SWISS USADVISORS LTD.

Swiss USAdvisors Ltd. Fraumünsterstr. 13 8001 Zurich Switzerland Phone: + 41 44 533 07 10 www.swissusadvisors.com Form ADV Part 2A – Firm Disclosure Brochure Effective: May 20, 2025 I. Cover Page This Form ADV Part 2A/Brochure provides information about the qualifications and business practices of Swiss USAdvisors Ltd. (“Swiss USAdvisors”). Swiss USAdvisors is registered as an investment adviser with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). If you have any questions about the contents of this brochure, please contact us by telephone at +41 58 533 0710 or by e- mail at info@swissusadvisors.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Swiss USAdvisors is also available on the SEC’s website at www.adviserinfo.sec.gov. The information contained in this brochure relates only to specific questions to which the relevant agencies request answers. This document is not, and is not intended to be, a marketing brochure, nor is it to provide detailed information about all aspects of Swiss USAdvisors’ business. There is no specific level of skill or training required to become a registered investment adviser with the SEC. Swiss USAdvisors requires its employees to have a high level of experience and education as described in more detail below. This Brochure provides information for U.S. clients of Swiss USAdvisors; most provisions of the Advisers Act and of this Brochure do not apply to Swiss USAdvisors’s non-U.S. clients. This Brochure has been prepared as of September 1, 2011 and last updated as of May 20, 2025. II. Material Changes In this Brochure, we are reporting no material changes.  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 Table of Contents III. I. Cover Page ............................................................................................................................................ 1 II. Material Changes .................................................................................................................................. 1 III. Table of Contents .................................................................................................................................. 2 IV. Advisory Business .................................................................................................................................. 3 Discretionary Asset Management Services ................................................................................................................. 3 Non-Discretionary (i.e., Advisory) Asset Management Services ......................................................................... 3 V. Fees and Compensation ........................................................................................................................ 4 VI. Performance Based Fees and Side-by-Side Management .................................................................... 5 Performance Based Fee Scheme ..................................................................................................................................... 5 Side-by-Side Management ................................................................................................................................................ 6 VII. Types of Clients ..................................................................................................................................... 6 VIII. Methods of Analysis, Investment Strategies and Risk of Loss .............................................................. 6 Methods of Analysis ............................................................................................................................................................. 6 Material Investment Risks ................................................................................................................................................ 7 IX. Disciplinary Information ........................................................................................................................ 9 X. Other Financial Industry Activities and Affiliations ............................................................................... 9 XI. Code of Ethics, Participation in Client Transactions and Personal Trading ........................................ 10 Code of Ethics ...................................................................................................................................................................... 10 Participation or Interest in Client Transactions .................................................................................................... 11 XII. Brokerage Practices ............................................................................................................................ 11 Use of Soft Dollars .............................................................................................................................................................. 12 Trade Errors ........................................................................................................................................................................ 13 XIII. Review of Accounts ............................................................................................................................. 13 XIV. Client Referrals and Other Compensation .......................................................................................... 13 XV. Custody ............................................................................................................................................... 14 XVI. Investment Discretion ......................................................................................................................... 15 XVII. Voting Client Securities ....................................................................................................................... 15 XVIII. Financial Information .................................................................................................................. 15 2 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 IV. Advisory Business Swiss USAdvisors Ltd. (“Swiss USAdvisors”), a Swiss corporation based in Zurich, Switzerland, provides investment advisory services to clients with connections to the United States (“U.S.”). Swiss USAdvisors was formed in 2011. The principal owner of Swiss USAdvisors is Roland Hansalik. Swiss USAdvisors provides investment supervisory services primarily for individuals, trusts, foundations and companies. The services provided include the provision of discretionary portfolio management and continuous advice concerning investment of assets consistent with the circumstances, preferences and objectives of each client. Investment supervisory services are provided based on the individual needs and investment objectives of each client as communicated to Swiss USAdvisors. Specifically, the structure for each client’s investment program is created in the context of certain considerations such as expected returns, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Discretionary Asset Management Services Under a discretionary management mandate, Swiss USAdvisors has the authority to supervise and direct the investments of and for each client’s account generally in line with the investment profile agreed with the client and without prior consultation with the client. Swiss USAdvisors determines which securities are bought and sold for the account and the total amount of the purchases and sales. Swiss USAdvisors’s authority may be subject to special conditions imposed by individual clients. For example, a client may restrict or prohibit transactions in certain types of securities. Swiss USAdvisors does not select the broker or dealer for effectuating securities transactions and does not negotiate the commission rates paid to effectuate transactions. Swiss USAdvisors works with the broker determined by the custodian bank selected by the client, which may or may not be a broker registered with the U.S. Securities and Exchange Commission (the “SEC”). Please refer to the discussion of brokerage practices below. Non-Discretionary (i.e., Advisory) Asset Management Services Under a non-discretionary management mandate, Swiss USAdvisors makes investment recommendations to a client, and the client subsequently makes all investment decisions about the investments held in the account. In order to implement the client’s decisions, the client may authorize Swiss USAdvisors to place orders for the execution of securities transactions for the client’s account. In such cases, Swiss USAdvisors does not select the broker or dealer used for effectuating such securities transactions and does not negotiate the commission rates paid. Swiss USAdvisors will place orders with the custodian bank or broker directed by the client. Swiss USAdvisors does not issue periodic publications, nor does Swiss USAdvisors prepare for distribution special reports or analysis relating to securities. Generally, Swiss USAdvisors does 3 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 not issue any charts, graphs, formulas or other devices for use by clients in evaluating individual securities, nor does Swiss USAdvisors furnish advice to clients on any matters not involving securities other than on an incidental basis. Related to its primary function as an asset manager, Swiss USAdvisors offers clients certain broad guidance commonly considered as financial planning. Swiss USAdvisors will not advise or act on behalf of clients in any legal proceeding, including bankruptcies or securities shareholder class action litigation involving securities held or previously held in client accounts. Accordingly, Swiss USAdvisors is not responsible for responding to, or forwarding to clients, any class action settlement offers relating to securities currently or previously held in the client account. V. Fees and Compensation For its discretionary asset management service and nondiscretionary asset management service, Swiss USAdvisors charges a fee for its services based on a percentage of the market value of assets under management. For its active trading based managed account strategy service, Swiss USAdvisors charges a fee with both a fixed and performance component as detailed below. Particularly in the context of clients selecting the active trading based managed account strategy, the fees charged by Swiss USAdvisors may be higher than the fees normally charged by other investment advisors offering similar investment management services. Fees charged by Swiss USAdvisors do not include custodian fees, fees for trade settlement, brokerage commissions, or any other fee imposed by the custodian bank or the broker. Swiss USAdvisors also advises clients on foreign currencies and the above fee schedule applies and is negotiable to such advice. Compensation is not payable in advance. Swiss USAdvisors may waive, discount and/or negotiate fees at its discretion. Swiss USAdvisors may also charge additional fees for services outside the scope of the services described above. Any additional fees are disclosed to the client. Swiss USAdvisors relies on custodian banks of its clients to value the assets in the respective client accounts, and Swiss USAdvisors computes its investment advisory fees based on these valuations provided by the custodian. At the end of the quarter Swiss USAdvisors arranges with the custodian for the direct payment of its fee from the respective client accounts. The client’s statement from the custodian will reflect all amounts disbursed from the account, including the amount of any advisory fee paid to Swiss USAdvisors. Swiss USAdvisors does not manage or advise accounts based on commissions, subscriptions fees, or hourly rate charges. 4 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 The fixed asset management fee for discretionary and nondiscretionary asset management services is charged quarterly in arrears and is calculated on the basis of the value of the assets under management at the last business day of the respective calendar quarter. The fee schedule below for discretionary asset management shows the applicable fee for each bracket of assets under management. To USD 3 Million 5 Million 10 Million From USD 1 Million 3 Million 5 Million Over 10 Million Fee 1.5% p.a. 1.25% p.a. 1.00% p.a. Negotiable There is a minimum annual fee of USD 15,000. Swiss USAdvisors offers certain clients the option of paying a lower base fee and a performance fee. This alternative compensation model is offered only in accordance with Rule 205-3 under the Advisers Act, to clients who meet the following requirements: (i) clients with at least $750,000 under management with Swiss USAdvisors; (ii) clients with more than $1,500,000 of net worth; or (ii) clients who are qualified purchasers under Section 2(a)(51) of the Investment Company Act of 1940, as amended (which generally is defined to include only individuals, companies or trusts with more than $5,000,000 in investments). Under this alternative compensation model, a base fee of 1% per annum is charged in lieu of the normal fee schedule and in addition, Swiss USAdvisors will receive a performance fee of 10%. The performance fee is payable on net performance of the managed account, which for these purposes is calculated by taking the gross performance (i.e., realized and unrealized capital gains, dividends and interest) and subtracting from that amount the flat base fee. The performance fee is not payable on recouperated losses in the value of the managed account on a quarter-by-quarter (i.e., the fee is subject to a high water mark). The flat base fee is charged quarterly in arrears and is calculated on the basis of the value of the assets under management at the last business day of the respective calendar quarter. The performance fee component is calculated and charged if applicable quarterly. For accounts opened during a calendar year, the flat base fee and the hurdle rate is adjusted on a pro rata basis. VI. Performance Based Fees and Side-by-Side Management Performance Based Fee Scheme See the discussion in Section V for a description of the performance fees charged by Swiss USAdvisors. 5 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 Side-by-Side Management Conflicts related to side-by-side management of different accounts may exist. For example, Swiss USAdvisors may manage more than one account according to the same or a substantially similar investment strategy. Side-by-side management of different types of accounts may raise conflicts of interest when two or more accounts invest in the same securities or pursue a similar strategy. These potential conflicts include the favorable or preferential treatment of an account or a group of accounts, conflicts related to the allocation of investment opportunities, particularly with respect to securities that have limited availability, such as initial public offerings, and transactions in one account that closely follow related transactions in a different account. In addition, the results of the investment activities for one account may differ significantly from the results achieved for other accounts, particularly as a result of Swiss USAdvisors’s practice to individually tailor each client’s investment portfolio. Swiss USAdvisors has policies and procedures in place aiming to ensure that all client accounts are treated fairly and equitably. Swiss USAdvisors strives to equitably allocate investment opportunities among relevant accounts over time. In addition, investment decisions for each account are made with specific reference to the individual needs and objectives of the account. Accordingly, Swiss USAdvisors may give advice or exercise investment responsibility or take other actions for some clients (including related persons) that may differ from the advice given, or the timing and nature of actions taken, for other clients. Investment results for different accounts, including accounts that are generally managed in a similar style, also may differ as a result of these considerations. Some clients may not participate at all in some investments in which other clients participate, or may participate to a different degree or at a different time. VII. Types of Clients Swiss USAdvisors offers investment management services to individuals, trusts, estates, corporations and other business entities or foundations. Generally, Swiss USAdvisors prefers its client relationships to have a minimum of $1 million of assets under management. Swiss USAdvisors may accept accounts below the minimum requirements, or may retain accounts that have dropped below the minimum requirement due to market fluctuation or investment performance. Accounts that have family, corporate or other relationships may be aggregated for purposes of the minimum account size. VIII. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Swiss USAdvisors uses a combination of a top-down, bottom-up approach to its investment approach. First, Swiss USAdvisors generates portfolio allocations based on the Client’s 6 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 investment profile supplemented by Swiss USAdvisors’ macro-economic views. Macro- economic trends along with cyclical and trending analysis of sectors, markets, industries, and asset classes then inform the portfolio selection. In selecting specific securities, Swiss USAdvisors then employs a bottom-up approach evaluating the fundamentals of the specific investment, comparisons to benchmarks and to similar securities, and timing. Thus, in sum, Swiss USAdvisors takes both long and short positions in securities based on their fundamentals, market conditions, cyclical indications, and timing all within the broader macroeconomic context of the particular industry, sector, market, credit and interest rate environment. Swiss USAdvisors views itself as a value investor when selecting individual securities. However, what makes Swiss USAdvisors’ approach unique is the global investment approach and the active currency overlay. Currency overlay refers to the management of currency exposure of the underlying investments. This risk is managed separately from the underlying assets. We actively manage this risk which enables the investor to reduce risk and add return to an international portfolio (alpha). Swiss USAdvisors offers investment management and advisory services on the following types of securities and transactions: exchange-listed securities, securities traded over-the-counter, foreign issuers, options, corporate debt securities (and other commercial paper), certificates of deposit, investment company securities such as mutual funds, exchange traded funds, foreign exchange transactions, and futures contracts on intangibles. Swiss USAdvisors will also invest in hedge funds or other private funds on a limited basis. Investments in private funds are available to “accredited investors” or “qualified purchasers,” and they typically require investors to lock-up their assets for a period of time. These investments may have limited or no liquidity and they may involve different risks than investing in registered funds and other publicly offered and traded securities. Swiss USAdvisors relies on the valuation and performance data provided directly from the private funds. Private funds may often be delayed in providing Swiss USAdvisors with the valuation information; therefore, Swiss USAdvisors may likewise be delayed in reporting this information to the client. Swiss USAdvisors will rely on the accuracy of a client’s representations in making corresponding representations regarding the investment restrictions on behalf of the client’s account in connection with certain derivative and other transactions. Swiss USAdvisors also requires notification by the client if the client’s representations become inaccurate. In certain cases Swiss USAdvisors may provide asset allocation recommendations that may include real estate holdings. These holdings are acquired through real estate investment trusts (REITs). Swiss USAdvisors does not invest in real properties. Material Investment Risks Clients should bear in mind that investing in securities involves a risk of loss. Among other risks, investments will be subject to market risk, liquidity risk, credit and counterparty risk, interest 7 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 rate risk, risk in fluctuations of commodity pricing, risk of loss due to political and economic developments in foreign markets, and risks involving movements in the currency markets. Clients should be prepared to bear the risk of losing their investment in securities. Past performance is not an indication as to future results. Certain investments have the following risks, particularly in the context of investments in derivatives or structured products: Leverage: A derivative instrument or transaction may have the effect of disproportionately increasing an account’s exposure to the market for the securities or other assets underlying the derivative position and the sensitivity of an account’s portfolio to changes in market prices for those assets. Leverage will tend to magnify both the positive impact of successful investment decisions and the negative impact of unsuccessful investment decisions by Swiss USAdvisors on an account’s performance. Counterparty Credit Risk: An account’s ability to profit from a derivative contract depends on the ability and willingness of the other party to the contract (a “Counterparty”) to perform its obligations under the contract. Although exchange-traded futures and options contracts are generally backed by a guarantee from a clearing corporation, an account could lose the benefit of a contract in the unlikely event that the clearing corporation becomes insolvent. A Counterparty’s obligations under a forward contract, over-the-counter option, swap or other over-the-counter derivative contract are not so guaranteed. If the Counterparty to an over-the- counter contract fails to perform its obligations, an account may lose the benefit of the contract and may have difficulty reclaiming any collateral that an account may have deposited with the counterparty. Lack of Correlation: The market value of a derivative position may correlate imperfectly with the market price of the asset underlying the derivative position. To the extent that a derivative position is being used to hedge against changes in the value of assets in an account, a lack of price correlation between the derivative position and the hedged asset may result in an incomplete hedge. Illiquidity: Over-the-counter derivative contracts are usually subject to restrictions on transfer, and there is generally no liquid market for these contracts. Although it is often possible to negotiate the termination of an over-the-counter contract or enter into an offsetting contract, a Counterparty may be unable or unwilling to terminate a contract with an account, especially during times of market instability or disruption. The markets for many exchange traded futures, options and other instruments are quite liquid during normal market conditions, but this liquidity may disappear during times of market instability or disruption. Less Accurate Valuation: The absence of a liquid market for over-the-counter derivatives increases the likelihood that Swiss USAdvisors will not be able to correctly value these interests. 8 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 Futures: Futures markets are highly volatile and are influenced by factors such as changing supply and demand relationships, governmental programs and policies, national and international political and economic events and changes in interest rates. Because of the low margin deposits normally required in futures trading, a high degree of leverage is typical of a futures trading account, and a relatively small price movement in a futures contract may result in substantial losses to the trader. Futures positions are marked to the market each day and variation margin payments must be paid to or by Swiss USAdvisors. Futures trading may also be illiquid, and certain exchanges do not permit trading in particular contracts at prices that represent a fluctuation in price during a single day’s trading beyond certain set limits. Should prices fluctuate during a single day’s trading beyond those limits, which conditions might last for several days with respect to certain contracts, Swiss USAdvisors could be prevented from promptly liquidating unfavorable positions and thus be subjected to substantial losses. Currency Exposure: Swiss USAdvisors invests in securities and other investments that are denominated in currencies other than U.S. Dollars. Accordingly, the value of such assets may be affected favorably or unfavorably by fluctuations in currency rates. Swiss USAdvisors seeks to hedge the foreign currency exposure but such hedging strategies may not necessarily be available or effective and may not always be employed. Accounts managed by Swiss USAdvisors are routinely subject to foreign exchange risks and bear a potential risk of loss arising from fluctuations in value between the U.S. Dollar and such other currencies. IX. Disciplinary Information Swiss USAdvisors has not been involved in any legal or disciplinary events. X. Other Financial Industry Activities and Affiliations Swiss USAdvisors and its management personnel are neither registered nor have an application pending to register as, broker-dealers, registered representatives of a broker-dealer, future commissions merchants, commodity pool operators, commodity trading advisors, or associated persons of the foregoing entities. Swiss USAdvisors is a member of Aquila & Ltd., which oversees its compliance with Swiss rules relating to anti-money laundering. Aquila & Ltd. is regulated by the Swiss Financial Market Supervisory Authority (FINMA). Swiss USAdvisors is also licensed by FINMA. Swiss USAdvisors’ principal owner also is the principal owner of Aquila Himco AG, a Swiss based investment adviser that is not registered with the SEC. Aquila Himco AG provides services to clients without a U.S. connection. Swiss USAdvisors does not believe the relationship with Aquila Himco AG creates a conflict of interest. 9 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 XI. Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Swiss USAdvisors has adopted a Code of Ethics (the “Code”) and attendant policies and procedures governing personal securities transactions by Swiss USAdvisors and its personnel. The Code also provides guidance and instruction to Swiss USAdvisors and its personnel on their ethical obligations in fulfilling its duties of loyalty, fairness and good faith towards the clients. The overriding principle of Swiss USAdvisors’s Code of Ethics is that all employees of Swiss USAdvisors owe a fiduciary duty to clients for whom Swiss USAdvisors acts as investment adviser or sub-adviser. Accordingly, employees of Swiss USAdvisors are responsible for conducting personal trading activities in a manner that does not interfere with a client’s portfolio transactions or take improper advantage of a relationship with any client. The Code contains provisions designed to try to: (i) prevent, among other things, improper trading by Swiss USAdvisors’s employees; (ii) identify conflicts of interest; and (iii) provide a means to resolve any actual or potential conflicts of interest in favor of the clients. The Code attempts to accomplish these objectives by, among other things, (i) requiring pre-clearance of specific trades, which includes documenting any exceptions to such pre-clearance requirement; (ii) restricting trading in certain securities that may cause a conflict of interest, as well as (iii) periodic reporting regarding transactions and holdings of employees. The Code contains sections including, but not limited to, the following key areas: (i) restrictions on personal investing activities; (ii) gifts and business entertainment; and (iii) outside business activities. The Code also provides for the Swiss USAdvisors’s execution of supervisory policies and procedures, and the review and enforcement processes of such policies and procedures. Swiss USAdvisors has designated a Chief Compliance Officer responsible for maintaining, reviewing and enforcing Swiss USAdvisors’s Code of Ethics and corresponding policies and procedures. The fundamental position of Swiss USAdvisors is that, in effecting personal securities transactions, personnel of Swiss USAdvisors must place at all times the interests of clients ahead of their own pecuniary interests. All personal securities transactions by these persons must be conducted in accordance with the Code of Ethics and in a manner to avoid any actual or potential conflict of interest or any abuse of any person’s position of trust and responsibility. Further, these persons should not take inappropriate advantage of their positions with or on behalf of a client. 10 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 Swiss USAdvisors will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions Swiss USAdvisors regularly personnel invest alongside the firm’s clients, both to align the interest of firm and personnel and firm clients and as an expression of confidence in our portfolio management efforts. In order to ensure that Swiss USAdvisors personnel never trade ahead of their clients, the firm generally tries to ensure that all trading in specific positions for officer and employee accounts to come after the analogous trades are executed for client accounts. XII. Brokerage Practices Swiss USAdvisors does not have custody or possession of client assets; each of Swiss USAdvisors’s clients maintains custody of its assets at one or more custodians (usually Swiss based banks). Each custodian bank acts as a broker-dealer itself and/or maintains relationships with designated broker-dealers (including potentially an affiliate of the custodian bank). Swiss USAdvisors effectuates security transactions through the custodian or the broker or dealer designated by the custodian bank selected by the client. Swiss USAdvisors does not guarantee best execution or the best commissions because Swiss USAdvisors does not control these factors. Swiss USAdvisors operates exclusively on this directed brokerage basis whereby the client and/or the client’s choice of custodian bank selects the broker-dealer to be used for securities transactions. Therefore, clients should be aware of the following:  Swiss USAdvisors does not negotiate commission rates with broker-dealers with whom orders are placed either directly or via the custodian bank because the broker-dealer is determined by the custodian bank and/or the client. The applicable commissions and fees charged for securities transactions are agreed upon between the client and the custodian bank when the client accepts the applicable commission schedule published by the custodian bank or otherwise agrees.  Commission charges will vary among clients and best execution may not be guaranteed by Swiss USAdvisors. Because the client selects the custodian and thereby the broker-dealer to be used for securities transactions involving its account, different clients may have accounts at the same custodian bank or a single client may have multiple accounts at different custodian banks. Therefore, a client may pay an executing broker a higher commission for a securities transaction than might be charged by another broker-dealer executing the same transaction or than the commission charged by the broker-dealer executing a similar transaction for another client of Swiss USAdvisors. Commission charges may also vary between clients. It also is possible that the 11 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 broker-dealer used for transactions may not be a registered broker-dealer under the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”). In making the decision as to which securities are to be purchased or sold and the amounts thereof, Swiss USAdvisors is guided by the general guidelines set up at the inception of the adviser-client relationship in cooperation with the client and a periodic review of the asset allocation. These general guidelines cover such matters as the relative proportion of debt and equity securities to be held in the portfolio, the degree of risk which the client wishes to assume and the types and amounts of securities to be held in the portfolio. Swiss USAdvisors’s authority may be further limited by specific instructions from the client which may restrict or prohibit transactions in certain securities. Swiss USAdvisors may manage numerous accounts with similar or identical investment objectives or may manage accounts with different objectives that may trade in the same securities. Despite such similarities, portfolio decisions relating to client investments and the performance resulting from such decisions may differ from client to client. Swiss USAdvisors will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible clients, particularly if different clients have selected different investment profiles, have materially different amounts of capital under management with Swiss USAdvisors or different amounts of investable cash available. In certain instances such as purchases of less liquid publicly traded securities (as some small cap securities frequently are) or oversubscribed public offerings, it may not be possible or feasible to allocate a transaction pro rata to all eligible clients, especially if clients have materially different sized portfolios. Therefore, not all clients will necessarily participate in the same investment opportunities or participate on the same basis. Use of Soft Dollars Swiss USAdvisors may maintain soft dollar arrangements, and to the extent it does it will only do so in accordance with the conditions of the safe harbor provided by Section 28(e) of the Exchange Act. Section 28(e) is a “safe harbor” that permits an investment manager to use brokerage commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data, certain valuation and pricing data and economic data); and advice from brokers on order execution. 12 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 instructions; routing settlement Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of instructions; post trade matching of trade allocation information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. Trade Errors Although the Swiss USAdvisors’s goal is to execute trades seamlessly in the manner intended by the client and consistent with its investment decisions, Swiss USAdvisors recognizes that errors can occur for a variety of reasons. Swiss USAdvisors’s policy in dealing with such errors is to: Identify any errors in a timely manner.   Correct all errors so that any affected account is placed in the same position it would  have been in had the error not occurred. Incur all costs associated with correcting an error (or to pass the costs on to the broker, depending on which party is at fault). Costs from corrective actions are not to be passed on to a client.  Evaluate how the error occurred and assess if any changes in any processes are warranted or if any continuing education is required. The consequences and the required corrective measures may be different depending upon the nature of the error or the account affected. XIII. Review of Accounts All managed accounts are reviewed at least quarterly in an effort to ensure that they remain aligned with the client’s investment plan and are positioned appropriately given current market conditions as part of Swiss USAdvisors’s general investment process. XIV. Client Referrals and Other Compensation Swiss USAdvisors may pay fees for client referrals. Such arrangements comply with the conditions and requirements of Rule 206(4)-3 under the Investment Advisers Act of 1940. Swiss USAdvisors may receive remuneration from third parties in connection with its investment advisory services. Such remuneration can include referral fees, marketing fees, discounts, 13 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 finder’s fees, service fees, including shareholder service fees, 12b-1 fees or bonus commissions paid by mutual funds, privately offered funds, insurance products, variable annuities or other investment products paid to Swiss USAdvisors for recommending an investment, for investing client funds in such product or for marketing assistance or the performance of certain administrative tasks associated with making an investment. Such remuneration received by Swiss USAdvisors from third parties belongs exclusively to Swiss USAdvisors and does not reduce the fee payable by the client to Swiss USAdvisors. Such fees can present a conflict of interest for Swiss USAdvisors as Swiss USAdvisors may receive compensation for making an investment advisory recommendation or investment allocation. Certain custodian banks may pay Swiss USAdvisors a fee in connection with a client’s account maintained at the custodian bank. Under customary Swiss banking practice, such fee is based on the size of the client account and based on the transactions that have occurred within the account during the past quarter. Due to the fact that increased trading within a client account will increase the fee paid by the custodian bank to Swiss USAdvisors, the receipt of such compensation presents a conflict of interest for Swiss USAdvisors. Swiss USAdvisors has a financial incentive to increase the number of transactions within a client’s account because the larger the commissions generated by trading within the account, the higher the fee paid by the bank to Swiss USAdvisors will be. Swiss USAdvisors agrees to fully disclose the receipt of such fees to the client in writing upon the client’s request. Swiss USAdvisors’s employees or associated persons may be invited to attend seminars and meetings with the costs associated with such meetings borne by a sponsoring brokerage firm or other party extending the invitation. XV. Custody Swiss USAdvisors typically is given authority to have its fees directly deducted from a client’s account. Consequently, Swiss USAdvisors is deemed to have custody of such funds. Swiss USAdvisors has established procedures to ensure the client’s account is held at a qualified custodian in a separate account for each client. The client establishes the bank account directly and therefore is aware of the qualified custodian’s name, address and the manner in which investments are maintained. Account statements are prepared by the custodian bank and delivered directly to the client or the client’s representative at least quarterly. Generally, these statements include a listing of all valuations and all transactions occurring during the period. Clients should carefully review these statements and when they have questions contact either Swiss USAdvisors or the custodian bank. The custodian bank also provides the client with all required year-end tax information. Swiss USAdvisors also may provide performance information to advisory clients about the client’s performance, which may also include a reference to a relevant market index or 14 V.1.0  Swiss USAdvisors Ltd. Form ADV Part 2A CRD: 158706 benchmark. Swiss USAdvisors may provide reports analyzing the sources of each account’s performance, including customary performance attribution and risk measurement statistics such as standard deviations, Sharpe ratios, deviations from benchmark returns, and investments that had the largest positive and negative impacts on performance. XVI. Investment Discretion Swiss USAdvisors accepts discretionary authority to manage client accounts as described above. Clients rarely restrict the authority by which Swiss USAdvisors may act; however, each client has the opportunity to communicate any form of limitation in writing. In the context of a discretionary mandate, Swiss USAdvisors makes investment decisions without consulting the client by utilizing its limited power of attorney for the management of the account maintained at the custodian bank selected by the client. In the context of a nondiscretionary mandate, Swiss USAdvisors’s investment discretion is limited to an advisory role and Swiss USAdvisors does not implement investment decisions without the approval of the client. Swiss USAdvisors never has discretionary authority to select a qualified custodian for a client’s account. XVII. Voting Client Securities In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Investment Advisers Act, Swiss USAdvisors has adopted and implemented written policies and procedures governing the voting of client securities. Swiss USAdvisors does have the authority to vote client proxies. Swiss USAdvisors will, until guidance to the contrary is provided by the SEC and/or such other relevant legal and/or regulatory bodies, employ proxy voting guidelines and proxy voting procedures, outlined in Swiss USAdvisors’s Compliance Manual. Clients may request a copy of these policies and procedures. Swiss USAdvisors does not direct client participation in class action lawsuits. Swiss USAdvisors will determine whether to return any documentation inadvertently received regarding clients’ participation in class actions to the sender, or to forward such information to the appropriate clients. XVIII. Financial Information Swiss USAdvisors has not been the subject of a bankruptcy petition at any time. 15 V.1.0