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PURSHE KAPLAN STERLING INVESTMENTS

SUPERVISORY PROCEDURES MANUAL

Amended March 2022

ACKNOWLEDGMENT OF REGISTERED REPRESENTATIVES By his/her signature below, the undersigned recipient of this Manual acknowledges that he/she has received the Manual, is responsible for knowing its contents and has read and understood its contents to the level of being able to answer questions about it from supervisors and regulatory auditors and to put its principles into practice. The undersigned understands that the Manual is continually updated and agrees to take responsibility for obtaining, reviewing and understanding any updates or supplements published by PKS. By his/her signature below, the undersigned expressly certifies that he/she is familiar with and understands each of the following subtopics listed below regarding Registered Representative Conduct, contained in Section 6 of the Manual.

• Duties and Responsibilities of Registered Representative • Prohibited Conduct • Firm Policy on Insider Trading • New Issue Rules • Private Securities Transactions ("Selling Away") [FINRA Rule 3280] • Transactions by Associated Persons of Other Broker-Dealers [FINRA RULE 3210] • Transactions by PKS Associated Persons at Other Broker-Dealers [FINRA RULE 3210] • Outside Business Activities

By his/her signature below, the undersigned expressly certifies that he/she is familiar with and understands the privacy , Protection of Customer Information and Identity Theft [Section 19.13] provisions of the Manual. By his/her signature below, the undersigned expressly certifies that he/she is familiar with and understands the Anti-Money Laundering [AML] Provisions of the Manual. __________________________________ _________________ Signature [Date] __________________________________ [Print or Type Name] (Amended 2/2015)

TABLE OF CONTENTS INTRODUCTION SECTION1: USE AND DISTRIBUTION OF THIS SUPERVISORY PROCEDURES MANUAL [“SPM”] SECTION 2: SUPERVISORY AND COMPLIANCE PERSONNEL

2.1 Executive Representative 2.2 Government Securities Act Amendments of 1993 2.3 Audit Committee 2.4 Annual Report Under FINRA Rule 3130 2.5 Annual Certification by Chief Executive Officer 2.6 SPM Committee 2.7 Growth Impact Assessment Committee 2.8 Cyber Security Committee 2.8.1 Cyber Incident Identification & Reporting Sub-Committee 2.9 Best Execution Committee SECTION 3: LICENSING 3.0 General 3.1 Institution al Sales Department 3.2 Licensing Department

3.3 Documentation Required 3.4 Assessment of Applicant 3.5 Procedures on Transition from Prior Firm 3.5.1 Waiver Requests 3.6 Compliance Department Procedures for New Associated Persons 3.7 State Registration 3.8 Termination of Registration 3.9 Investment Advisory Outside Business Activities

SECTION 4: STANDARDS OF SUPERVISION

4.1 Supervisory Review System 4.2 Centralized Supervisory System 4.2.1 Documentation and Supervision of Supervisory Personnel 4.3 Supervisory Responsibilities of Regional Supervisors 4.4 Trade Desk Supervision 4.5 Reserved 4.6 Heightened Supervision 4.7 Reserved 4.8 Branch Offices 4.9 Offices of Supervisory Jurisdiction 4.10 Branch Office Supervision 4.11 Bank Networking Arrangements

4.12 Insurance Agency Network Agreement With PKS Financial Services, Inc, for Variable Product

4.13 Conduct Manual For Variable Insurance Through PKS Financial Services SECTION 5: COMPLIANCE DEPARTMENT 5.0 Chief Compliance Officer 5.1 Audit/Inspections of Offices-Time Requirements 5.2 Reserved 5.3 Branch Office and OSJ Audit Procedures 5.3.1 Satellite Branch Offices and Non Registered Branch Offices 5.4 Review of Exception Reports 5.5 Investigation of Suspect RR Activity

5.6 Review of Accounts Held by Officers and Directors of Publicly Traded Companies

5.7 Reserved 5.8 Annual Compliance Meeting and Certification

5.9 SPM Record Keeping and Updates 5.10 Review of Correspondence 5.11 Review of Outgoing Communications With the Public 5.12 Public Appearances 5.13 Continuing Education 5.14 Fingerprinting Unregistered Personnel – SEC 17f-2(a) 5.15 Professional Designations 5.16 Annual Internal Audit SECTION 6: REGISTERED REPRESENTATIVE CONDUCT 6.1 Duties and Responsibilities of Registered Representatives 6.2 Prohibited Conduct 6.3 Firm Policy on Insider Trading 6.3.1 New Issue Rules 6.4 Private Securities Transactions ("Selling Away") [FINRA Rule 3280] 6.5 Transactions by Associated Persons of Other Broker-Dealers [FINRA RULE 3210]

6.6 Transactions by PKS Associated Persons at Other Broker-Dealers [FINRA RULE 3210]

6.7 Outside Business Activities 6.8 Registered Representatives Acting as Trustee 6.9 Political Activities and Political Contributions by Registered Representatives 6.10 Registered Representatives Named as Beneficiaries, Receiving Bequeathments, or

Holding a Position of Trust for a Customer SECTION 7: CUSTOMER RELATIONS 7.0 Know Your Customer 7.0.1 Regulation Best Interest

7.0.1.1 Massachusetts Fiduciary Rule 7.1 The Suitability Rule: FINRA Rule 2111 [Text of Rule] 7.2 Analysis of FINRA Rule 2111 [Suitability] 7.3 PKS Suitability Procedures 7.4 Temporary Holds on Disbursement of Funds or Securities 7.5 Designation of Trusted Contact Persons 7.6 Address Changes 7.6.1 Non-Electronic Deposit of Customer Funds 7.7 Death of a Customer 7.8 Restrictions on Telemarketing 7.9 Loans To/From Customers 7.10 Orders and Discretion in Customer Accounts 7.11 Sharing Profits/Losses 7.12 Senior Investors 7.13 Supervision of Outsourcing Arrangements with Third Party-Providers 7.14 PKS Electronic Signature Procedures 7.15 Reserved

7.15.1 Margin Disclosure Statement 7.15.2 Order Execution and Routing Practices 7.15.3 Risks of Concentrated Positions and Active Accounts 7.15.4 Procedures for Client Notification of Concentrated Positions and

Active Accounts 7.15.5 Regulation SP 7.15.6 Notification and Supervision of Changes of Investment Objective 7.15.7 Supervision of Outsourcing Arrangements

7.16 Check, Electronic Funds Transfer (EFT’s) and Wire Request Procedures 7.17 Fees Charged to Customers 7.18 Commission Recapture Program 7.18.1 Other Special Account For Benefit of Customers 7.19 Disclosure of Compensation in ERISA Accounts 7.20 Individual Retirement Account (IRA) Prohibited Transaction Exemption PTE 2020-02 7.21 Transactions Involving the Sales of Insurance Policies and Annuity Contracts to IRAs and Retirement Plans – Prohibited Transaction Exemption PTE 84-24 SECTION 8: CUSTOMER COMPLAINTS 8.0 Customer Complaints

8.1 Disclosure Reporting Requirements

8.2 Complaints Made By Telephone (NFA) 8.3 Written Complaints (NFA) SECTION 9: OPENING NEW ACCOUNTS; ACCOUNT TRANSFERS 9.1 New FCCS Brokerage Account Form 9.1.1 Omnibus Accounts 9.1.2 Custodial Accounts

9.2 New Account Restrictions 9.3 Signature Guarantees

9.4 Reserved 9.4.1 Reserved 9.4.2 Reserved 9.5 Reserved 9.6 ACATS and Other Account Transfers 9.7 Margin Accounts 9.8 Short Sales 9.9 Accounts of Associated Persons of Other Firms (FINRA, NYSE, AMEX) 9.9.1 Obligations of Executing Member

9.10 Obligations Of Associated Persons Concerning an Account with An Investment Adviser, Bank or Other Associated Financial Institution

9.11 Lost or Stolen Certificate Scenarios 9.11.1 Possible Scenarios 9.11.2 Certificates Lost by the Registered Holder 9.11.3 Certificates Lost or Stolen in Correspondent Control 9.11.4 Certificates Lost or Stolen in Transit 9.11.5 Certificates Lost on Premises at FCCS 9.11.6 Certificates Mailed but not Received 9.11.7 Certificates Lost or Stolen in Transit from the Registered Holder 9.11.8 Certificate Mailed Directly to the Customer 9.11.9 Certificate Registered in Name of FCCS mailed directly to Fidelity or FCCS 9.11.10 Certificate Registered in Name of Customer Mailed to FCCS or Fidelity 9.11.11 Transfer Agent Notification Beyond Required Time Period

9.12 Account Transfers and Recruitment Practices SECTION 10: TRANSACTIONS

10.1 Mark-ups/Mark-downs 10.1.1 Net Transactions with Customers 10.2 Charges for Services

10.3 Churning 10.4 Mutual Fund Sales 10.5 Restrictions on IPO Transactions 10.6 Fictitious Accounts

10.7 “Soft Dollar” and Directed Brokerage 10.8 “Parking” 10.9 Bulletin Board and “Penny Stocks” 10.10 International Trading

SECTION 11: ADVERTISING/PROMOTION

11.1 Reserved 11.2 Product Sales Material 11.3 Training or Educational Events

11.4 Research Reports 11.5 Options Advertising 11.6 Reserved

11.6.1 Purchases and Sales of Mutual Funds and Other Securities

11.7 Gifts, Gratuities and Rebates 11.8 Research SECTION 12: TRADE DESK 12.1 Best Execution 12.2 Limit Order Policy 12.3 The Order Ticket 12.3.1 Regulation SHO 12.4 Consolidated Audit Trail System (CAT) 12.5 TRACE Reporting

12.6 Order Processing 12.6.1 Market-Wide Trading Halts 12.6.2 Reciprocal Activity

12.7 Confirmations 12.7.1 Markup Disclosure for Corporate and Agency Bonds 12.7.2 Markup Disclosure for Municipal Bonds 12.8 Small Order Execution System (SOES) 12.9 Solicited/Unsolicited Transactions

12.10 Rule 144 Transactions 12.11 Reserved 12.12 Payment for Order Flow 12.13 Payment Rules 12.14 Reserved 12.15 “Internal Use Only” Material 12.16 Surveillance Activity to Monitor Trading 12.17 Security Procedures

SECTION 13: CUSTODY 13.1 In General 13.2 The Securities Investor Protection Corporation (SIPC)

13.3 Clearing Agreements SECTION 14: INVESTMENT BANKING

14.1 New Issues Through Fidelity Capital Markets 14.1.1 IPO Certification Form 14.1.2 Electronic Mail Consent Form For IPO Transactions 14.1.3 IPO Negative Consent Letter 14.1.4 IOI Ticketing E-mail

14.2 New Issues Through Other Dealers SECTION 15: PARTICULAR INVESTMENT PRODUCTS

15.0 New Products 15.0.1 Skybridge Series G 15.0.2 Private Placement Variable Life Insurance 15.0.3 Private Company Access Fund LP 15.1 Mutual Funds

15.1.1 In General 15.1.2 Suitability 15.1.3 Disclosure of Fees and Expenses 15.1.3a Addition of “Service Fees” to No-Load Funds 15.1.4 Breakpoint Sales 15.1.5 Letters of Intent 15.1.6 Rights of Accumulation 15.1.7 NAV Transfer Programs 15.1.8 Rights of Reinstatement 15.1.9 Grouping of Family Orders 15.1.10 “Trails” and Other Contingent Deferred Sales charges 15.1.11 Repurchases and Redemption 15.1.12 Reserved 15.1.13 Selling Dividends 15.1.14 Selling Compensation 15.1.15 Prospectus Delivery 15.1.16 Completion of Direct Mutual Fund Applications and Tickets 15.1.17 Market Timing of Mutual Funds 15.1.18 Receipt of Non-cash Compensation and Sales Incentives 15.1.19 Records 15.1.20 Unit Investment Trusts

15.2 Variable Products 15.2.1 Product Identification 15.2.2 Suitability Under FINRA Rule 2330

15.2.2.1 PKS Financial Services 15.2.2.2 Variable Life Insurance 15.2.2.3 Whole Life 15.2.2.4 Military Sales Practices 15.2.2.5 Reserved

15.2.3 Switching (“Twisting”)

15.2.4 Liquidity 15.2.5 Sales Charges; Promotional Payments 15.2.6.0 Variable Annuity Exchanges from Non-Portable Products 15.2.6 Completion of Variable Annuity Applications 15.2.6.1 Variable Annuity Compliance Forms 15.2.6.2 Morningstar Annuity Intelligence 15.2.7 Principal Review of Variable Annuity Applications 15.2.8 Supervisory Procedures for FINRA Rule 2330 Compliance 15.2.9 Training for FINRA Rule 2330 Compliance 15.2.9.1 Miscellaneous Variable Annuity Procedures 15.3 Corporate Bonds 15.3.1 Secured Bonds 15.3.2 Unsecured Bonds 15.3.3 Zero-Coupon Bonds 15.3.4 High Yield Debt

15.4 Collateralized Mortgage Obligations (CMO’s) 15.4.1 Product Identification 15.4.2 Educational Material

15.5 Direct Participation Programs 15.5.1 Reserved 15.5.2 Reserved 15.5.3 Reserved 15.5.4 Reserved 15.5.5 Reserved 15.5.6 Secondary Market Trading 15.5.7 Valuation of DPP Units for Reporting Purposes

15.6 Municipal Securities 15.6.1 Supervisory Responsibilities 15.6.2 Sales Practices 15.6.2.2 Municipal Bond Material Events and Disclosure Checklist 15.6.3 Books and Records 15.6.4 MSRB Rule G-8 Customer Accounts 15.6.5 MSRB Rule G-37 15.6.6 Bonds and Borrowed Loan Transactions 15.6.7 Municipal Fund Securities/529 Plans 15.6.8 Supervision of Municipal Transaction Reporting

15.7 Options 15.7.1 General 15.7.2 Types of Options 15.7.3 Options Position Limits 15.7.4 Opening of Accounts 15.7.5 Trading for the Client’s Account 15.7.6 Exercise Procedures 15.7.7 Margin Procedures 15.7.8 Supervision of Options Activity 15.7.9 Customer Complaints

15.7.9.1 Options in an IRA 15.8 General Fixed Income Products

15.8.1 Reserved 15.8.2 Parking of Securities 15.8.3 Repurchase and Reverse Repurchase Agreements 15.8.4 Churning in Fixed Income 15.8.5 Adjusted Trading

15.9 Derivative Products 15.10 Government Sponsored Enterprises Distribution and Treasury Securities 15.10.1 Disclosure of Principal Returns

15.11 Certificates of Deposit 15.12 Completion of an Alternative Investment Submission

15.12.1 Alternative Investment Compliance Forms 15.12.2 Principal Review of REIT Applications

15.12.3 1031 Exchanges 15.13 Portfolio Limitations on Certain Unregistered Securities and other .

Illiquid and/or Alternative Investments 15.14 Commodities Futures Transactions 15.14.1 Managed Futures 15.15 Hedge Funds 15.16 Equity-Indexed Annuities 15.17 Structured Products

SECTION 16: CONTINUING EDUCATION 16.1 In General

16.2 Regulatory Element 16.2.1 Required Participation Cycle 16.2.2 Customized Programs 16.2.3 CRD Notifications and Reports 16.2.4 Failure to Complete 16.2.5 Re-entry into Program

16.3 Firm Element 16.3.1 Persons Subject to the Firm Element 16.3.2 Standards for the Firm Element 16.3.3 Participation in the Firm Element 16.3.4 Specific Training Requirements 16.3.5 Regulatory Consequences for Non-Compliance

SECTION 17: RECORD KEEPING AND REPORTING 17.1 Principal Responsibilities 17.2 Use of Electronic Media 17.3 Net Capital Requirements

17.4 Annual Financial Audit 17.5 Focus Reports 17.6 Reporting Required Under SEC Rule 17a-11

17.7 Customer Account Statements 17.8 Record of Written Complaints 17.9 Reserved 17.10 Customer Account Information 17.11 Release of Confidential Customer Information 17.12 Preparation of Required Records 17.13 FINRA Fees and Assessments 17.14 Records Regarding Approval of Communications 17.15 Records of Examinations Reports 17.16 Records of Cash and Non-Cash Compensation 17.17 Record Keeping Requirements 17.17.1 Preservation of Required Records 17.18 Municipal Securities Business 17.19 Investment Banking

17.20 Options Business SECTION 18: REGISTERED REPRESENTATIVES ALSO ASSOCIATED WITH

REGISTERED INVESTMENT ADVISORY FIRMS 18.1 Independent Advisory Activities SECTION 19: INFORMATION SECURITY POLICIES AND PROCEDURES

19.1 Comprehensive Information Security Program (CISP) 19.2 Definitions 19.3 Risk Mitigation Practices and Procedures 19.4 Detection of Threats to Information Security 19.5 Response to Breach of Security 19.6 Response to Other Information Security Incidents 19.7 Secure Disposal of Documents and Data 19.8 Reserved 19.9 Reserved 19.10 Other Electronic Safeguards 19.11 Acceptable Use Policy 19.11.1 Overview 19.11.2 Purpose 19.11.3 Scope 19.11.4 Policy 19.11.4.1 General Use and Ownership 19.11.4.2 Security and Proprietary Information 19.11.4.3 Unacceptable Use 19.11.4.4 Blogging and Instant Messaging 19.11.4.5 Internet Usage 19.12 Non-Published IT Department Procedures 19.13 Identity Theft Prevention Program

PART I: Supervisory Procedures PART II: Appendices Appendix A: Anti-Money Laundering Compliance and Supervisory Procedures Appendix B: Business Continuity and Disaster Recovery Plan for Registered Representatives Appendix C: Forms referenced in Part I Appendix D: Procedure Amendments due to COVID-19 INTRODUCTION This Supervisory Procedures Manual of Purshe Kaplan Sterling Investments (also referred to as the “Company”, the “Firm”, or “PKS”) is maintained pursuant to Section 3110 and 3170 of the Financial Industry Regulatory Authority (FINRA) and FINRA Regulatory Notices issued pursuant thereto. (Amended 9/2021) It is the obligation of Purshe Kaplan Sterling Investments (PKS) to supervise the activities of its registered and associated persons. The procedures contained in this Manual are intended to enable the Company’s designated supervisors to ensure compliance with the rules and regulations of the SEC, FINRA and applicable state jurisdictions and statements of policy there under, in which its Registered Representatives (or “Representatives”) are conducting business. Each principal assigned supervisory responsibility has the obligation to ensure that the rules, regulations, and policies applicable to the business of PKS are maintained and followed. This Manual is not to be construed as all inclusive, but rather serves as a guide in conducting the daily supervisory functions. At this time, PKS engages in stocks, bonds, options, and other securities trade execution services and offers variable annuities, retirement plans, margin accounts, money market funds, mutual funds, non-traded REIT’s, structured products, hedge funds, managed futures, direct participation programs, and private placements. The company may in the future offer public offerings. Therefore, these issues have been addressed in this manual in anticipation of the Company offering these services as well as to educate interested Registered Representatives as to the Compliance issues associated with offering these products. PKS, in the conduct of its operations, strives to maintain high standards of commercial and ethical conduct and just and equitable principles in its dealings. The Company is dedicated to serving the best interests of its clients and complying with regulatory requirements. SECTION 1: USE AND DISTRIBUTION OF THIS SUPERVISORY PROCEDURES MANUAL [“SPM”] (Amended 9/2019)

This Supervisory Procedures Manual constitutes the written supervisory procedures of Purshe Kaplan Sterling Investments (“PKS”) and shall be referred to hereafter as “SPM”. The SPM is available to all associated persons of the firm on the Broker’s Resource Home Page, the password- protected portion of the company’s public website. Familiarity with this SPM will reduce errors, avoid losses, and save time. Registered Representatives are required to know how to access the SPM at all times and to be familiar with its content. The SPM implements those rules, regulations and policies that are considered to be most applicable to the day-to-day activities of the Company’s Registered Representatives and other associated persons. It is not all-inclusive of the laws and regulations with which the Firm and its associated persons must comply. Securities are governed by the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, FINRA Rules, MSRB Rules, NFA Rules, and other federal and state laws and rules. These statutes, rules and regulations are quite complex and all Registered Representatives and associated persons are advised to consult the Compliance Department for further clarification. The SPM Committee formed pursuant to SPM Section 2.6 meets on no less than a monthly basis to review and incorporate significant changes to SEC, FINRA, state or in-house policies. In 2010, the SPM Committee began a systematic and ongoing revision of the SPM. The revision process may result in temporary conflict between revised procedures and existing procedures which have not yet undergone review by the SPM Committee. Any and all conflicts between procedural sections in the SPM shall be resolved by reference to the provision containing the most recent revision date. The provisions of this SPM apply to the firm itself as well as its associated persons. As noted above, the SPM provides guidance for implementation of complex regulatory rules applicable to the firm’s operations. However, the complexity of the regulatory environment coupled with the inevitability that unforeseeable circumstances will arise in the course of a securities business make it necessary for the firm to retain some flexibility to make exceptions in limited cases where the best interest of the investor is served. For this reason, the firm reserves the right to fashion individual exceptions from these procedures where such exception is determined to be in the best interest of the investor and is specifically approved and documented by an appropriate Committee or Senior Management. The SPM is the exclusive property of Purshe Kaplan Sterling Investments and, as such, its contents are confidential, and shall not be revealed to any third party without the express written consent of PKS. SECTION 2: SUPERVISORY and COMPLIANCE PERSONNEL For supervisory functions Purshe Kaplan Sterling Investments designates the following appropriately registered Principal(s) with authority to carry out the supervisory responsibilities of

PKS for each type of business in which it engages for which registration as a broker-dealer is required. The Chief Compliance Officer of Purshe Kaplan Sterling is Peter Kvam , who shall serve as the Registered Principal with responsibility for establishing supervisory systems and overall oversight of compliance functions. These include:

COMMUNICATION: Provide instructions as to how to operate within the guidelines. CONFIRMATION: Establish and enforce procedures for checking on activities of

all personnel to determine that the guidelines are being followed. CONSEQUENCES: Determine action to be taken in the event the guidelines are not

followed.

2.1 EXECUTIVE REPRESENTATIVE (Amended 9/2021)

Pursuant to FINRA Requirements, the Company must designate an Executive Representative to whom official FINRA notifications will be sent and who will have responsibility within the Company for notifying applicable personnel.

Executive Representative: Principal, Title: J. Peter Purcell , CEO Principal’s Registration Status: Series 24

Effective date(s) of Designation: Series 24 – October 7, 1989 Series 7 – April 25, 1987 Series 63 – February 5, 1994 Location: Albany, NY

PLEASE NOTE: Each time the Executive Representative is changed, the Company must notify the FINRA Corporate Secretary in writing and amend Form BD on the CRD system. Chief Financial Officer, FinOp Principal, Title: Tracey Bohley, CFO Principal’s Registration Status: Series 27 Effective Date of Designation: August 16, 2021 Series 27 – December 7, 2015 Location: Albany, NY Chief Operating Officer & President Principal, Title: Christopher Motta, COO, President Principal’s Registration Status: Series 24 Effective Date(s) of Designation: November 30, 2020 Series 24 – July 18, 1998 Location: Albany, NY

All PKS Persons In Charge report to the Director of Supervision, or designated Supervising Principal, who in return reports to the Director of Supervision.

(Amended 9/2021) Type of Business:

Mutual Funds: Principal, Title: Ryan D’Antonio, Director of Supervision Principal’s Registration Status: Series 24 Effective Date(s) of Designation: May 12, 2021 Series 24 – October 21, 2011 Location: Albany, NY Commission Recapture Programs: Principal, Title: Tracey Bohley, CFO Principal’s Registration Status: Series 27 Effective Date of Designation: August 16, 2021 Series 27 – December 7, 2015 Location: Albany, NY Program Implementation: January 3, 2006

Variable Product: Principal, Title: Ryan D’Antonio, Director of Supervision Principal’s Registration Status: Series 24 Effective Date(s) of Designation: May 12, 2021 Series 24 – October 21, 2011 Location: Albany, NY

Direct Participation Programs: Principal, Title: Ryan D’Antonio, Director of Supervision Principal’s Registration Status: Series 24 Effective Date(s) of Designation: May 12, 2021 Series 24 – October 21, 2011 Location: Albany, NY Corporate Bonds: Principal, Title: Ryan D’Antonio, Director of Supervision Principal’s Registration Status: Series 24 Effective Date(s) of Designation: May 12, 2021 Series 24 – October 21, 2011 Location: Albany, NY Municipal Securities:

Principal, Title: Stephen Smith, Regional Supervisor Principal’s Registration Status: Series 53 Effective Date(s) of Designation: April 1, 2010 Series 53-March 24, 2010 Location: Albany, NY Options: Principal, Title: Stephen Smith, Regional Supervisor Principal’s Registration Status: Series 24; Series 4 Effective Date(s) of Designation: July 1, 2010 Series 24 –August 27, 2009 Series 4 – June 16, 2010 Location: Albany, NY Managed Futures: Principal, Title: Jason Depasquale, Regional Supervisor Principal’s Registration Status: Series 24; Series 3 Effective Date(s) of Designation: November 20, 2007 Series 24 –April 10, 2006 Series 4 – November 20, 2007 Location: Albany, NY Mortgage Securities: N/A Investment Banking: N/A

(Amended 8/2021) The following individuals are responsible for Home Office and Branch Office supervision:

Home Office Supervisor: Pamela Young Branch Office Supervisor: Ryan D’Antonio, Director of Supervision Principal Responsible for Continuing Education: Peter Kvam, CCO Principal Responsible for Anti-Money Laundering: Peter Kvam, CCO

A list of all PKS Branch Offices and the individual responsible for supervising that office is listed on Form BR. (Amended 8/2021)

The following individuals are the PKS Regional Supervisors who are responsible for conducting required supervisory reviews:

Jason Depasquale

Ryan D’Antonio Rachel Dickinson

Myles Birrittella Pamela Young Daniel O’Neill Stephen Smith Colleen Maron Victoria Wabnig Michael McGrath Modesto Lugo

(Amended 2/2019)

2.2. Government Securities Act Amendments of 1993

Purshe Kaplan Sterling is not a registered Government Securities broker/dealer, and may only sell or purchase treasury securities in the secondary market. However, PKS will abide by the 1993 Amendments to the Securities and Exchange Act of 1934 Rule 15Ca2-1 and file with the Central Registration Depository a Form BD if any change in this status should occur. PKS re-filed its Form BD in 1999, in compliance with Rule 15C2a(3) before the December 15, 1999 deadline. PKS’ status as a wholly-owned subsidiary of PKS Holdings, LLC is disclosed in Schedule A of the Form BD, including information on all partners, directors, and executive officers of the company and their proportional ownership. In the NASD’s NTM 95-48, it states that “In general, the recordkeeping amendments require Section 15C broker/dealers to maintain and preserve records concerning the financial and securities activities of affiliates whose business activities are reasonably likely to have a material impact on the financial or operation condition of the Section 15C broker/dealers.” Although PKS is exempt from this section, the firm will nevertheless abide by this Rule and file any materially important information on the partners, directors, or executive officers, such as bankruptcy, acquisition of another member firm, or affiliation with any other financial institution, such as a bank or insurance company. (Amended 5/2010) 2.3 Audit Committee (Amended 12/2010)

A. Composition of Audit Committee

Pursuant to FINRA Rule 3130, an Audit Committee is hereby established to consist of the following members:

Chief Executive Officer Directors of the Corporation Chief Operating Officer Director of Supervision Chief Compliance Officer Comptroller General Counsel B. Meetings of the Audit Committee (1) Monthly Meetings

The Audit Committee shall meet on a monthly basis, (2) Special Meeting to Review Annual Report Preliminary Draft

No less than 45 days prior to the anniversary date of the prior year certification made by the Chief Executive Officer under FINRA Rule 3130, the Audit Committee shall meet to review and approve the preliminary draft of the Annual Report under FINRA Rule 3130.

(3) Special Meeting to Receive Annual Report in Final Form

Prior to or contemporaneous with certification by the CEO under FINRA Rule 3130, the Audit Committee shall meet to approve the Annual Report under FINRA Rule 3130 in final form.

C. Content of Audit Committee Meetings

The following matters shall be included and addressed in Audit Committee meetings.

(1) Discuss and review the matters that are the subject of the certification;

(2) Discuss and review PKS’ compliance efforts as of the date of such meetings; and

(3) Identify and address significant compliance problems and plans for emerging business areas.

D. Record Keeping

The C

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