THE AUGUST GROUP CAPITAL LIMITED

August Group FIRM BROCHURE (Part 2A of Form ADV) July 9, 2025 705-320 Bay Street Toronto, ON M5H 4A6 Phone: (438) 792-5161 www.augustgroup.com Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and business practices of August Group Capital Limited (“August” or “August Group” or the “Firm”). If you have any questions about the contents of this Brochure, please contact our Chief Compliance Officer at (416) 624-3950 or compliance@augustgroup.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about August and its investment adviser representatives is also available on the SEC’s website at www.adviserinfo.sec.gov. August Group is an SEC registered investment adviser. Registration does not imply any level of skill or training.  August Group Form ADV Part 2A July 9, 2025 ITEM 2: MATERIAL CHANGES August filed the last annual update to this brochure on February 26, 2025. August continues to conduct its business activities and provide investment advisory services in substantially the same manner as described in the last update to the brochure. The ensuing is only a list of changes since the last update that are or may be considered material. On July 9, 2025, the following material changes were made: Item 4, Advisory Business was updated to reflect that MattShans Holdings Inc. is now an indirect principal owner of August. 2  August Group Form ADV Part 2A July 9, 2025 ITEM 3: TABLE OF CONTENTS Item Number Page ITEM 2: MATERIAL CHANGES ................................................................................................................. 2 ITEM 3: TABLE OF CONTENTS .................................................................................................................. 3 ITEM 4: ADVISORY BUSINESS ................................................................................................................. 4 ITEM 5: FEES AND COMPENSATION ......................................................................................................... 5 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................... 8 ITEM 7: TYPES OF CLIENTS ..................................................................................................................... 8 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................... 9 ITEM 9: DISCIPLINARY INFORMATION .................................................................................................... 11 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................................ 11 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ... 12 ITEM 12: BROKERAGE PRACTICES ......................................................................................................... 13 ITEM 13: REVIEW OF ACCOUNTS .......................................................................................................... 14 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................... 15 ITEM 15: CUSTODY ............................................................................................................................ 16 ITEM 16: INVESTMENT DISCRETION ...................................................................................................... 17 ITEM 17: VOTING CLIENT SECURITIES .................................................................................................... 17 ITEM 18: FINANCIAL INFORMATION ...................................................................................................... 17 3  August Group Form ADV Part 2A July 9, 2025 ITEM 4: ADVISORY BUSINESS A. Description of Firm and Principal Owners August Group (“August”, the “Firm”, “we” or “us”) is a Canadian corporation that was formed in 2020. Based in Toronto, Ontario, August is principally owned by Lino Saputo Jr. and Amelia Violo through their ownership of August’s parent company, August Group, through Quadriam Investments Inc. (“Quadriam”), a family office and investment holding company. August is also principally owned indirectly by MattShans Holdings Inc. August became registered with the Securities and Exchange Commission as an investment advisor in 2021. August is also registered with the Ontario Securities Commission (OSC) in Ontario and in the provinces of Quebec, Alberta, British Columbia, and Manitoba. August’s activities with respect to non-U.S. clients may differ from those described generally herein and August may provide additional or different services to non-U.S. clients. Furthermore, any discussion of activities with respect to non-U.S. clients is intended solely to provide recipients a more complete understanding of August’s business. B. Types of Advisory Services Offered August Family Office Clients receiving the August Family Office service receive the full suite of August’s offerings: investment management, Family Office services, and Client Experience services. Family Office services include assistance with accounting, financial reporting, banking and credit, bill payment, cash flow and liquidity planning, major purchases, insurance planning, estate planning, cross-border planning, and tax and legal matters. Third party providers may be engaged for clients receiving the August Family Office services, at the client’s expenses. Depending on the nature of the services, Family Office advisory services may be provided through August Group Capital Ltd. or through August Group Legacy Ltd. August Client Experiences services are concierge and lifestyle services unique to each client’s needs. These services may include travel planning and management, private aviation management, entertainment and event planning, vehicle management, property management, personalized home services, and health and wellness planning. The August Family Office service is intended for high net worth and ultra-high net worth individuals and entities who have need of and intend to use the full suite of services offered by August and its affiliates, not only its investment management services. August Capital Allocation 4  August Group Form ADV Part 2A July 9, 2025 Clients receiving the August Capital Allocation service receive investment management services from us. Clients receiving the August Capital Allocation do not receive Family Office or Client Experiences services. Capital Allocation clients can engage us for our August Ascent program, which enables a client to pay a fixed fee for an initial financial roadmap from our Family Office team, as well as ad hoc advisory services that the client may require. C. Client Tailored Services and Client Imposed Restrictions Prior to providing investment advisory services to a client, August will first draft an Investment Policy Statement (“IPS”) for the client, and confirm with the client the parameters set out within it, taking into account the client’s personal circumstances, financial condition, investment objectives and goals, investment time horizon, and risk profile. August will rely upon this Investment Policy Statement when providing discretionary portfolio management services to the client. The client is responsible for advising August of any material change in the client’s personal circumstances, financial condition, investment objectives and goals, investment time horizon, and risk profile that may affect whether the parameters in the client’s IPS remain suitable for the client. In the IPS, or otherwise, clients may impose restrictions on investing in certain securities or types of securities. D. Participation in Wrap Programs August does not participate in any wrap fee program. E. Amount of Client Assets Managed As of December 31, 2024, the following represents the amount of client assets under management by the Firm on a discretionary and non-discretionary basis: Type of Account Discretionary Non-Discretionary Total: Assets Under Management $607,457,561 $42,280,284 $649,737,846 ITEM 5: FEES AND COMPENSATION A. Compensation for Advisory Services The specific advisory fees charged by August will be documented in each client’s written advisory agreement. 5  August Group Form ADV Part 2A July 9, 2025 August Family Office As the August Family Office service extends beyond investment management to provide a full suite of services intended to help clients manage numerous aspects of their wealth and their lives, fees for the Family Office service are charged on net worth. For clients receiving our Family Office service, we will charge a fee equal to an annual rate of 0.85% of net worth, which may be adjusted based on complexity. Net worth is defined as being the value of assets less the value of liabilities, subject to certain exclusions that may be captured in clients’ investment management agreement. For this purpose, assets may include assets held directly or indirectly, assets managed by third-party portfolio managers or invested in funds, assets that August manages directly, and cash and cash equivalents, among other assets. Liabilities may include mortgage debt, lines of credit, and other debt we determine from time to time at our discretion. August Capital Allocation For clients receiving our Capital Allocation service, the fee schedule is based on the value of investments overseen by August – that is, “assets under management” – including funds managed by third-party portfolio managers and invested in funds, as well as funds invested in alternative investments and private equity investments. The annual fee ranges from 1.00% of assets under management up to $5 million, to 0.40% of assets under management over $200 million. The annual fee is calculated on a marginal basis. Adjusted Fee Approaches As is set out above, August uses standardized fee approaches for its Family Office and Capital Allocation service offerings. From time to time, clients may negotiate adjusted fee approaches that differ from August’s standardized fee approaches. Whether a client may have an adjusted fee approach depends on a number of factors, including: • ongoing recognition of legacy fee structures that August no longer uses; • clients having specific assets or liabilities (for Family Office clients) where there is a reasonable rationale for the exclusion of such assets or liabilities in the calculation of net worth (e.g. August provides no advice or Family Office services in relation to such assets or liabilities); clients being on a fixed fee to reflect that they are receiving limited services from us; • • clients requesting a trial period, following which they will revert to August’s standardized fee approaches (if they agree to continue with August after the trial period); or clients needing some, but not all, of the services August offers. • 6  August Group Form ADV Part 2A July 9, 2025 Any adjustments to August’s standardized fee approaches are reviewed and approved by August’s management and compliance team. Fee negotiations are at the sole discretion of August. B. Billing Method Fees are usually deducted from a designated client account or accounts to facilitate billing. The client must consent in advance to direct debiting of their account. Payment by check is also acceptable. By signing August’s advisory agreement, and the selected custodian’s account opening documents, you will be authorizing the withdrawal of August’s advisory fees from your account. The withdrawal of these fees will be performed by the selected custodian or through a qualified, unaffiliated third-party processor. This custodian or processor will remit these advisory fees directly to our firm. You are encouraged to verify the accuracy of fee calculations and compare the statements provided to you by August with the statements from the custodian(s). The custodian does not verify the accuracy of the advisory fees charged to you. C. Other Fees and Expenses In addition to the service fees paid to August, clients will also incur certain charges imposed by other third parties, such as broker-dealers, third-party portfolio managers, custodians, trust companies, banks and other financial institutions. These additional charges will include securities brokerage commissions, transaction fees, custodial fees, management and performance fees charged by investment advisors selected by August, margin costs, charges imposed directly by a mutual fund or ETF in a client's account, as disclosed in the fund's prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd- lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. It is important to note that if a client retains a third-party portfolio manager to be overseen by August, the client will pay them fees in accordance with the agreement that you enter into with them, which will be in addition to any fees you pay to August. August recommends third-party portfolio managers or custodians based on a number of factors, including August’s knowledge and experience, August’s prior experience with the third-party portfolio manager or custodian, and fee discounts or other offerings that August may have secured from the third-party portfolio manager or custodian for its clients. Thus, it is important for clients to understand that they may be directly and indirectly paying two – or possibly three - levels of advisory fees: one layer of fees and expenses at the fund or independent manager level, one layer of advisory fees to a third-party portfolio manager (if applicable) and one layer of advisory fees to August. It may be possible to purchase such 7  August Group Form ADV Part 2A July 9, 2025 investments directly, without using the services of August and without incurring our advisory fees. In addition, the service fee charged by August does not include fees for services obtained from third party service providers that may be engaged as part of the Family Office service, including accountant fees, tax returns, real estate agents, insurance premiums, legal advice, etc. All such fees are payable separately and in addition to the Firm’s service fee. Any fees that you pay will impact the returns that are generated in your account by decreasing those returns. Since returns are compounded over time, the greater the value left in the account, the greater the potential to earn higher returns over time. Therefore, higher fees serve to reduce the total returns earned over time. When we charge a fee based on your net worth or assets under management, the more assets that are in your account, the more you will pay in fees. We therefore may have an incentive to encourage you to increase the assets on which we can charge our service fee. D. Termination of Services August bills clients quarterly in arrears. Either the client or August may terminate the Firm’s services without penalty, as per the terms of the Investment Management Agreement. E. Outside Compensation for Sale of Securities August’s personnel include licensed representatives of August Group Legacy, an affiliated licensed insurance agency. Accordingly, these personnel may recommend insurance products and receive commissions when insurance products are purchased through August Group Legacy. A conflict of interest exists as these personnel have an incentive to recommend insurance products through August Group Legacy based on the compensation they will receive. Clients are under no obligation, however, to purchase any insurance products through August Group Legacy. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT August does not charge performance-based fees (i.e., fees calculated based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client). As a result, the Firm does not engage in side-by-side management of accounts that are charged a performance-based fee by August with accounts that are charged another type of fee (such as assets under management). ITEM 7: TYPES OF CLIENTS August provides advisory services primarily to individuals and high net worth individuals, as well as to families, trusts, estates, and other business entities. 8  August Group Form ADV Part 2A July 9, 2025 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. Methods of Analysis and Investment Strategies In formulating investment advice and managing assets, August will utilize fundamental analysis and conduct due diligence, including reviewing the respective portfolio managers and investment team, the firm’s track records, and, in certain cases, conducting operational due diligence. Clients should be aware that investing in securities involves risk of loss that they should be able to bear. B. Investment Strategies The primary investment strategy used to implement any investment advice given to clients is asset allocation. Based on the client’s Investment Policy Statement (IPS) and, in particular, client-driven factors such as desired rate of return, aversion to risk, investment time horizon, tax consequences, country of residency and other constraints, investments are diversified across different asset classes and investment styles. C. Risk of Loss Investing in securities involves a significant risk of loss, and all investments have certain risks that are borne by the investor. Past performance is not indicative of future results. Therefore, clients should never assume that future performance of any specific investment or investment strategy will be profitable. Because of the inherent risk of loss associated with investing, August is unable to represent, guarantee, or even imply that its services and methods of analysis can or will predict future results or insulate you from losses due to market corrections or declines. When considering an investment, or your investment approach, clients should carefully consider whether it is appropriate in light of investment experience, objectives, financial resources, risk tolerance and other relevant circumstances. Clients should understand the nature of what you invest in and the extent of your exposure to risk. Depending on the nature of the investment, the nature of the investment risks associated with it will vary. August monitors the risk of the investment portfolios of our portfolio management clients to ensure that they are meeting their objectives and remain within their risk constraints. Generally, the value of securities will fluctuate in accordance with changes in the financial condition of the issuers of those securities, market conditions generally, and other factors. There is a strong relationship between the amount of risk associated with a particular investment and its potential to increase in value in the long term. Some risks associated generally with investing include: 9  August Group Form ADV Part 2A July 9, 2025 • Capital risk: the risk that you may lose the money you invest. • Credit risk: the risk that a borrower (e.g. the issuer of a bond, a private company obtaining private loans) will not be able to repay principal or interest to the lender when it comes due. • Market risk: the risk that investments in equities and investments that are exposed to the equity markets will be affected by changes in the stock market. Stock market changes can be caused by a number of factors, including interest rate fluctuations, changes in market outlook, and changes in economic, social or political climates. • Interest rate risk: the risk of losses due to changes in interest rates (e.g. investments in debt instruments may become less valuable when interest rates rise because newer debt instruments will pay a current, higher interest rate). • Foreign currency risk: the risk that currency movements and fluctuating exchange rates affect the value of investments in foreign securities or income such securities pay. • Foreign markets risk: the risk that companies in other markets, including less developed markets, or the securities they issue, may be more difficult to sell or may decline in value due to political, regulatory, social, or economic change. • Inflation risk: the risk that the value of money may erode over time. • Liquidity risk: the risk that your investment may be difficult or impossible to convert into cash when required. • Concentration risk: the risk of loss from investments being concentrated in in a particular issuer, group of issuers or sector, or in a single country or region. Concentration in any one of these means that the value of a portfolio of investments tends to be more volatile than a more diversified portfolio. • Asset allocation risk: the risk that one or more asset classes to which an investment portfolio is allocated underperforms relative to the other asset classes in the portfolio. • Cybersecurity / technology risk: the risk of loss resulting from a cybersecurity incident (e.g. fraud, phishing, hacking). Clients investing in an investment fund or private equity fund will be bound by the redemption provisions in that fund’s documentation (as well as all other provisions), because those provisions are legally binding. Such redemption provisions can be restrictive and require lengthy advance notice prior to redemption, which means that the client could be restricted from receiving a return on their investment for a lengthy period of time. This is known as an illiquid investment. Clients should ensure they are comfortable with a long-term commitment of capital prior to investing in any such investment product. 10  August Group Form ADV Part 2A July 9, 2025 A description of the risks associated with any specific investment is included in the offering documentation associated with that product. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisers such as August are required to disclose all material facts regarding any legal or disciplinary event that would be material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. August has not been subject to any such legal or disciplinary event, and thus has no information to disclose with respect to this Item. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither August, nor any member of its management is registered as a securities broker-dealer, or a futures commission merchant, commodity pool operator or commodity trading advisor. The Firm does not have any affiliation with any related person who is a broker-dealer, investment company, other investment advisor, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. August does not receive compensation directly or indirectly from other advisers that creates a material conflict of interest, nor does it have other business relationships with advisers that would create a material conflict of interest. August is under common control with Quartexx, a sports agency that represents certain clients of August. August provides investment advisory services to Quadriam, the majority owner of August’s parent company, which is a conflict of interest since August has an incentive to favor Quadriam when recommending third-party investment managers and allocating investment opportunities to clients. To help mitigate this conflict, August has policies and procedures in place to ensure that Quadriam does not receive favorable treatment when the Firm recommends such managers and investments to clients. Separately, August has taken steps to ensure that any recommendation it makes on behalf of clients with regard to the use of a custodian or third- party investment manager will not directly benefit Quadriam (e.g., lower fees paid by the holding company for its own accounts). August is affiliated with August Lifestyle, which provides non-investment advisory, concierge services. August Lifestyle may receive referral compensation when sending a client to certain services providers. Clients are under no obligation to use the services of August Lifestyle and may choose another services provider to meet their needs. 11  August Group Form ADV Part 2A July 9, 2025 August is affiliated with August Marketing, which provides services such as content creation, videography, and social media strategies. Additionally, August Marketing assists in negotiating sponsorships and endorsements. Clients are under no obligation to use the services of August Marketing and may choose another services provider to meet their needs. August is also affiliated with August Group Legacy, a licensed insurance agency in Canada. Certain personnel of August are licensed representatives of August Group Legacy and may receive commissions when insurance products are purchased through this entity. As a result, there is a conflict of interest as August has an incentive to recommend insurance products through August Group Legacy. Clients are under no obligation, however, to purchase any insurance products through this entity. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Description of Code of Ethics The principals and employees of August have adopted a Code of Ethics for the purpose of instructing its personnel in their ethical obligations and to provide rules for their personal securities transactions. The Firm owes a duty of loyalty, fairness and good faith towards its clients, and the obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code of Ethics covers a range of topics that include the following: general ethical principles, receipt and giving of gifts and entertainment, reporting personal securities trading, exceptions to reporting securities trading, initial public offerings and private placements, reporting violations, and the distribution of the Code of Ethics. We will provide a copy of the Code of Ethics to any client or prospective client upon request. B. Participation or Interest in Client Transactions As part of August’s fiduciary duty to its clients, the Firm and its supervised persons seek at all times to put the interests of its clients first, and at all times are required to adhere to the Firm’s Code of Ethics. August’s principals and employees may have positions in securities and funds that we also recommend to clients. August’s recommendations to clients may differ from client to client, based on each client’s unique circumstances. The Firm may also recommend the purchase of a security for one client while recommending the sale of that security for another. However, as a fiduciary, August endeavors to act for the benefit of clients and place clients’ interests before its own. Similarly, client transactions have priority over transactions in securities and other investments of which our principals and employees may own. Principals 12  August Group Form ADV Part 2A July 9, 2025 and employees may participate with clients in block trades and must adhere to the Firm’s personal trading policies and procedures at all times. To help mitigate any real or potential conflicts of interest associated with these practices, the Chief Compliance Officer of August reviews employee trades involving reportable securities each quarter and holding reports annually. Such reviews help ensure that personal trading does not disadvantage clients. It is August’s policy not to enter into any principal transactions or cross transactions on behalf of client accounts. Principal transactions occur where an advisor, acting as principal for its own account or the account of an affiliate, buys securities from or sells securities to an advisory client. Cross transactions occur where an investment advisor arranges a transaction between two client accounts. ITEM 12: BROKERAGE PRACTICES A. Factors Used to Select Custodians and/or Broker-Dealers Custodians and broker-dealers will be recommended by August based on the firm’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent and August may also consider the market expertise and research access provided by the custodian or broker-dealer. August will not charge a premium or commission on transactions, beyond the actual cost imposed by the custodian or broker-dealer. B. Research and Other Soft Dollar Benefits The Firm does not have any arrangements to receive soft dollar benefits in connection with client securities transactions. August may receive research and other products and services from custodians and broker-dealers. C. Brokerage for Client Referrals August does not have any arrangements to receive client referrals from any broker-dealer or third party. D. Directed Brokerage 13  August Group Form ADV Part 2A July 9, 2025 The Firm does not require clients to execute transactions through a specified broker-dealer. However, August may recommend that a client use the services of a particular third-party portfolio manager, custodian or bank. In cases where either August or a client recommends that a specific custodian or broker-dealer be used to execute advisory transactions, August may be unable to achieve more favorable execution of client transactions. In addition, clients may pay higher transaction costs as a result of a broker-directed account by a client. E. Aggregation of Orders August may aggregate (“block trade”) sale and purchase orders with other client accounts that have similar orders being made at the same time under the management of the Firm, if in the Firm’s judgment aggregation is reasonably likely to result in an overall economic benefit to the client. Such benefits may include better transaction prices and lower trade execution costs. If all aggregate orders do not fill at the same price, August may cause the client and each similar order to pay or receive the average prices at which the orders were filled. If such orders cannot be fully executed under prevailing market conditions, August may allocate the securities traded among clients and each similar order in a manner which it considers equitable, taking into account the size of the order placed, the client’s cash position, investment objective of the account, and liquidity of the security. ITEM 13: REVIEW OF ACCOUNTS A. Review of Accounts The Firm’s managed accounts are reviewed on an at least an annual basis and take into account the overall asset allocation of the client’s portfolio and any changes to the personal circumstances, financial situation, investment needs and objectives, investment knowledge, risk profile, or investment time horizon of the client. B. Review Triggers The Firm’s managed accounts are reviewed with regard to the overall asset allocation of the portfolio and in light of the client’s investment objectives and risk tolerance. Triggers for investment reviews may include, but are not limited to: • Deposits or withdrawals • Changes in third-party investment managers • Significant changes in the client’s situation or in the client’s objectives • Re-balancing of accounts • Change in country of residence • Client request 14  August Group Form ADV Part 2A July 9, 2025 C. Regular Reports August typically sends written quarterly reports to all clients. The reports include portfolio holdings summaries and performance reports. For clients receiving the Capital Allocation service, accounts, assets or other investments that the client does not want to be actively managed by the Firm will generally not be included in August’s quarterly reports. In contrast, such assets will generally be included in August’s quarterly reports for clients receiving the firm’s Family Office service. For clients who also open accounts with third-party portfolio managers, the third-party portfolio manager that you open an account with will also be responsible for providing statements in accordance with the agreement that the client enters into with them and in accordance with their legal obligations. Clients are urged to carefully compare statements sent by August with statements sent by other third parties, such as those sent by the client’s custodian. Account reporting may be delivered in hard copy to a mailing address or may be delivered electronically. August requests consent to deliver such information and reporting electronically in it account opening documentation, but clients may request to receive account reporting in hard copy. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. Referrals to August August enters into written arrangements with third parties to act as promoters or solicitors for August’s investment advisory services. Referral relationships, where applicable, will be fully disclosed to each client to the extent required by applicable law. August will verify each promoter/solicitor is properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with the Advisers Act, where applicable. Advisory fees paid to August by clients referred by promoters/solicitors are not increased as a result of any referral relationship. August will disclose any referral arrangement that applies to a client, since it is important for the client to understand and consider that the third-party referrer will be compensated by August for the referral of business to August, and that, therefore, the third-party referrer may be incentivized to recommend August over other firms. Under no circumstances will a client pay August more in fees because of having come to August through a referral. August has adopted several procedures to ensure it determines that accepting a referral is in a referred client’s best interest. These procedures include (i) requiring Chief Compliance Officer approval of any referral arrangement, (ii) conducting due diligence on potential third-party referrers, (iii) only onboarding a referred client if the firm determines that its services are suitable for that client and that client wishes to proceed to engage the firm as its portfolio manager, (iv) not increasing the amount of the management fee that would otherwise be paid 15  August Group Form ADV Part 2A July 9, 2025 by a referred client to the firm for the same service or product as a result of August being obligated to pay a portion of the management fees it receives from a referred client to the third-party referrer, and (v) keeping records of all payments related to the firm’s referral arrangements. B. Referrals from August August recommends third-party portfolio managers or a custodian to clients. August recommends third-party portfolio managers or custodians based on a number of factors, including August’s knowledge and experience, August’s prior experience with the third-party portfolio manager or custodian, and fee discounts or other offerings that August may have secured from the third-party portfolio manager or custodian for its clients. August does not receive compensation from any of the third-party portfolio managers or custodians it may recommend, and has no mutual referral arrangements in place with any of the third-party portfolio managers or custodians it may recommend. From time to time, August will refer clients to a third party service provider who does not provide investment management services, typically to provide services related to our Family Office and Client Experiences service offerings. For example, August will refer to accountants, tax advisors, lawyers, or similar professionals. We identify third party service providers to refer clients to based on a number of factors, including our prior experience with these providers, our industry knowledge, recommendations from others, or special rates or offerings that we may secure from these providers, where applicable. However, third party service providers are responsible for the quality and accuracy of their own work, and clients are not obligated to use any third party service providers August may refer them to and may use third party service providers of their own choosing. We do not receive compensation from third party service providers for such referrals. ITEM 15: CUSTODY Occasionally, August receives checks and income tax returns on behalf of our clients. In such cases, August will contact the client for instructions regarding which account the cheques or returns should be deposited into. For certain clients of August Group with their assets custodied at RBC USA, August Group is authorized by the client to make certain money movements from investment accounts on their behalf. An example of this could be to meet a capital call for a private investment. These activities give August custody of these funds. To ensure transparency and accountability, we have enlisted the services of a public company accounting oversight board (PCAOB) auditing firm to conduct surprise audits. August has implemented policies and procedures regarding the receipt of such checks. 16  August Group Form ADV Part 2A July 9, 2025 August also has the authority and ability to debit its fees directly from clients’ accounts, August may be deemed to have custody with regard to such accounts, pursuant to Rule 206(4)-2 of the Advisers Act. To mitigate any potential conflicts of interests, all client assets are maintained with an independent qualified custodian. Furthermore, clients will receive statements on at least a quarterly basis directly from the qualified custodian that holds and maintains their assets. Clients are urged to carefully review all custodial statements and compare them to the quarterly statements provided by August. August’s statements may vary slightly from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. ITEM 16: INVESTMENT DISCRETION We generally provide our investment advisory services on a discretionary basis, which allows our firm to implement investment decisions, such as the recommendation of third-party portfolio managers and the purchase or sale of securities on behalf of your account, without requiring your prior authorization in order to meet your stated investment objectives. This authority will be granted through your execution of our advisory agreement and, if applicable, the selected third-party portfolio managers custodian’s account opening documents. Clients are permitted to impose reasonable limitations on August. All such limitations, restrictions, and investment guidelines must be communicated to August in writing, such as in the client’s Investment Policy Statement (IPS). ITEM 17: VOTING CLIENT SECURITIES It is August’s policy and practice to only vote proxies when specifically instructed by a client. In such cases, August will vote solely in the best interest of that client and has established general guidelines for voting proxies. August may vote in a manner that is contrary to these general guidelines if the firm believes that doing so would be in a client’s best interest. If a proxy proposal presents a material conflict of interest between August and a client, then August will notify the relevant clients about the conflict of interest and obtain their approval prior to voting the proxy. Clients may obtain a complete copy of the proxy voting policies and procedures by contacting August in writing and requesting such information. Each client may also request, by contacting August in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the relevant client during the prior annual period. ITEM 18: FINANCIAL INFORMATION August does not require or solicit prepayment of more than $1,200 in fees per client, six months 17  August Group Form ADV Part 2A July 9, 2025 or more in advance and therefore is not required to provide, and has not provided, a balance sheet. Furthermore, August does not have any financial commitments that may impair its ability to meet contractual and/or fiduciary obligations to clients. Finally, the Firm has not been the subject of a bankruptcy proceeding. 18