) and the brokers/custodians used; such costs (including commissions, spreads, and mark-ups/mark-downs) are borne by the client and are separate from the Adviser’s fee. Other fees and expenses. The Adviser’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses, which are generally incurred directly by the client. Clients may incur charges imposed by custodians, brokers, and other third parties, including but not limited to: custodial P a g e | 7  fees; brokerage commissions; mark-ups and mark-downs; spreads; deferred sales charges (if applicable); odd-lot differentials; transfer taxes; wire transfer and electronic funds fees; and other fees and taxes on brokerage account and securities transactions. Mutual funds and exchange traded funds also charge management fees and other expenses that are disclosed in a fund’s prospectus or offering documents. All such charges, fees, and commissions are in addition to the Adviser’s fee, and the Adviser does not receive any portion of these commissions, fees, or costs, unless otherwise specifically disclosed. Termination of the Agreement The advisory relationship is ongoing until terminated by either party in accordance with the client’s advisory agreement. The client or the Adviser may terminate an agreement by written notice to the other party with thirty (30) days’ advance notice, or as otherwise agreed between the client and the Adviser. If an agreement is terminated during a period in which the client has already paid advisory fees in advance (if applicable), the Adviser will reimburse, on a prorated basis, the unearned portion of any advisory fees collected for services not rendered. Unless otherwise directed by the client, any refund will be sent to the client’s address of record (or returned through the custodian, as applicable) within thirty (30) days of termination of the agreement. Item 6 - Performance-Based Fees and side-by-side management Performance-based fees are fees based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- based fees. SC Asesores does not charge performance-based fees and does not manage any accounts that are subject to performance-based fee arrangements. The Adviser’s fees are calculated as described in Item 5 (Fees and Compensation) and are not based on a share of capital gains or capital appreciation of a client’s account. Item 7 - Types of Clients SC Asesores provides asset and/or portfolio management services to individuals, institutions, and corporations. The minimum dollar value for establishing an Account is generally $160,000, although the Adviser may accept Accounts with lower initial investments at its discretion. The minimum may be waived or adjusted at the Adviser’s discretion based on the nature of the engagement and other factors. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss General Investment Strategies and Methods of Analysis SC Asesores utilizes a variety of methods of analysis in developing investment recommendations and managing client Accounts. The Adviser may maintain arrangements (formal and informal) with third parties, including affiliated entities, through which the Adviser receives general macroeconomic analysis of economies, currencies, markets, and market sectors, as well as research reports on specific securities, sample asset allocations, and certain administrative or operational support services. The Adviser uses such P a g e | 8  information as an analytical tool and also performs its own research and due diligence in connection with investment advisers, investment vehicles, and investment opportunities. The Adviser makes investment allocation decisions based on each client’s investment objectives, restrictions, time horizon, liquidity needs, and risk tolerance, among other factors. In discretionary Accounts, the Adviser identifies, structures, monitors, invests, and liquidates investments consistent with the client’s objectives and the Adviser’s strategy. The design and day-to-day management of client portfolios is determined by the Adviser through its assigned portfolio manager. Except in connection with sub-advisory arrangements (described below), third-party service providers that provide research or analytical information generally do not have access to, or knowledge of, the specific investment decisions and recommendations made for the Adviser’s clients. Through its strategy, the Adviser seeks asset preservation and capital appreciation by customizing asset allocations and selecting investment vehicles that the Adviser believes align clients’ risk/return expectations with long-term and short-term investment needs and goals. Portfolio allocations and expectations are implemented through various financial instruments and investment vehicles, which may include equities, fixed income securities, exchange-traded funds (“ETFs”), options and other derivatives, and alternative investments, among others. The Adviser selects and monitors investments for each asset class based on historical and prospective risk and return characteristics, suitability for each client’s needs, and applicable fees and expenses. Use of sub-advisers and affiliated relationships. The Adviser may engage its affiliated U.S. registered investment adviser, IPG-IA, as a sub-adviser in connection with certain “offshore” or non-Mexico transactions or strategies, as described in the client’s advisory agreement. The use of a sub-adviser may present conflicts of interest and introduces the risk that the sub-adviser’s investment decisions may differ from those the Adviser would make for the Account. The Adviser seeks to address these risks through oversight and monitoring of the sub-adviser relationship. Material Risks for Significant Investment Strategies While it is the intention of the Adviser to implement strategies designed to manage risk, there can be no assurance that such strategies will be successful. Investing in securities involves risk of loss, including the risk that a client may lose a substantial portion or all of the assets in its Account. The following is a discussion of typical risks applicable to the Adviser’s clients; it does not purport to be a complete explanation of all risks. There is no guarantee that, in any time period (particularly in the short term), a client’s portfolio will achieve appreciation or that a client’s investment objectives will be met. The value of securities in which the Adviser invests on behalf of clients may be volatile. Price movements may result from factors affecting individual companies, sectors or industries, or the securities markets generally. In addition, inflation, economic recession, changes in interest rates, political events, and other market conditions beyond the Adviser’s control may adversely affect investment results. The Adviser notes that, even where the Adviser does not employ leverage directly, underlying funds, pooled vehicles, or other investments held in client Accounts may utilize leverage, derivatives, or other strategies that can materially impact performance and, in turn, the value of a client’s portfolio. Mexico markets and local practices; offshore implementation. When implementing investment strategies involving Mexican markets, transactions may be executed through brokers/custodians in P a g e | 9  Mexico and may be subject to local market practices, settlement cycles, liquidity constraints, tax considerations, and transaction costs that may differ from those in other markets. In addition, Accounts invested in MXN-denominated securities or instruments may be exposed to currency exchange-rate risk even if the Adviser does not engage in foreign exchange trading for speculative purposes. Hedging Transactions May Increase Risk of Capital Losses The Adviser may utilize hedging strategies primarily to seek to manage risk and/or preserve capital. Investment products in which the Adviser invests client Accounts may utilize a variety of financial instruments, such as options, for risk management purposes. While hedging transactions may seek to reduce risk, such transactions may result in worse overall performance. Certain risks cannot be hedged, such as credit risk relating both to particular securities and counterparties. The Adviser will not always invest in funds or other investment vehicles that utilize hedging strategies. Leverage Certain strategies or underlying investment vehicles may use leverage, including borrowing, short selling, and derivatives such as swaps, futures, and options. While leverage can increase return potential, it also increases the risk of loss arising from adverse price changes. Where leverage is used indirectly (e.g., by a fund manager for a fund held in a client Account), a sharp decrease in the value of the investment can have a significant impact on a client’s portfolio and may increase volatility. Liquidity of Investment Portfolio The market for some securities in which the Adviser invests directly or indirectly on behalf of clients may be relatively illiquid. Liquidity relates to the ability to sell an investment in a timely manner. The market for relatively illiquid securities tends to be more volatile than the market for more liquid securities. Investments in relatively illiquid securities may restrict the ability of a fund or portfolio manager to dispose of investments at a price and time desired. Illiquidity risk can also arise in over-the-counter transactions, where there may be no regulated market and pricing may be established by dealers. Client Accounts invested in funds or other instruments that contain illiquid investments may be subject to these risks. Foreign Currency Markets The Adviser’s investment strategies may cause a client to be exposed to fluctuations in currency exchange rates where it invests directly or indirectly in securities denominated in currencies other than U.S. dollars. The Adviser generally does not engage in foreign currency trading for speculative purposes; however, underlying funds and other investment vehicles may engage in foreign currency transactions. Foreign exchange markets can be highly volatile, and significant changes in liquidity and prices can occur within short periods of time. Foreign exchange risks include, but are not limited to, exchange rate risk, interest rate risk, and potential interference by foreign governments through regulation of local exchange markets or capital controls. Derivatives The Adviser’s investment strategy may cause a client to be exposed to derivatives, including instruments and contracts the value of which is linked to one or more underlying securities, financial benchmarks or indices, currencies, or interest rates. Derivatives may be used for hedging or other purposes and can provide market exposure greater than the amount invested. As a result, a relatively small adverse market P a g e | 10  movement can result in the loss of the entire investment and may expose a client to losses exceeding the original amount invested. Structured Products The Adviser’s investment strategy may cause a client to be exposed to structured products that may be speculative in nature and involve high volatility. Structured products are complex and may involve leverage. Participation in structured products can subject investors to counterparty credit risk and liquidity risk. The issuer is often the ultimate counterparty and may be the only market maker; there may be limited or no secondary market, and it may be difficult to obtain a favorable price when selling. Clients should review offering or disclosure documents and understand the risks, fees, and expenses associated with these products. Settlement Risks The Adviser’s investment strategies may expose clients to the credit risk of parties with whom the Adviser (or underlying funds) trades and to the risk of settlement default. Market practices in emerging markets relating to clearing, settlement, and custody may present increased risks. Clearing, settlement, and registration systems in certain markets may be less developed than in more mature markets, which can result in delays and other material difficulties in settling trades and registering transfers. Emerging Markets The Adviser’s investment strategies may include direct and indirect investments in emerging markets, which involve special risks and considerations. These may include nationalization, expropriation or confiscatory taxation, foreign exchange controls, political changes, government regulation, social instability or diplomatic developments, and restrictions on foreign investment or repatriation of capital. Emerging markets may have smaller capital markets, limited liquidity, higher volatility, and less stringent accounting standards. Investments in emerging markets may become illiquid, constraining the Adviser’s ability to realize some or all of a client’s holdings. Investment Concentration Some client Accounts may have a high concentration in one sector, industry, issuer, or security, which may subject such Accounts to greater risk of loss in the event such investments decline in value. Material Risks for Particular Types of Securities The Adviser does not invest primarily in a specific security or type of security. Material risks associated with investing are described above. Item 9 - Disciplinary Information Investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of an adviser or the integrity of the adviser’s management. Adviser has no information applicable to this Item in reference to criminal, civil or regulatory actions applicable to the firm. However, one of its affiliates maintains regulatory actions which are properly disclosed. P a g e | 11  Item 10 - Other Financial Industry Activities and Affiliations General SC Asesores is responsible for selecting broker-dealers, dealers, banks, custodians, and other intermediaries for client transactions and for seeking best execution. “Best execution” means the Adviser seeks to execute transactions so that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In seeking best execution, the Adviser considers a range of factors, which may include: price; total transaction costs (including commissions, spreads, and mark-ups/mark- downs, as applicable); speed and likelihood of execution and settlement; liquidity; the size and complexity of the transaction; the intermediary’s financial responsibility and operational capabilities; and the quality and responsiveness of services provided. The Adviser may consider factors in addition to commission rates or other transaction charges when selecting intermediaries. Accordingly, the Adviser may not always obtain the lowest possible commission or transaction cost for each transaction. Non-U.S. (“Offshore”) Transactions (Including Mexico) For transactions effected outside the United States, including transactions in Mexican markets, SC Asesores generally places trades through non-U.S. broker-dealers, dealers, banks, and/or custodians in accordance with applicable local laws, rules, and market practices. Non-U.S. transactions may involve different settlement conventions, liquidity conditions, trading practices, and transaction costs than U.S. markets. As a result, clients may incur transaction-related charges and expenses, including (as applicable) commissions, spreads, mark-ups/mark-downs, custodial and settlement charges, transfer taxes, and wire or transfer fees. These costs and expenses are borne by the client and are separate from, and in addition to, the Adviser’s management fee. In selecting non-U.S. brokers, dealers, banks, custodians, and other intermediaries (including in Mexico), SC Asesores seeks to obtain best execution by considering factors such as price, total transaction costs, speed and likelihood of execution and settlement, liquidity, and the intermediary’s execution, clearing, custody, and operational capabilities. The Adviser periodically reviews execution quality and service providers as part of its oversight process. Sub-Adviser Implementation for Certain Non-U.S./Offshore Transactions or Strategies For certain non-U.S. and/or “offshore” transactions or strategies, SC Asesores may engage its affiliated U.S. registered investment adviser, IPG-IA, as a sub-adviser to provide portfolio management and/or trade implementation services for all or a portion of a client Account, as described in the client’s advisory agreement and related documentation. The scope of IPG-IA’s authority (including whether IPG-IA provides non-discretionary recommendations and/or has authority to select brokers and execute transactions) will be set forth in the applicable agreements. Where IPG-IA is engaged and has authority to recommend, select, or execute transactions, IPG-IA may recommend or utilize broker-dealers or other intermediaries consistent with its own policies and procedures, including best execution considerations. SC Asesores maintains oversight of IPG-IA as sub- adviser in accordance with the applicable agreements and its policies and procedures. P a g e | 12  Affiliated Broker/Placement Relationships (Conflict of Interest) SC Asesores is under common ownership with IPG-IA. IPG-IA is affiliated with, and under common ownership with, Investment Placement Group, a Financial Industry Regulatory Authority (“FINRA”) registered broker-dealer. If IPG-IA recommends, selects, or uses Investment Placement Group (or any other affiliated entity) in connection with client transactions or investment activity (for example, for trade execution, placements, or other transaction-related services), this relationship creates a conflict of interest because IPG-IA has an incentive to select an affiliated firm rather than an unaffiliated firm. SC Asesores addresses this conflict through written disclosure and oversight of the sub-adviser relationship, and expects that any affiliated usage will be subject to applicable best execution considerations and any additional disclosures required by law. Client Brokerage Costs and Other Expenses Clients bear brokerage commissions (if applicable), spreads, mark-ups/mark-downs, custodial charges, and other transaction-related costs and expenses. In addition, clients who invest in mutual funds, exchange-traded funds (“ETFs”), or other pooled investment vehicles indirectly bear their proportionate share of those vehicles’ internal expenses (e.g., management fees and operating expenses), as described in the applicable prospectus or offering documents. These costs and expenses are in addition to the Adviser’s management fee. Trade Aggregation and Allocation Where appropriate and permitted, the Adviser may aggregate (combine) orders for multiple client Accounts for execution. When orders are aggregated, the Adviser seeks to allocate trades and related costs in a fair and equitable manner over time, consistent with its policies and procedures and applicable law. Not all orders can be aggregated due to factors such as client restrictions, order size, timing, or market conditions. Directed Brokerage If a client directs the Adviser to use a particular broker-dealer or intermediary for execution, the Adviser may be unable to seek best execution for those transactions and the client may pay higher transaction costs. In addition, directed brokerage may prevent the Adviser from aggregating orders with other clients, which may also affect execution quality and costs. Any directed brokerage arrangements will be documented in the client’s advisory agreement or in separate written instructions from the client. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading Policies Adviser has adopted the Code of Ethics pursuant to Rule 204A-l of the Advisers Act in an effort to prevent violations of federal securities laws. Adviser expects all employees to act with honesty, integrity and professionalism and to adhere to federal securities laws. P a g e | 13  All officers, directors, and employees of the Adviser and any other person who provides advice on behalf of Adviser and is subject to Adviser’s control and supervision (collectively referred to as “Supervised Persons”) are required to adhere to the Code. Prevention of Insider Trading Adviser has adopted policies designed to prevent insider trading that is more fully described in the Code. Adviser’s policy on insider trading applies to securities trading and information handling by all Supervised Persons of Adviser (including spouses, minor children and adult members of their households and any other relative of a Supervised Person on whose behalf Supervised Person is acting) for their own account or the account of any client of Adviser. Adviser takes its obligation to detect and prevent insider trading with the utmost seriousness. Adviser may impose penalties for breaches of the policies and procedures contained in this manual, even in the absence of any indication of insider trading. Depending on the nature of the breach, penalties may include a letter of censure, profit “give ups,” fines, referrals to regulatory and self-regulatory bodies and dismissal. Personal Securities Transactions Periodic Reports As more fully described in the Code, “access persons” are required to submit reports detailing their personal securities holdings to the Chief Compliance Officer on an initial basis, a quarterly basis, and an annual basis. As an alternative to submitting quarterly transaction reports, Adviser requires persons who are “access persons” to submit brokerage statements or trade confirmations as long as such documents contain the information required under Rule 204A-l(b)(2)(i)(A)-(E) under the Advisers Act. Initial Public Offerings and Limited Public Offerings Access Persons must obtain prior written approval from the Chief Compliance Officer before investing in initial public offerings (“IPOs”) or limited offerings (i.e., private placements). In the event the Chief Compliance Officer wishes to purchase IPOs or the securities of a private placement for his/her own employee account, the Chief Compliance Officer must obtain prior written approval from the Chief Executive Officer, who may seek advise on the matter from third parties if necessary. Review of Personal Securities Reports The Chief Compliance Officer (or their designee) is responsible for reviewing the Access Person’s Quarterly Transaction Reports as well as the Initial Holdings Report and the Annual Holdings Report as part of Adviser’s duty to maintain and enforce the Adviser’s Code. In instances when the Chief Compliance Officer has engaged in personal securities transaction, the Chief Executive Officer shall review the Chief Compliance Officer’s brokerage statements and/or trade confirmations. P a g e | 14  Outside Business Activities and Private Investments of Employees Unless otherwise consented by the Chief Compliance Officer, such as certain management and associated persons that are also registered or associated with our affiliate broker-dealer, SC Asesores Securities, all employees are required to devote their full time and efforts to Adviser’s business. As such, no person may make use of either his or her position as an employee or information acquired during employment, or make personal investments in a manner that may create a conflict, or the appearance of a conflict, between the employee’s personal interests and Adviser’s interests. Accordingly, every employee is required to complete a disclosure form and have the form approved by Adviser’s Chief Compliance Officer prior to serving in any of the capacities or making any of the investments more fully described in the Code. Reporting Violations All Supervised Persons (any officer, director, partner and employee of Adviser) are required to report actual or known violations or suspected violations of Adviser’s Code promptly to the Chief Compliance Officer or his designee. Any report of a violation or suspected violation of the Code will be treated as confidential to the extent permitted by law. As part of Adviser’s obligations to conduct an annual review of all of its policies and procedures pursuant to Rule 206(4)-7 of the Advisers Act, the Chief Compliance Officer shall review on an annual basis the adequacy of the Code and the effectiveness of its implementation. Recordkeeping Adviser maintains the following: ▪ Copies of the Code; ▪ Records of violations of the Code and actions taken as a result of the violations; ▪ Copies of Adviser’s supervised persons’ written acknowledgement of receipt of the Code; ▪ Records of Access Persons’ personal trading — Initial Holdings Reports, Annual Holdings Reports, and Quarterly Transaction Reports, including any information provided under Rule 204A- 1(b)(3)(iii) in lieu of such reports, i.e., brokerage confirmations and transaction reports; ▪ A record of the names of Adviser’s “Access Persons”; ▪ Records of decisions, and the reasons supporting the decision to approve an Access Person’s acquisition of securities in initial public offerings or limited offerings; and ▪ Records of decisions, and the reasons supporting the decision to approve the Chief Compliance Officer’s acquisition of securities in initial public offerings or limited offerings. Acknowledgement of the Code Each employee will execute a written statement certifying that the employee has (i) received a copy of Adviser’s Code; (ii) read and understands the importance of strict adherence to such policies and procedures; and (iii) agreed to comply with the Code. Training and Education P a g e | 15  All Supervised Persons, i.e., all employees, are to receive training on complying with the Code on an annual basis as part of Adviser’s annual employee compliance review meeting to ensure that all employees fully understand their duties and obligations and how to comply with the Policy’s procedures. Copies of Adviser’s Code A copy of Adviser’s Code is available upon request. For a copy, please contact Adviser at 55 525 19309. Participation or Interest in Client Transactions and Associated Conflicts of Interest Adviser may recommend or invest in securities, including funds, issued or managed by its affiliates (or where the affiliate acts as general partner) in which its affiliates have a material financial interest. Adviser has polices that require personnel who develop advice and recommendations for clients to render only disinterested and impartial advice to clients and to comply with other fiduciary obligations, including having an adequate basis in fact for all recommendations and an obligation to recommend only investments that are suitable for the particular client. The potential conflicts of interest involved in any such transactions are generally governed by Adviser’s Code. Pursuant to the stipulations of the Code, Adviser or a related person may buy or sell for itself securities that it also recommends to clients. The potential conflicts of interest involved in such transactions are governed by the Code, which establishes sanctions if its requirements are violated and requires that Adviser and employees place the interests of Adviser’s clients above their own. Investments in Securities by Adviser and its Personnel Adviser’s personnel or a related person of Adviser may invest in the same or similar securities and investments as those recommended to or entered into on behalf of Adviser’s clients. The results of the investment activities of Adviser’s personnel or related persons for their accounts may differ from the results achieved by or for client accounts managed by Adviser. The conflicts raised by these circumstances are discussed below. Adviser may recommend or effect the purchase or sale of securities in which its related persons or an affiliate, directly or indirectly, has a position or interest, or of which related or affiliated person buys or sells for itself. Such transactions may also include trading in securities in a manner inconsistent with the advice given to Adviser’s clients. Activities and transactions for client accounts may be impaired or effected at prices or terms that may be less favorable than would otherwise have been the case had Adviser or related persons not pursued a particular course of action with respect to the issuer of the securities. In addition, in certain instances Adviser’s personnel may obtain information about the issuer that could limit the ability of such personnel to buy or sell securities of the issuer on behalf of client accounts. Transactions undertaken by Adviser’s clients may also adversely impact one or more client accounts. Other clients of the Adviser may have, as a result of receiving reports or otherwise, access to information regarding Adviser’s transactions or views that may affect their transactions outside of accounts controlled by Adviser, and such transactions may negatively impact other clients’ accounts. A client’s account may P a g e | 16  also be adversely affected by cash flows and market movements arising from purchase and sale transactions by, as well as increases of capital in and withdrawals of capital from, other clients’ accounts. These effects can be more pronounced in less liquid markets. Adviser has adopted a Code of Ethics. Such Code of Ethics together with Advisers policies and procedures restrict the ability of certain officers and employees of Adviser from engaging in securities transactions in any securities that its clients have purchased, sold or considered for purchase or sale, for an appropriate “black out” period. Other restrictions and reporting requirements are included in Advisers procedures and Code of Ethics minimize or eliminate conflicts of interest. Trading Alongside by Adviser and its Personnel Client accounts managed by Adviser may trade in the same or similar securities at or about the same time as accounts managed or advised by affiliates of the Adviser. Investments by Adviser’s affiliates and their clients may have the effect of diluting or otherwise disadvantaging the values, prices or investment strategies of a client’s account, particularly in small capitalization, emerging market or less liquid investment vehicles. This may occur when portfolio decisions regarding a client’s account are based on research or other information that is also used to support portfolio decisions for Adviser’s affiliates. If a portfolio decision or strategy for Adviser’s affiliates’ accounts or the accounts of clients of affiliates is implemented ahead of, or contemporaneously with, similar portfolio decisions or strategies for Adviser’s client’s account, market impact, liquidity constraints, or other factors could result in the account receiving less favorable trading results and the costs of implementing such portfolio decisions or strategies could be increased. Errors and operational risks Errors may occur from time to time in transactions for client accounts. The Adviser will typically correct any such errors that are the fault of the Adviser at no cost to the client, other than costs that the Adviser deems immaterial. To the extent that the subsequent sale of such securities generates a profit to the Adviser, the Adviser may retain such profits, and may, but is not required to, use such profits to offset errors in the future or pay other client-related expenses. The Adviser will not be responsible for any errors that occur that are not the fault of the Adviser. Privacy Policy Adviser considers your privacy our utmost concern. Adviser does not share any information of clients with nonaffiliated third parties, except such information may be disclosed as necessary to process a transaction an investor has requested, to the extent the investor specifically authorized the disclosure, to service providers or joint marketers who agree to limit their use of such information, and to the extent required or specifically permitted by law or reasonably necessary to prevent fraud, unauthorized transactions or liability. When Adviser discloses non-public personal information of clients to a non-affiliated third party that provides services to Adviser or engages in joint marketing, Adviser shall: ▪ notify investors of the possibility of such disclosure; and P a g e | 17  ▪ enter into a contractual agreement with the third party that prohibits the third party from disclosing or using the investors’ information other than to carry out the purposes for which the information was disclosed to the third party. In particular, Adviser may enter, in compliance with the above conditions, into an agreement with a non- affiliated third party to store the records of Adviser clients and investors including electronic and e-mail records. As arranged with clients and pertaining to agreements with sub-advisers, the Adviser can share client information related to their investment profile, strategy and goals in order to receive appropriate information from such third parties (sub-advisers) and better serve the client account. For more information about Adviser’s privacy policies or to request a brochure describing Adviser’s privacy policies contact Adviser at 55 525 19309 and/or by email at jvilla@summa-coporation.com. Item 12 - Brokerage Practices SC Asesores typically has discretionary authority, subject to the terms and conditions set forth in the client agreement, to determine (1) the securities to be bought and sold, (2) the amount of securities to be bought and sold, and (3) the broker, dealer, bank, custodian, or other intermediary to be used to effect transactions. SC Asesores’ discretionary authority is limited by any reasonable restrictions that the client places on the management of the Account, provided such restrictions are communicated in writing and accepted by SC Asesores. Best Execution and Selection of Brokers, Dealers, and Custodians In recommending or selecting broker-dealers, dealers, banks, custodians, and other intermediaries, SC Asesores generally seeks to obtain best execution and the best overall combination of execution and services, taking into account the total cost and the range and quality of services provided. Relevant factors used in evaluating execution quality may include, among other factors: historical net prices; the execution, clearance, and settlement capabilities of the intermediary; error correction capabilities; willingness to commit capital; reliability and financial stability; the size and complexity of the transaction; liquidity; availability of securities to borrow for short sales (if applicable); and the market for the security. In addition to an intermediary’s ability to provide execution quality, SC Asesores’ selection criteria may include the value of various services or products provided by the intermediary. For example, SC Asesores may obtain: research reports or other information about particular companies, sectors, or industries; economic surveys and analyses; recommendations as to specific securities; electronic market quotations; non-mass-marketed financial publications; portfolio evaluation services; performance measurement services; market, economic and financial studies and forecasts; data on pricing and availability of securities; financial database software and services; and other products or services that may enhance its investment decision-making process. Non-U.S. (“Offshore”) Transactions (Including Mexico) For transactions effected outside the United States, including transactions in Mexican markets, SC Asesores generally places trades through non-U.S. broker-dealers, dealers, banks, and/or custodians in accordance with applicable local laws, rules, and market practices. Non-U.S. transactions may involve P a g e | 18  different settlement conventions, liquidity conditions, trading practices, and transaction costs than U.S. markets. As a result, clients may incur transaction-related charges and expenses, including (as applicable) commissions, spreads, mark-ups/mark-downs, custodial and settlement charges, transfer taxes, and wire or transfer fees. These costs and expenses are borne by the client and are separate from, and in addition to, SC Asesores’ management fee. In selecting non-U.S. intermediaries (including in Mexico), SC Asesores may consider additional factors relevant to local markets, including custody/clearing capabilities, settlement performance, operational controls, and overall service quality. SC Asesores periodically reviews execution quality and service providers as part of its oversight process. Sub-Adviser Implementation for Certain Offshore Transactions or Strategies For certain offshore transactions or strategies, SC Asesores may engage its affiliated U.S. registered investment adviser, IPG-IA, as a sub-adviser to provide portfolio management and/or trade implementation services for all or a portion of a client Account, as described in the client’s advisory agreement and related documentation. The scope of IPG-IA’s authority (including whether IPG-IA provides non-discretionary recommendations and/or has authority to select intermediaries and execute transactions) will be set forth in the applicable agreements. Where IPG-IA is engaged and has authority to recommend, select, or execute transactions, IPG-IA may recommend or utilize broker-dealers or other intermediaries consistent with its policies and procedures. SC Asesores maintains oversight of IPG-IA as sub-adviser in accordance with the applicable agreements and its policies and procedures. Affiliated Broker/Placement Relationships (Conflict of Interest) SC Asesores is under common ownership with IPG-IA. IPG-IA is affiliated with, and under common ownership with, Investment Placement Group, a FINRA registered broker-dealer. If IPG-IA recommends, selects, or uses Investment Placement Group (or any other affiliated entity) in connection with client transactions or investment activity (for example, for trade execution, placements, or other transaction- related services), this relationship creates a conflict of interest because IPG-IA has an incentive to select an affiliated firm rather than an unaffiliated firm. SC Asesores addresses this conflict through written disclosure and oversight of the sub-adviser relationship, and expects that any affiliated usage will be subject to applicable best execution considerations and any additional disclosures required by law. Aggregation and Allocation of Trades SC Asesores may aggregate (combine) purchase and sale orders for securities for one client with similar orders being made simultaneously for other client Accounts when, in the reasonable judgment of SC Asesores, aggregation is reasonably likely to result in an overall economic benefit to participating clients (for example, through improved pricing, reduced transaction costs, or more efficient execution). When orders are aggregated, SC Asesores generally allocates the resulting trades among participating Accounts in a fair and equitable manner, consistent with its policies and procedures. In general, where applicable, the average price of all securities purchased or sold in such transactions will be determined, and a client will be charged or credited, as the case may be, the volume-weighted average price. Although in any given case this practice could have a detrimental or beneficial effect upon the price or value of a security for a particular Account, SC Asesores believes that, on an overall basis, aggregation P a g e | 19  and allocation practices are beneficial to clients. There can be no assurance that any particular client will not be treated more or less favorably than another client with respect to any specific transaction. Soft Dollars and Research It is SC Asesores’ policy not to enter into soft dollar arrangements. SC Asesores has no formal soft dollar arrangements and does not direct client transactions to broker-dealers or other intermediaries for the purpose of obtaining client referrals. To the extent SC Asesores receives research or other products or services from intermediaries, SC Asesores seeks to ensure that any such benefits are consistent with applicable law and its policies and procedures. Brokerage for Client Referrals SC Asesores does not direct brokerage to particular broker-dealers or other intermediaries in consideration for client referrals. Item 13 - Review of Accounts Accounts are typically reviewed by the Chief Compliance Officer on a periodic basis or as needed due to market conditions or transactional activity, amongst other items. The Chief Compliance Officer typically reviews daily transactions entered into for investment advisory clients to determine that correct entries have been made for all client records. Factors Triggering a Review There are no specific triggering factors leading to a review. Client Reports Clients of the Adviser receive monthly reports from their qualified Custodian. The Adviser can provide a consolidated/performance report, upon request, or periodically as agreed between the Adviser and the client. The content of such consolidated/performance report will typically include a list of securities holdings, their respective market value as of month-end (or requested date), and performance information, as applicable. Item 14 - Client Referrals and Other Compensation The Adviser’s compensation is primarily in the form of asset-based management fees (or, in limited cases, a fixed fee), as described in Item 5 (Fees and Compensation). The Adviser maintains referral, solicitor, or promoter arrangements pursuant to which third party(ies) (whether affiliated or unaffiliated) receive cash or non-cash compensation for referring or soliciting prospective clients on behalf of the Adviser. The Adviser provides clients with required disclosures and conducts such arrangements in accordance with applicable law, including Rule 206(4)-1 under the Investment Advisers Act of 1940, as applicable, and the Adviser’s written policies and procedures. Separately, SC Asesores does not currently pay referral fees to, or receive referral fees or other compensation from, unaffiliated professionals (such as attorneys, accountants, or consultants) in connection with client referrals. P a g e | 20  Item 15 - Custody All assets are typically held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record monthly. SC Asesores does not maintain physical custody of its clients’ funds. Clients receive monthly or quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. Item 16 - Investment Discretion Adviser receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Adviser observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to Adviser in writing. Item 17 - Voting Client Securities SC Asesores does not vote proxies on securities, thus, clients are expected to vote their own proxies. Clients may request a copy of proxy voting records via contact to the Client’s respective custodian. Clients will receive proxies directly from the issuer of the security or the custodian. Clients may obtain a copy of SC Asesores’ voting policies and procedures, or proxy voting records upon request to jvilla@summa-coporation.com. Item 18 - Financial Information The Adviser has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. Also, the Adviser has not been the subject of a bankruptcy proceeding. P a g e | 21