Founded in 2009, Windrose Advisors, LLC (hereinafter referred to as “Windrose”, “company”, “firm” “we”, “us”, and “our”) delivers sophisticated, highly customized, financial advice to a select group of high net-worth individuals, families, charitable foundations, and pooled investment vehicles (“funds”) on both a discretionary and non-discretionary basis. William A. Heitin, Daniel Fireman, DF Capital, LLC, DF Capital II LLC, and Phyllis Fireman Reebok GRAT FBO Daniel Fireman are the principal owners. Windrose develops close, trusting, relationships with clients. From the start of a relationship, we implement a careful and meticulous process to get to know our clients, understand their needs and map out a strategy that meets their long-term objectives. Risk tolerance, return expectations, liquidity constraints, time horizon, and overall financial goals are reviewed and discussed before formalizing an investment plan. We also provide education and integrated financial planning into investment recommendations and strategy. Windrose has developed a proprietary investment platform across all asset classes. We source, diligence, review and manage each investment we recommend to clients. Clients enjoy full access to our research. We believe proprietary direct investments or “in-house” products create a potential conflict of interest. We gain access to and partner with high-quality external investment managers. We employ mainly active, but also passive styles of investing depending on the asset class and client needs. Windrose provides financial planning services to clients and integrates this service into investment recommendations and strategy. Financial planning often includes charitable giving, generational wealth transfer, liability management, retirement planning, and estate planning and insurance. We work closely with other professional service providers, such as attorneys and accountants, who directly advise and execute strategy for clients. In addition, when appropriate, Windrose creates pooled investment vehicles to invest client funds in other private investment funds. Windrose also serves as investment advisor to these privately offered pooled investment vehicles. These pooled investment vehicles are available only to persons who are “accredited investors” under the Securities Act of 1933, or, in the case of some of the funds, “qualified purchasers” under the Investment Company Act

of 1940, as amended. These pooled investment vehicles have not historically been made available to non- Windrose clients and are not registered investment companies. Windrose tailors investment advisory services to the individual needs of the client. While we use our best efforts to recommend investments designed to address client investment objectives and risk tolerance, we cannot assure that our recommendations will achieve those objectives. Windrose clients are allowed to impose restrictions on the investments in their account. Windrose does not participate in a Wrap Fee Program. The total amount of client assets managed and advised by Windrose as of December 31, 2023, was $2,503,397,523. These assets are comprised of: Regulatory Assets Under Management
• Discretionary assets under management: $807,327,499
• Non-discretionary assets under management: $1,696,070,024, and Assets under Advisement
• Assets under Advisement: $1,283,397,600 Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.