SKYBOUND WEALTH USA

Form ADV Part 2A SKYBOUND WEALTH MANAGEMENT USA, LLC DBA SKYBOUND WEALTH USA 2700 POST OAK BOULEVARD, 21ST FLOOR, HOUSTON, TEXAS, 77056, USA +1 346 845 0001 WWW.SKYBOUNDWEALTHUSA.COM MARCH 27, 2026 This brochure provides information about the qualifications and business practices of Skybound Wealth Management USA, LLC. dba Skybound Wealth USA. If you have any questions about the contents of this brochure, please contact us at (346) 845 0001 or clientservices@skyboundwealthusa.com. 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. Registration with the SEC or notice filing with any state securities authority does not imply that Skybound Wealth Management USA, LLC dba Skybound Wealth USA or any of its principals or employees possesses a particular level of skill or training in the investment advisory business. Additional information about Skybound Wealth Management USA, LLC dba Skybound Wealth USA also is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 2 - MATERIAL CHANGES Since our last Form ADV Part 2A dated May 2025, we have made the following material changes: • Item 4 was amended to reflect a change in ownership from Victoria Creer to Joshua Burton. • Item 5 was amended to reflect changes to the Adviser’s fee schedule. • Item 10 was amended to include an additional affiliate, Skybound Wealth Management Limited (foreign branch of SWML – UK). • Item 14 was amended to provide additional disclosure regarding client referral arrangements within the Skybound group and the Adviser’s relationship with wealth.com. Page 2 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 3 – Table Of Contents Cover Page Item 1 – Cover Page 2 Item 2 - Material Changes 3 Item 3 - Table Of Contents 4 Item 4 - Advisory Business 9 Item 5 - Fees And Compensation 12 Item 6 - Performance-Based Fees And Side By Side Management 13 Item 7 - Types Of Clients 14 Item 8 - Methods Of Analysis, Investment Strategies And Risk Of Loss 18 Item 9 - Disciplinary Information 19 Item 10 - Other Financial Industry Activities And Affiliations 21 Item 11 - Code Of Ethics, Participation Or Interest In Client Transactions And Personal Trading 22 Item 12 - Brokerage Practices 24 Item 13 - Review Of Accounts 25 Item 14 - Client Referrals And Other Compensation 26 Item 15 - Custody 27 Item 16 - Investment Discretion 28 Item 17 - Voting Client Securities 29 Item 18 - Financial Information Page 3 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157  Item 4 – Advisory Business Skybound Wealth USA (“Skybound” or the “Firm”) provides investment management and financial planning services designed to help clients manage their wealth over the long term. The firm works with individuals, families, and internationally mobile clients seeking professional management of investment portfolios and guidance on retirement planning and broader financial matters. Skybound Wealth Management USA, LLC is owned by Skybound Wealth Management Group Limited, a Malta based holding company, and Joshua Burton, a principal of the firm. The firm is part of the Skybound Wealth Management group of affiliated financial services companies operating internationally. Skybound Wealth USA was established in 2017 and has been registered as an investment advisor with the United States Securities and Exchange Commission (“SEC”) since May 6th 2021. As of December 31, 2025, Skybound Wealth USA managed approximately $166,454,921 in regulatory assets under management. Of this amount, approximately $7,580,928 was managed on a discretionary basis and approximately $158,873,993 was managed on a non discretionary basis. The Firm’s non discretionary assets under management primarily reflect client relationships where Skybound provides ongoing investment advice, portfolio recommendations, and financial planning services, while clients retain final decision making authority or assets are implemented through third party platforms or managers. Skybound provides investment advisory services through investment adviser representatives (“Adviser Representatives” or “ARs”) to clients. At the outset of its relationship with you, Skybound designates a particular Adviser Representative to serve you in all matters regarding the delivery of wealth management services to you. Your designated AR helps you design a financial plan that is most suited to your financial circumstances, investment objectives and strategies, and risk tolerance. In addition, the Adviser Representative discusses with you the fees and costs you may incur for receiving these services. An Adviser Representative conducts all of his investment advisory activities as an associated person and supervised person of the firm. As a supervised person of Skybound, an Adviser Representative is subject to the supervision and control of Skybound in connection with all matters regarding this relationship. As an investment adviser, Skybound is a fiduciary in its dealing with clients. As such, Skybound must act at all times in your best interest as its client. It has a duty to be loyal to you and to provide you with full and fair disclosure of, and to mitigate, all material conflicts of interest that may arise in the course of performing its duties to you. It must seek best execution when conducting purchase or sale transactions on your behalf. It must ensure that the investment advice it provides to you is suitable given your financial circumstances, investment objectives, and risk tolerance, and that it has a reasonable, independent basis for this advice. And it, as well as all of its supervised persons and other personnel who are involved in delivering investment advisory services to you, must refrain from engaging in personal securities transactions that are inconsistent with your interests. Skybound also has fiduciary responsibilities with respect to retirement accounts of clients that are covered by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). As an ERISA fiduciary,Skybound is required to provide advice that is in the best interest of a covered client, charge fees that are reasonable in relation to the services provided to this client, and ensure that a covered client receives full and fair disclosure about recommended transactions, fees and compensation, conflicts of interest, or any other matters relevant to the client’s investment decision-making. Types of Services Investment Management Services Skybound provides ongoing investment management services designed to help clients build, manage, and preserve their wealth over the long term. These services involve continuous monitoring of client portfolios and the provision of investment advice tailored to each client’s financial objectives, risk tolerance, time horizon, and overall financial circumstances. Investment management services may be provided on either a discretionary or nondiscretionary basis. The type of authority granted will be defined in the client’s investment advisory agreement and related account documentation. Under a discretionary arrangement, Skybound is authorized to make investment decisions on behalf of the client without obtaining prior approval for each transaction. This authority may include determining the securities to be purchased or sold, adjusting portfolio allocations, selecting investment strategies, and implementing portfolio rebalancing when appropriate. Discretionary authority is granted by the client through the investment advisory agreement and associated account documentation. Under a nondiscretionary arrangement, Skybound provides investment recommendations but must obtain the client’s approval before executing transactions or making changes to the portfolio. Because client approval is required before trades can be implemented, nondiscretionary accounts may experience delays in executing investment decisions, which may result in missed opportunities or less efficient portfolio management. Certain investment strategies or model portfolio programs may require discretionary management in order to be implemented effectively. As a result, nondiscretionary management may not be available for accounts utilizing certain model portfolios or overlay management strategies. Page 4 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 As part of the investment management process, Skybound may perform one or more of the following services depending on the needs of the client: • Construct and manage diversified investment portfolios • Select securities, investment funds, or other investments to be purchased or sold within the portfolio • Adjust portfolio allocations and rebalance holdings periodically • Select and monitor third party investment managers or model portfolio strategies where appropriate • Provide ongoing oversight of portfolio performance and investment strategy • Periodically review the client’s financial circumstances and update investment recommendations as needed Clients may impose reasonable restrictions on the management of their accounts, including limitations on certain types of securities or investment strategies. Any such restrictions must be communicated to Skybound in writing and accepted by the firm. Clients also retain the right to modify or terminate the advisory relationship at any time in accordance with the terms of the advisory agreement. In many cases, Skybound may recommend that all or a portion of a client’s assets be managed by one or more unaffiliated third party investment managers or through investment management platforms, collectively referred to as “Independent Managers”. These Independent Managers may be accessed directly or through investment platforms that provide access to a range of investment strategies and portfolio managers. When Independent Managers are utilized, Skybound typically serves as the client’s primary adviser and relationship manager. Skybound assists the client in defining investment objectives, selecting appropriate managers or strategies, and establishing any investment restrictions or preferences applicable to the account. The Independent Manager will generally have discretionary authority for the day to day investment management of the assets placed under their management. Skybound performs initial and ongoing due diligence on Independent Managers to evaluate factors such as investment philosophy, performance history, regulatory standing, operational infrastructure, and overall suitability. Skybound also monitors the ongoing performance and strategy of these managers to help ensure that their approach remains consistent with the client’s investment objectives and overall portfolio strategy. Skybound does not receive compensation from Independent Managers for recommending their services unless otherwise disclosed to the client. In constructing client portfolios, Skybound may consider a range of investment types including equities, bonds, exchange traded funds, mutual funds, model portfolios, third party investment strategies, and private investment funds where appropriate. The specific investments used will depend on the client’s objectives, risk tolerance, liquidity needs, and time horizon. Skybound generally focuses on long term portfolio construction and diversification rather than attempting to predict short term market movements. However, portfolio allocations may be adjusted periodically in response to changes in market conditions, client circumstances, or investment objectives. In certain situations, portfolio strategies may also be modified to accommodate specific client considerations, including tax planning objectives or other financial circumstances. Investment management involves risk, including the potential loss of principal. While Skybound seeks to construct diversified portfolios designed to align with each client’s objectives and risk tolerance, no investment strategy can guarantee profits or protect against losses in all market conditions. Clients should carefully consider their investment objectives and risk tolerance before investing. Clients should be aware that transactions within taxable accounts, including portfolio rebalancing or reallocations, may generate taxable events. Tax consequences generally do not apply to transactions within qualified retirement accounts such as individual retirement accounts or other tax deferred retirement arrangements. Skybound encourages clients to consult with their tax advisers regarding the tax implications of investment decisions and portfolio transactions. Structured Products as Diversifying Investments As part of its portfolio construction methodology, Skybound Wealth Management USA, LLC (“Skybound”) may recommend structured products in certain circumstances as a diversifying investment within a client portfolio. Structured products are debt securities issued by financial institutions whose returns are linked to the performance of an underlying asset, index, basket of securities, or market benchmark. Depending on the structure, these investments may offer features such as defined income payments, partial downside protection, or participation in the performance of an underlying market or index subject to certain conditions. Within Skybound’s investment framework, structured products are classified as diversifying assets and may be used in limited allocations alongside traditional asset classes such as equities and fixed income. The inclusion of these investments is intended to provide additional diversification and alternative sources of return within a broader portfolio. Skybound does not structure, issue, or broker structured products. These investments are issued by third party financial institutions and are accessed through independent broker dealers that structure and distribute such products. Skybound may review structured products available through broker dealers, including Causeway Securities, and may recommend specific offerings from the available menu where the investment characteristics are consistent with a client’s objectives and portfolio strategy. Skybound acts solely in its capacity as an investment adviser when recommending structured products and does not receive commissions or placement fees related to the issuance or sale of these investments. Any compensation paid in connection with the distribution of structured products is received by the broker dealer involved in structuring or distributing the product and may be embedded within the product’s pricing. Page 5 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Structured products are considered as part of the overall portfolio allocation and are recommended only when the characteristics of the investment are consistent with the client’s investment objectives, risk tolerance, and time horizon. Although Skybound does not receive compensation in connection with these investments, the recommendation of structured products may present a conflict of interest due to the complexity of such products and the involvement of third party issuers and broker dealers. Estate Planning Coordination Services As part of its financial planning services, Skybound Wealth Management USA, LLC (“Skybound”) may assist clients with coordinating aspects of their estate planning. In certain circumstances, Skybound may recommend that clients use Wealth.com, a technology platform that facilitates the creation and administration of estate planning documents. Wealth.com provides digital tools that allow individuals to develop estate planning documentation through an online platform. Clients who choose to use the platform will establish a relationship directly with Wealth.com and, where applicable, with legal professionals engaged through the platform. Skybound does not provide legal advice and is not responsible for the drafting of estate planning documents. Any legal documentation produced through the platform is prepared by Wealth.com or by licensed legal professionals engaged through the platform. Skybound may assist clients in organizing information, coordinating planning objectives, and navigating the platform as part of the client’s broader financial planning process. UK Pension Transfer Services If you have previously lived and worked in the United Kingdom and now reside in the United States, you may maintain assets in defined benefit or defined contribution pension accounts that were established while living and working in the U.K. These assets are kept under arrangements with their former employers that involve the use of institutional trustees to safe-keep and administer the assets. Over the years, Skybound has found that many individuals may consider alternative that afford them more flexibility to manage their pension plan assets while they are living and working in the United States. Pension legislation in the United Kingdom has made it possible for individuals to transfer their pension assets to certain approved personal pension schemes so that they can manage those assets on a more flexible basis going forward. Skybound helps you, to assess whether a transfer to a Self Invested Personal Pension (SIPP) might be in your best interest. Skybound has established a process to elicit the right information in order to help you make this decision and to discuss the options that might be available to you. Additionally, we provide management services over any existing UK pensions including qualified retirement overseas pensions (QROPs). The process of transferring a UK defined benefit or contribution plan is a complex and lengthy process and has many layers of fees. It is important you understand the costs, expenses and that a transfer can take up to or over a year to complete, particularly for defined benefit plans. Further, defined benefit (DB) plan transfers will require you to engage a UK advisor, in addition to Skybound, to evaluate your situation and issue an advice report. This is an added cost that can be as high as 5000 GBP. This fee is set by the UK advisor and they are independent of Skybound. Additionally, you will be required to participate in an educational session to help you understand your options. You will be issued a written assessment or report by the UK advisor outlining whether a pension transfer should be considered. The report will outline the advantages and disadvantages of transferring and information on the various costs and expenses. It is important clients considering transferring their UK pension review consumer information provided at https://www.fca.org.uk/consumers. There are advantages and disadvantages to transferring a UK pension as well as costs. A pension transfer is not appropriate for all individuals. When making a transfer, you will be giving up certain guarantees offered by the pension. Skybound will provide you with a written assessment, for DB pensions this will be in addition to the assessment by the UK advisor, and if you choose to transfer your UK pension, Skybound will provide continuous and ongoing management services for an ongoing fee. Skybound will manage the assets or suggest the use of a third-party asset manager. Use of a discretionary fund manager or model manager or strategist will add additional costs which will be fully disclosed to you. It is important to understand that reporting on UK assets is different from the United States. Valuation statements are generally made available on an annual basis (unless otherwise specifically requested). However, most UK platform providers provide online access to your pension. We do not provide tax advice including, without limitation, in relation to any US tax reporting requirements and/or other tax implications arising in relation to clients’ pension transfers. We recommend you seek your own tax advice, including in relation to procedures under tax treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on non-US pension arrangements. Financial Planning Services We offer advisory services in the form of financial planning services. Financial planning services can be made available alongside investment management services or as a standalone service that Skybound offers for a fee as details in Item 5. Financial planning can be described as helping individuals determine and set their long-term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand their overall financial situation and help them set financial objectives. Page 6 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 We analyze and review the client’s financial documentation, which typically includes the client’s assets and liabilities, investment portfolio, retirement plan, education plan, risk management plan, risk tolerance, estate plan, and other areas relevant to the client’s financial health. We then provide an executive summary highlighting the plan of action. Our Wealth Managers are available to assist with implementing the plan and to answer any client questions. Still, the client is ultimately responsible for implementing or rejecting our recommendations. You are never obligated or required to implement our recommendations. Furthermore, we can implement the plan with the client throughout the year. It remains the client’s responsibility to promptly notify us of any changes in their financial situation or investment objectives to review, evaluate, or revise our previous recommendations and/or services. In the course of designing a financial plan, Skybound may enlist the assistance of third parties that are specialists in various disciplines, such as tax and estate planning. Skybound does not charge a fee or receive any other compensation or benefit for referring clients to these specialists. As a client, you are free to make your own arrangements with these specialists on terms that are acceptable to you. Financial planning services are separate from the Firm’s investment advisory services and may be provided independently or in conjunction with ongoing portfolio management. General Considerations Investment recommendations and advice offered by Skybound is not considered and should not be considered legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform Skybound promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify Skybound of any such changes will result in investment recommendations not meeting your needs. Skybound tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. Services will begin with an initial consultation and data gathering. Your Advisory Representative will ask you various questions about your financial situation and request certain documents about your financial accounts. You may be asked to complete a fact finder or data gathering document. The information gathered by Skybound will assist the firm to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, Skybound will gather various financial information and history from you including, but not limited to: • Retirement and financial goals • Investment objectives and horizon • Financial needs • Cash flow analysis • Cost of living needs • Education needs • Savings tendencies • Other applicable financial information required by Skybound in order to provide the investment advisory services requested. • SIPP product providers may be available through other investment advisers under slightly different programs with different fees, charges and restrictions. These should be considered in deciding who you select as your financial advisers and other service providers, including Skybound. An external service provider will have separate fee agreements as part of its service level agreement. These agreements will be provided to you for review and sign-off, at the same time as the appointment of your Adviser Representative and as part of your overall investment management agreement and package with us. IRA Rollover Considerations When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. As part of our consulting and advisory services, we offer you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations can include you consider withdrawing the assets from your employer’s retirement plan or other qualified retirement account and rolling the assets over to an individual retirement account (“IRA”). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand that many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: Page 7 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 1. Leave the funds in your employer’s (former employer’s) plan. 2. Move the funds to a new employer’s retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer’s retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans often have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy can have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could delay your required minimum distribution beyond age73. (You must take your first required minimum distribution starting the year in which you turn age 73 (72 if you reach 72 prior to January 1, 2023, or 70 ½ if you reach 70 ½ before January 1, 2020). If you reach 70½ in 2020, you had to take your first RMD by April 1 of the year after you reach the age of 72. For all subsequent years, including the year in which you were paid the first RMD by April 1, you must take the RMD by December 31 of the year. (Source IRS.gov)) 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. Persons Residing Outside of the United States Services for clients living outside the United States may be restricted or limited due to custodial rules or other factors. Investment options and strategies may differ from our typical recommendations, including but not limited to the foreign tax treatment of investment transactions in the United States. In addition, foreign laws or requirements may also impact our ability to service accounts or require additional disclosure as determined on an individual country basis. The client will be responsible for satisfying all legal and tax reporting requirements of the United States and all applicable foreign governments. Any person located outside of the United States who wishes to open an account or an existing client who is located outside of the United States will be subject to the custodian’s policy regarding that country (including their right to decline to open or maintain the account), and all applicable customer identification and anti-money laundering regulations. In its sole discretion, Skybound reserves the right to decline an engagement with any prospective client outside of the United States, or terminate an engagement with an existing client, if they move outside of the United States. Skybound does not participate in wrap-fee programs. Page 8 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157  Item 5 - Fees And Compensation Skybound Wealth Management USA, LLC charges fees for investment advisory services provided to clients. The firm’s advisory fees are separate from and in addition to fees charged by custodians, investment platforms, trustees, third party investment managers, underlying investment funds, and other service providers. The total cost of investing may therefore include several layers of fees depending on the services provided and the structure of the client’s account. Fees may vary depending on the scope and complexity of services, the size of the account, household relationships, and other relevant factors. Any deviation from the firm’s standard fee schedule must be approved in accordance with the firm’s supervisory procedures. Advisory fees and other costs associated with client accounts are described below. Investment Management Fees For clients receiving ongoing investment management services, Skybound generally charges an annual advisory fee based on a percentage of assets under management. This fee compensates Skybound for services that may include portfolio construction, investment selection, monitoring of investments, portfolio rebalancing, ongoing advice, and periodic client reviews. Standard Investment Management Fee Schedule Account Value Annual Advisory Fee Up to $500,000 Up to 1.5 percent $500,000 to $1,000,000 Up to 1.25 percent Above $1,000,000 Up to 1 percent The advisory fee is typically charged quarterly unless otherwise specified in the client agreement.Fees may be negotiated in certain circumstances based on factors such as: • total household assets • complexity of the engagement • scope of services provided • legacy client relationships Any negotiated fee arrangements must be approved internally in accordance with the firm’s supervisory procedures. Financial Planning Fees Skybound may provide financial planning services as a standalone engagement or as part of an ongoing advisory relationship. Financial planning services are separate from the Firm’s investment advisory services and may be provided independently or alongside portfolio management services. Planning services may include retirement planning, investment planning, cross border financial planning, pension planning, estate planning coordination, and cash flow or wealth structuring advice. In certain circumstances, Skybound may assist clients with coordinating estate planning activities, including facilitating access to estate planning platforms or professionals. Skybound does not provide legal advice or draft legal documents. Planning services may be billed in one of the following ways depending on the nature of the engagement. Service Type Fee Structure Comprehensive financial plan Fixed fee Planning engagement Hourly fee Ongoing advisory relationship Monthly retainer The specific fee structure will be agreed with the client before services begin and will be documented in the client agreement. Clients who choose to utilize third party services or platforms in connection with estate planning may incur additional fees payable directly to those service providers. These fees are separate from any fees charged by Skybound. Page 9 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 UK Pension Transfer and Advisory Fees In certain circumstances Skybound may provide advisory services relating to the review and potential transfer of UK pension arrangements. These services may include analysis of an existing pension, preparation of a suitability report, and assistance with the implementation of a recommended strategy. Pension Advisory Fees Service Fee Initial advice and analysis Up to 3 percent of assets transferred Ongoing advisory fee Up to 1.25 percent annually The initial advisory fee is typically payable only if the client proceeds with a recommended transfer or restructuring of pension assets. Ongoing advisory fees apply if the client engages Skybound for ongoing investment management following implementation. Because Skybound receives compensation if a transfer occurs, this creates a financial incentive for the firm to recommend a transfer. This represents a potential conflict of interest. Clients are under no obligation to proceed with a transfer and should carefully consider whether retaining the existing pension arrangement may be more appropriate. Pension transfers are not suitable for every client and clients are encouraged to seek independent advice where appropriate. Third Party Investment Manager Fees In some cases Skybound may recommend that a portion of a client’s portfolio be managed by an independent third party investment manager or implemented through an investment management platform. Where third party managers are used, additional management fees may apply. These fees are separate from and in addition to Skybound’s advisory fee. Typical Third Party Manager Fees Service Provider Typical Fee Range Third party investment managers 0 percent to 1.00 percent annually These fees are charged by the respective provider and are disclosed in the offering documents or client agreements associated with those services. Skybound does not receive compensation from third party investment managers for recommending their services unless otherwise disclosed to the client. Additional Fees and Costs In addition to the advisory fees described above, clients may incur other costs associated with maintaining investment accounts and purchasing investments. These costs may include but are not limited to: Fee Type Description Custodial fees Fees charged by the custodian holding client assets Brokerage commissions Transaction costs associated with buying and selling securities Platform fees Fees charged by investment platforms or trustees Fund management fees Expenses charged by mutual funds, exchange traded funds, or private funds Administrative fees Charges associated with account maintenance These costs are charged by third party providers and are disclosed in the relevant account documentation and investment prospectuses. Page 10 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Fee Calculation Methodology Advisory fees based on assets under management are generally calculated as a percentage of the market value of the assets in the client’s account. The methodology used to calculate advisory fees may vary depending on the custodian or investment platform used for the account. Certain custodians or investment platforms calculate advisory fees on a daily accrual basis, with the fee assessed based on the account value each day during the billing period. In other cases Skybound may be responsible for calculating advisory fees directly. Where Skybound calculates the advisory fee, the fee is generally calculated quarterly based on the market value of the account as of the last business day of the calendar quarter. Market values used for fee calculations are typically based on the account valuation provided by the custodian or investment platform. Certain investments, including private funds or other less liquid investments, may be valued based on information provided by the investment sponsor or administrator. If assets are deposited into or withdrawn from an account during a billing period, advisory fees may be adjusted on a prorated basis depending on the timing and size of the transaction. The exact fee calculation methodology and billing frequency applicable to a client account will be described in the client’s advisory agreement. Billing Practices Advisory fees are generally deducted directly from client accounts held with the custodian or investment platform, provided the client has authorized this arrangement in writing. Where fees are deducted by the custodian or platform, the fee amount is typically calculated based on information provided by Skybound. The custodian or platform will then process the deduction from the client account in accordance with the authorization provided by the client. When fees are deducted from client accounts: • the client receives a statement showing the fee amount • the custodian also provides account statements • clients should review both statements carefully In some cases clients may elect to pay advisory fees directly. Household Accounts and Fee Aggregation In certain cases Skybound may aggregate accounts belonging to members of the same household for purposes of determining advisory fee levels. Householding may include accounts held by spouses, domestic partners, trusts, or other related accounts where the clients have requested that the accounts be treated together for fee purposes. Aggregation of accounts may allow clients to qualify for reduced advisory fee rates based on the combined value of assets managed by the firm. Clients who wish to request household fee aggregation should notify their advisory representative so that the firm can evaluate whether the accounts qualify for aggregation. Skybound reserves the right to determine whether accounts are eligible to be aggregated for fee purposes. Termination and Refunds Clients may terminate their advisory agreement at any time upon written notice in accordance with the terms of the agreement. If an advisory relationship is terminated, fees will be prorated based on the portion of the billing period during which services were provided. Any unearned prepaid fees will be refunded promptly to the client. Conflicts of Interest Related to Fees Certain compensation arrangements may create potential conflicts of interest. These include: • receiving compensation for implementing pension transfers • charging asset based fees that increase as client assets increase • adviser representatives receiving compensation based in part on advisory fees paid by clients Skybound seeks to manage these conflicts through supervisory oversight and by providing clear disclosure so clients can make informed decisions regarding advisory services. Page 11 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 6 - Performance-Based Fees And Side By Side Management Skybound does not charge performance based fees. Accordingly, the firm does not engage in side by side management that would create conflicts associated with performance fee arrangements. Page 12 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 7 - Types Of Clients Skybound primarily provides advisory services to individuals, families, retirees, pension related accounts, trusts, and estates. The firm also works with clients whose circumstances involve cross border planning considerations or assets held across multiple jurisdictions. Page 13 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 8 - Methods Of Analysis, Investment Strategies And Risk Of Loss Skybound Wealth Management USA, LLC provides investment advice using a structured investment governance framework that combines centralized investment research with adviser led portfolio implementation. The firm uses a combination of internally constructed model portfolios and strategies provided by third party investment managers to construct diversified portfolios aligned with each client’s investment objectives, risk tolerance, and time horizon. All investments involve risk, including the possible loss of principal. Clients should understand that investment returns cannot be guaranteed and that market fluctuations may affect the value of investments. Investment Governance Framework Skybound maintains an Investment Committee responsible for overseeing the firm’s investment process and the activities of the Central Investment Operations Team. The Investment Committee provides oversight and challenge to the research, portfolio construction, and manager selection activities undertaken by the Central Investment Operations Team. The composition of the Investment Committee may change from time to time but currently includes: • the Chief Compliance Officer • the Chief Executive Officer and Head of USA • one adviser representative who may rotate periodically • two members of the Central Investment Operations Team The Investment Committee reviews and approves the firm’s portfolio construction methodology and conducts an annual review of that methodology to ensure it remains appropriate in light of market conditions and evolving investment research. The committee also reviews recommendations and analysis prepared by the Central Investment Operations Team and may challenge, amend, or approve proposals relating to portfolio construction, manager selection, or other investment matters. Central Investment Operations Team The Central Investment Operations Team is responsible for the day to day research and portfolio construction activities of the firm. This team is responsible for: • developing and maintaining Skybound’s portfolio construction methodology • constructing and maintaining Skybound model portfolios • conducting investment research and analysis • performing due diligence on third party investment managers • conducting periodic reviews of approved managers and investment strategies The work of the Central Investment Operations Team is subject to oversight and challenge by the Investment Committee. Portfolio Construction Methodology Skybound maintains a formal portfolio construction methodology designed to deliver consistent long term investment outcomes while managing risk appropriately. The methodology seeks to achieve three core objectives: • maximize long term risk adjusted returns • minimize drawdowns and capital erosion during adverse market conditions • align portfolios with each client’s individual risk profile and investment objectives Portfolios are constructed using a dynamic investment framework that considers factors such as economic conditions, valuation levels, liquidity cycles, and cross asset correlations rather than relying on static asset allocation models. The methodology emphasizes transparency, liquidity, and cost efficiency, typically using institutional grade exchange traded funds as core portfolio building blocks while selectively using actively managed funds where they are believed to add value. Risk Profile Framework Skybound portfolios are aligned with defined client risk profiles to ensure that investment strategies remain suitable for the client’s risk tolerance and time horizon. Page 14 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 The firm maintains five primary risk rated portfolio profiles: • Defensive • Cautious • Balanced • Adventurous • Extremely Adventurous Each profile has defined asset allocation ranges across equities, fixed income, diversifying assets, and cash, as well as target volatility ranges designed to ensure portfolios remain aligned with the client’s risk tolerance. Portfolios must remain within the allocation ranges defined in the methodology unless exceptional circumstances are documented and approved. Use of Model Portfolios and Third Party Managers Client portfolios may be implemented using: • Skybound internally constructed model portfolios • model portfolios or strategies provided by third party investment managers • a combination of both approaches As an independent advisory firm, Skybound maintains relationships with a number of third party asset managers and model providers. The selection of particular investment strategies may depend on the suitability of the strategy for the client as well as the investment platform or custodian used by the client, as certain strategies may only be available through specific platforms. In limited circumstances, clients may be allocated to discretionary third party investment managers who assume responsibility for day to day portfolio management. Due Diligence of Third Party Managers Skybound conducts due diligence on third party investment managers before including their strategies within client portfolios. For globally established institutions such as large asset management firms, formal due diligence may be limited given the scale and reputation of those institutions. For other asset managers, Skybound conducts an initial due diligence review and performs ongoing monitoring of both the investment manager and their investment strategies. In addition, all model portfolios and strategies used by the firm are reviewed annually to assess their continued suitability. Strategies that no longer meet the firm’s standards may be removed from approved solutions. Role of Advisers Advisers are responsible for working with clients to implement investment strategies that are appropriate for the client’s individual financial circumstances, investment objectives, and risk tolerance. Advisers may implement portfolios using Skybound model portfolios, third party model portfolios, or a combination of both. Advisers may also blend models or adjust allocations to reflect client specific circumstances. Where advisers deviate from model allocations, the resulting portfolio must remain consistent with the firm’s portfolio construction methodology. Any material deviations must be documented and may be reviewed by the Central Investment Operations Team. Investment Selection Portfolios are constructed using a disciplined investment selection framework. Exchange traded funds are typically used as the core building blocks of portfolios due to their liquidity, transparency, and cost efficiency. Mutual funds may be used selectively where active management is believed to provide demonstrable value in specific markets or asset classes. Investment instruments are evaluated based on factors such as fund size, cost, liquidity, manager quality, and long term performance characteristics. Structured Products and Diversifying Investments Skybound’s portfolio construction methodology categorizes investments into several asset groups, which may include equities, fixed income, and diversifying investments. Diversifying investments may include instruments whose return characteristics differ from traditional asset classes and may provide additional sources of return or portfolio diversification. Page 15 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Structured products may be considered within this category of diversifying investments. These securities are typically issued by financial institutions and derive their returns from the performance of an underlying asset, index, or basket of securities. Structured products may incorporate complex payoff structures and may include features such as income payments, participation rates, caps on returns, or partial downside protection. While these characteristics may provide certain portfolio benefits in specific market environments, they may also introduce additional risks. Risks associated with structured products may include, but are not limited to: • credit risk of the issuing financial institution • limited liquidity or secondary market availability • complexity of payoff structures and investment terms • caps or limits on potential returns • potential loss of principal depending on product structure • market risk associated with the underlying reference asset or index Structured products are typically considered as limited allocations within a diversified portfolio and may not be appropriate for all investors. Clients should review the product documentation and offering materials associated with each structured product before investing. As with all investments, there is no guarantee that any strategy involving structured products will be successful, and investors may experience losses. Portfolio Monitoring and Rebalancing Skybound portfolios follow a long term investment philosophy with a focus on disciplined portfolio management rather than frequent trading. The Central Investment Operations Team reviews portfolio construction and asset allocation positioning on a periodic basis in accordance with the portfolio construction methodology. Neutral allocations within the Skybound models are reviewed centrally and any updates are communicated to advisers for implementation where appropriate. Advisers typically review client portfolios during periodic client meetings and may rebalance portfolios when necessary to ensure they remain aligned with the client’s risk profile. Rebalancing is generally required when allocations move outside the tolerance ranges defined within the portfolio construction methodology. Risk of Loss All investment strategies involve risk and may result in the loss of principal. Market fluctuations, economic events, interest rate changes, and other factors may cause investment values to increase or decrease over time. Clients should understand that past performance is not indicative of future results and that no investment strategy can guarantee profits or protect against losses in all market conditions. Clients should discuss any questions regarding investment risks with their adviser before implementing an investment strategy. Market Risk Either the stock market as a whole or the value of an individual company as a result of moves in the overall market goes down, resulting in a decrease in the value of client investments. This is also referred to as systemic risk. Equity (stock) market risk Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. Company Risk When investing in stock positions, there is always a certain level of company or industry-specific risk inherent in each investment. This is also called unsystematic risk and can be reduced through appropriate diversification. The risk is that the company will perform poorly or decrease its value based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Fixed Income Risk When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk of inflation eroding their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. Page 16 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 ETF and Mutual Fund Risk When we invest in an ETF or mutual fund for a client, the client will bear additional expenses based on its pro rata share of the ETF or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Tax Harvesting Risk One trading strategy employed in client accounts is tax harvesting. This strategy intends to sell an ETF or mutual fund at a taxable loss and replace those positions with a holding whose historical performance and expected future performance are similar, thereby having little impact on the overall strategic allocation but capturing the tax loss. Because past performance is no indication of future performance, there is potential for the future performance of the replacement position to deviate from that of the initial holding. This strategy may also increase the frequency of trading and transaction costs. Management Risk Actively managed client account performance can depend on the investment skills and abilities of the portfolio manager(s) to develop and implement strategies to achieve a mandated objective. The subjectivity of the analysis and implementation can result in the client account incurring losses or missing profitable opportunities that may have otherwise been capitalized. Values-based or Environmental, Social, and Governance Fund (“ESG”) Based Investing Risk. When directed by the client, thematic or ESG-based investments may be included in the client’s portfolio. It is important to note that fund managers consider ESG factors to varying degrees. Not every fund incorporates ESG factors in the same manner or degree, which can cause difficulty comparing different funds. As such, there is no standard matrix or benchmark upon which ESG factors affecting performance can be compared. ESG funds may include or exclude securities based on ESG practices vs. other investment methodologies, impacting performance, fund expenses, and investment risk. We base our ESG recommendations on the information provided to us by the issuers. Foreign Exchange Risk Investments that involve exposure to foreign currencies are subject to foreign exchange risk. Changes in exchange rates between currencies may affect the value of investments and may result in gains or losses independent of the underlying investment performance. Clients with international investments or cross-border financial arrangements may be particularly exposed to currency fluctuations. Movements in exchange rates may reduce investment returns or increase losses. Cybersecurity Risk Skybound Wealth Management USA, LLC (“Skybound”) and the third party service providers it relies upon use technology systems to support business operations, including portfolio management, trading, and client reporting. These systems may be subject to cybersecurity risks, including unauthorized access, data breaches, system disruptions, or other forms of cyber attack. Such events could result in the loss of confidential information, temporary inability to access client accounts or systems, or financial loss. While Skybound and its service providers implement measures designed to protect systems and data, no system is completely secure. As a result, cybersecurity incidents may occur that could adversely affect clients or their accounts. Business Continuity Risk Skybound maintains business continuity and disaster recovery procedures designed to support the continuation of critical business functions in the event of a disruption. Despite these measures, unforeseen events such as system failures, natural disasters, or disruptions affecting third party service providers may impair the Firm’s ability to operate or access systems. Such disruptions could impact the Firm’s ability to service client accounts or execute transactions in a timely manner. Page 17 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 9 - Disciplinary Information Skybound has an obligation to disclose to you any legal or disciplinary events involving Skybound or any of its supervised persons, including your Adviser Representative, which would be material to your evaluation of Skybound and the services it provides. There are no legal or disciplinary events to disclose. Additional disclosure about any disciplinary event involving your Adviser Representative is included in Part 2B of Form ADV. A copy of your Adviser Representative’s Part 2B will be furnished to you at no charge upon request. Page 18 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 10 - Other Financial Industry Activities And Affiliations Skybound Wealth Management USA, LLC (“Skybound” or the “Firm”) is primarily engaged in the provision of investment advisory and financial planning services as described in this brochure. Certain advisory representatives of the Firm may hold licenses that allow them to offer insurance products, including life insurance policies or annuity contracts issued by insurance companies. Where appropriate, such products may be discussed or recommended as part of a client’s broader financial planning strategy. If an advisory representative facilitates the purchase of an insurance product, the representative may receive commissions from the issuing insurance company. These commissions are separate from, and in addition to, the advisory fees paid to Skybound for investment advisory services. The receipt of commissions presents a potential conflict of interest because the representative may have a financial incentive to recommend insurance products. Clients are under no obligation to purchase insurance products through Skybound or through any advisory representative of the Firm. Affiliations with Other Financial Services Firms Skybound Wealth Management USA, LLC (“Skybound”) is part of the broader Skybound group of companies, an international network of affiliated firms that provide financial planning, wealth management, insurance brokerage, and related financial services in various jurisdictions. Certain affiliated entities within the Skybound group provide services that may be complementary to the advisory services offered by Skybound. These services may include financial planning, insurance brokerage, and investment advisory services in other jurisdictions. The following entities are affiliated companies within the Skybound group: Skybound Wealth Management Limited Skybound Wealth Management Limited is a company incorporated in the United Kingdom under company number 4479650 and is authorised and regulated by the Financial Conduct Authority (FCA) under firm reference number 217994. Skybound Wealth Management Limited (Foreign Branch of SWML – UK) Skybound Wealth Management Limited operates a foreign branch in Abu Dhabi, United Arab Emirates. The branch operates under company number 1534907 and holds a Professional Licence number 608018 issued by the UAE Securities and Commodities Authority. Skybound Financial Planning SA Skybound Financial Planning SA is a company organized in Switzerland and is a member of the Association Romande des Intermédiaires Financiers (ARIF), a Swiss self regulatory organization for financial intermediaries and independent asset managers. Skybound Insurance Brokers Ltd Skybound Insurance Brokers Ltd is a company registered in Cyprus under registration number HE 424935 and is authorised by the Insurance Companies Control Service under licence number 6940 to operate as an insurance intermediary. Skybound Insurance Brokerage LLC Skybound Insurance Brokerage LLC is authorised by the Central Bank of the United Arab Emirates and is registered with the UAE Insurance Authority under registration number 251. These affiliated entities operate independently within their respective jurisdictions and regulatory frameworks. While they are part of the broader Skybound group, clients of Skybound Wealth Management USA are not required to use the services of any affiliated company. Where services offered by an affiliated company may be relevant to a client’s financial planning needs, Skybound may introduce the client to the affiliated entity. Clients remain free to engage any service provider of their choosing. Relationships with Third Party Investment Managers As described in Item 4, Skybound may recommend that some or all of a client’s assets be managed by third party investment managers, discretionary portfolio managers, or model portfolio strategists (“Third Party Managers”). These managers may be accessed directly or through investment platforms or custodial arrangements used by the Firm. Where a Third Party Manager is engaged, the manager may assume discretionary authority for the day to day management of the portion of the client’s portfolio allocated to that strategy. Skybound remains responsible for providing overall investment advice to the client and for monitoring the suitability of the selected investment strategy within the context of the client’s broader financial circumstances. Fees charged by Third Party Managers are separate from and in addition to the advisory fees charged by Skybound. Page 19 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 In many cases, Third Party Managers or investment platforms will calculate and deduct advisory fees from the client’s account and remit the portion of the fee attributable to Skybound to the Firm. Further details regarding advisory fees and the calculation of those fees are provided in Item 5 of this brochure. Page 20 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157   Item 11 - Code Of Ethics, Participation Or Interest In Client Transactions And Personal Trading Skybound has a fiduciary duty to you to act in your best interest and to always place your interests ahead of its own. Skybound takes its compliance and legal obligations seriously and requires all persons for which it has supervisory responsibility in connection with its business as an investment adviser to comply with policies and procedures it has adopted under its Code of Ethics. The principal objective of the Code of Ethics is to ensure that neither Skybound nor any of its access persons misuse material non-public information that might have come into their possession or to which they might have become privy in the course of conducting investment advisory activities on behalf of Skybound or the business of the firm. In addition, the policies and procedures in the Code of Ethics are designed to ensure that Skybound advisory personnel and other access persons do not engage in personal securities transactions that would disadvantage and result in material harm to Skybound clients. To accomplish these objectives, the Code of Ethics contains provisions for standards of business conduct in order to comply with federal securities laws, personal securities reporting requirements, pre-approval procedures for certain transactions, code violations reporting requirements, and safeguarding of material non-public information about your transactions. Among other procedures, Skybound maintains a list of all securities holdings for its associated persons and has adopted procedures to supervise the trading activities of associated persons who have knowledge of your transactions and their related family accounts at least quarterly. Further, associated persons are prohibited from trading on non-public information or sharing such information. Page 21 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 12 - Brokerage Practices Skybound Wealth Management USA, LLC (“Skybound” or the “Firm”) generally requires that client investment accounts be maintained with independent third party custodians or investment platforms. These custodians and platforms are responsible for holding client assets, executing securities transactions, and providing account administration and reporting. Skybound does not take custody of client assets. Primary Custodian For most client brokerage accounts, Skybound recommends Charles Schwab & Co., Inc. (“Schwab”) as the primary custodian. Schwab provides custody, trade execution, settlement, and account administration services for client investment accounts. Schwab also provides access to a broad range of investment products including exchange traded funds, mutual funds, equities, fixed income securities, and other investment instruments. Schwab is frequently used for both U.S. resident clients and many U.S. connected individuals residing outside the United States, as Schwab is able to support accounts for clients residing in a wide range of jurisdictions. Alternative Custodian In certain circumstances, Skybound may recommend Interactive Brokers LLC (“IBKR”) as a custodian. Interactive Brokers may be used where client investment needs require additional capabilities, such as the ability to hold and transact in multiple currencies or access certain international markets. These features may be relevant for clients with multi currency investment requirements or cross border financial arrangements. The use of Interactive Brokers is generally limited to specific situations where these additional capabilities are necessary. Pension Platforms Certain client assets, particularly UK pension arrangements, may be administered through pension platforms rather than through U.S. brokerage custodians. In these situations, Skybound may utilize platforms such as the Morningstar Wealth Platform, which provides administration and investment access for pension arrangements typically administered in jurisdictions such as the Channel Islands. These platforms facilitate investment access and provide administrative services for pension accounts but do not act as custodians in the same manner as U.S. broker dealers. Custody of pension assets is typically maintained by the trustee of the pension arrangement. Broker Selection Skybound seeks to recommend custodians and brokerage arrangements that it believes provide clients with reliable execution, access to appropriate investment products, financial stability, and quality client service. In evaluating custodians and brokerage providers, the Firm may consider factors including: • execution capability and reliability • available investment products and services • financial stability of the provider • operational infrastructure and reporting capabilities • client service and technology platforms While the Firm seeks to obtain favorable execution for client transactions, the Firm does not necessarily select the broker dealer offering the lowest possible transaction cost. The overall value of brokerage and custodial services provided may be considered when selecting a broker dealer. Best Execution Skybound has a duty to seek best execution for client transactions. In fulfilling this duty, the Firm seeks to execute securities transactions in a manner that the Firm reasonably believes will result in the best overall outcome for clients under the circumstances. In evaluating execution quality, the Firm may consider factors such as: • execution price • transaction costs • speed and likelihood of execution • financial stability of the broker dealer • access to trading markets and liquidity The Firm periodically reviews its brokerage arrangements to evaluate whether the custodians and brokerage firms used continue to provide quality execution and services to clients. Page 22 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Soft Dollar Benefits Custodians such as Charles Schwab may provide certain services, technology tools, research, or operational support to Skybound that assist the Firm in managing client accounts. These services may include items such as: • portfolio management and trading software • research and market data • compliance and reporting tools • operational support systems • educational or practice management resources These services are typically provided without additional cost to the Firm and are made available as part of the custodial relationship. Economic Benefits from Custodians Skybound may receive certain economic benefits from custodians such as Charles Schwab in connection with maintaining client accounts at those custodians. These benefits may include access to technology platforms, trading systems, research, operational support tools, and other services that assist the Firm in managing client accounts. These services are typically provided without direct cost to the Firm and are made available as part of the custodial relationship. The receipt of these benefits creates a potential conflict of interest because the Firm may have an incentive to recommend a custodian that provides such services. Skybound seeks to mitigate this conflict by recommending custodians based primarily on the quality of services provided to clients. Directed Brokerage Clients may request that their assets be maintained with a specific custodian or brokerage firm. In these cases, Skybound may be limited in its ability to obtain the best available execution or to aggregate transactions with other client accounts. Clients who direct the Firm to use a specific broker dealer should understand that brokerage commissions and transaction costs may differ from those available through the Firm’s preferred custodial relationships. Trade Aggregation Skybound may aggregate trades across multiple client accounts when purchasing or selling the same securities. Trade aggregation may allow the Firm to seek more efficient execution and may reduce transaction costs. When trades are aggregated, transactions will generally be allocated among participating client accounts in a manner that the Firm believes is fair and equitable. Page 23 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 13 - Review Of Accounts Accounts receiving investment management services are reviewed to ensure that the portfolio remains aligned with the client’s investment objectives, risk tolerance, financial circumstances, and overall financial plan. Client portfolios are reviewed by the client’s Advisory Representative at least annually, and more frequently when required based on client circumstances, portfolio changes, or client requests. These reviews are typically conducted in connection with client meetings or advisory engagements. In addition to adviser level reviews, Skybound maintains a centralized investment governance structure. Model portfolios and investment strategies used by the Firm are reviewed at least semi annually by the Central Investment Operations Team and overseen by the Investment Committee. These reviews assess the continued suitability of portfolio construction methodology, asset allocation frameworks, and third party investment managers used within client portfolios. Account reviews may also occur when specific events arise, including: • changes in a client’s financial circumstances, investment objectives, or risk tolerance • significant market developments or economic events • material changes to investment managers or investment strategies • portfolio allocations moving outside established asset allocation ranges • client requests for additional review Clients are encouraged to notify their Advisory Representative promptly of any changes to their financial situation, investment objectives, time horizon, or liquidity needs, as such changes may require a review of portfolio allocations and potential adjustments. Clients receiving ongoing investment management services or financial planning services will generally be invited to participate in review meetings with their Advisory Representative at least annually, although meetings may occur more frequently depending on the scope of services and client needs. Clients receiving stand alone financial planning or consulting services will not typically receive ongoing reviews unless this has been specifically agreed as part of the engagement. Skybound recommends that financial plans be revisited periodically to ensure that the assumptions and recommendations remain appropriate over time. Clients receive account statements directly from the qualified custodian or investment platform that maintains custody of their assets. For U.S. brokerage accounts, including those held with Charles Schwab or Interactive Brokers, account statements are generally provided at least quarterly, together with confirmations for transactions executed in the account. For certain pension arrangements, including UK pension assets held on investment platforms, clients generally receive valuations directly from the platform provider at least annually, with additional access to account information available through online platform access or upon request. Clients should carefully review the statements provided by their custodian or platform and compare them with any reports provided by the Firm. The custodian’s statements should be considered the official record of account holdings and transactions. Page 24 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 14 - Client Referrals And Other Compensation We receive an economic benefit from Schwab and Interactive Brokers (IB) in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab and IB. Additionally, we receive similar support products and services from some of the third-party managers we utilize. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). The Advisory Representatives have a direct incentive in the advisory fees being charged since a portion of the advisory fee collected by Skybound will be paid to the Advisory Representative for compensation for advisory services. In other words, Advisory Representatives share in the fees charged to you by the firm. Wealth.com Platform Skybound may recommend Wealth.com as a technology platform that facilitates the preparation and administration of estate planning documents. Skybound pays a licensing fee to access the Wealth.com platform. Skybound does not receive compensation from Wealth.com for referring clients to the platform. Clients who choose to use Wealth.com enter into a separate agreement directly with the platform and any legal professionals engaged through it. Clients are not required to use Wealth.com and are free to work with any estate planning professional or service provider of their choosing. Skybound Wealth Management USA, LLC (“Skybound”) is part of a broader group of affiliated companies operating under the Skybound brand in various jurisdictions. From time to time, affiliated entities within the Skybound group may refer clients to Skybound for investment advisory and financial planning services. In certain cases, Skybound may enter into referral or revenue sharing arrangements with these affiliated entities. Compensation may be paid in the form of a portion of advisory fees or other economic benefits. This arrangement creates a conflict of interest, as the referring entity has a financial incentive to recommend Skybound’s services. Skybound addresses this conflict by ensuring that any such referral arrangements are disclosed to the client at or prior to the time of engagement. Clients are not obligated to engage Skybound and are free to select any adviser or service provider of their choosing. Skybound may share client information with third party service providers to facilitate services, subject to applicable privacy and data protection policies. Page 25 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 15 - Custody In the United States, Skybound uses unaffiliated banks and/or registered broker-dealers to hold client assets. Each custodian is a qualified custodian within the meaning of Rule 206(4)-2 under the Investment Advisers Act. Although the firm does not maintain custody of funds and securities held in a client’s account, Skybound is deemed to have custody when it has the authority to deduct investment advisory fees directly from a client’s account and when it has the authority to transfer funds or securities between a client’s accounts pursuant to standing letters of authorization provided by this client. Clients receive quarterly account statements directly from the qualified custodian for the accounts. Each client is advised to carefully review these statements and compare them with statements received from Skybound to ensure that there are no material discrepancies in the information provided. Skybound believes that the safety of U.K. pension assets is one of the paramount considerations in selecting an adviser for your UK pension transfers and subsequent management. Skybound does not take custody of any client assets and utilizes the services of non-US financial institutions to safe-keep your assets and to provide administrative services for your account. Each financial institution serving as custodian is a qualified custodian within the meaning of Rule 206(4)-2 under the Investment Advisers Act. A financial institution acting as custodian or administrator charges separate fees to provide these services to you. Page 26 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 16 - Investment Discretion Based on your advisory agreement you may opt for your account to be managed on a discretionary basis. Discretionary authority authorizes Skybound and your Advisory Representative the authority to buy, sell, exchange and convert securities in your managed accounts and to engage, terminate, or replace Third-Party Service Providers. You will grant such authority by execution of the client advisory agreement. You may terminate discretionary authorization at any time upon receipt of written notice by Skybound. Discretionary authority will be limited to Skybound and your Advisory Representative having the authority to determine the securities to be bought or sold for a client’s account, the amount of securities to be bought or sold for a client’s account, and the Third-Party Service Providers on your account. Additionally, you are advised that: You may set parameters with respect to when accounts should be rebalanced and set trading restrictions or limitations; Your written consent is required to establish any brokerage account; With the exception of deduction of Skybound’s advisory fees from the account, if you have authorized automatic deductions, the firm will not have the ability to withdraw your funds or securities from the account. Skybound will not have authority to remove or transfer funds or assets out of your account without your authorization with the exception of deduction of advisory fees from your account. Page 27 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 17 - Voting Client Securities Skybound does not have, and will not accept, authority to vote the securities held in your account. The custodian for your account sends proxies or other solicitations for the voting of securities held in your account directly to you. If a proxy or other solicitation is sent directly to Skybound, it is the firms policy to promptly remit this proxy or other solicitation to you. Although you may contact your Adviser Representative about questions you may have about the voting of securities held in your account, the decision about how to vote any proxy rests solely with you. Page 28 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157 Item 18 - Financial Information Skybound does not require any client to prepay more than $1,200, six months or more in advance of receiving the investment advisory services to be provided to this client. Skybound does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Skybound has not been the subject of a bankruptcy petition in the past ten years or at any time in its operating history. Page 29 of 29 Copyright © 2023. Skybound Wealth Management USA, LLC dba Skybound Wealth USA All rights reserved. March 27 2026 Version 1.12Skybound Wealth Management USA, LLC dba Skybound Wealth USA is registered with the SEC: CRD 313358. SEC No. 801-121157