BELVOIR WEALTH MANAGEMENT AG

Part 2A of Form ADV hat gelöscht: <Objekt> Information about the qualifica- tions and business practices of Belvoir Wealth Management AG Part 2A of Form ADV Firm Brochure Item 1 Cover Page March 2025 March 24, 2025 Page 1 of 19  Part 2A of Form ADV hat gelöscht: <Objekt> Item 3: Table of Contents Item 1 Cover Page ......................................................................... 1 Belvoir Wealth Management AG Tödistrasse 16 8002 Zurich, Switzerland Item 3: Table of Contents ............................................................... 2 www.belvoirwealth.com Item 2: Material Changes ............................................................... 3 info@belvoirwealth.com Item 4: Business ............................................................................. 3 +41 43 244 7550 Item 5: Fees and Compensation ..................................................... 6 CRD Number 128649 Item 6: Performance-Based Fees and Side-By-Side Management 8 SEC File Number 801-62473 Item 7: Types of Clients .................................................................. 8 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................................................ 8 Item 9: Disciplinary Information .................................................. 13 hat gelöscht: 12 Item 10: Other Financial Industry Activities and Affiliations ....... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................. 14 Item 12 Brokerage Practices ........................................................ 14 Item 13 Review of Client Accounts .............................................. 16 This brochure provides infor- mation about the qualifica- tions and business practices of Belvoir Wealth Manage- ment AG (“BWM”). If you have any questions about the contents of this brochure, please contact us. Item 14 – Client Referrals and Other Compensation ................... 17 hat gelöscht: 16 Item 15 – Custody ........................................................................ 17 Item 16 – Investment Discretion .................................................. 18 hat gelöscht: 17 Item 17 – Voting Client Securities ................................................ 18 Item 18 – Financial Information ................................................... 19 hat gelöscht: 18 The information in this bro- chure has not been approved or verified by the United States Securities and Ex- change Commission (SEC) or by any state securities au- thority. Other Information ........................................................................ 19 hat gelöscht: 18 at BWM is a registered invest- ment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an ad- viser provide you with infor- mation about which you de- termine to hire or retain an infor- adviser. Additional mation about BWM is also available on the SEC’s web- site www.advis- erinfo.sec.gov. Clients and prospective cli- ents should review this bro- chure carefully. March 24, 2025 Page 2 of 19  Item 2: Material Changes This Firm Disclosure Brochure is dated March, 2025. This document is an updated version of our previous Firm Disclosure Brochure dated June 2024. In addition to stylistic and formatting changes, we updated our assets under management under item 4. Because this Item 2 discusses only changes to this Firm Disclosure Brochure that have been made since our last filing, this Firm Disclosure Brochure should be reviewed in its entirety. Pursuant to SEC Rules, we will ensure that clients receive a summary of any material changes to this and subsequent Firm Disclosure Brochure within 120 days of the close of our business’s fiscal year. Addition- ally, as BWM experiences material changes in the future, we will file an updated Firm Disclosure Brochure and send you a copy. Our Firm Disclosure Brochure may be requested by contacting the CCO office at +41 43 244 75 50 or info@belvoirwealth.com Our most recently updated Firm Disclosure Brochure can also be viewed at the SEC’s website https://ad- viserinfo.sec.gov/firm/summary/128649 Item 4: Business BWM was incorporated in Zurich, Switzerland, on March 1st, 2004. BWM is a minority and woman owned firm. BWM provides investment services to individuals, trusts, estates, charitable organizations and other enti- ties that are “U.S. persons,” as defined by the U.S. Internal Revenue Code of 1986, as amended. This def- inition could include U.S. citizens and permanent U.S. residents. On a limited basis, we serve so-called offshore clients, i.e., non-US trusts, non-US foundations, non-US partnerships, non-operating non-US companies and non-US insurance companies where the ultimate ben- eficial owner(s), policy holder and/or beneficiary is/are a natural person(s) who is/are subject to US fed- eral income tax as described above. The company is registered with the SEC. BWM is also a FINMA authorized asset manager in Switzerland. Simultaneously the firm is a member of the Association of Swiss Asset Managers. Types of advisory services offered Discretionary Portfolio Management Agreement (DA) The Discretionary Portfolio Agreement (DA) requires BWM to conduct due diligence, suitable investments and manage the client’s investment portfolio with full discretion. BWM offers clients Investment Management Services that encompass the traditional asset classes of fixed income, Swiss and European equities, but can also include alternative asset classes as well. The Firm will manage a client’s investment portfolio on a discretionary basis, and may assist the client in the establish- ment of the necessary custodial account(s). When exercising its discretionary authority, BWM will make appropriate "buy, sell, hold" decisions as it believes they are needed using the Firm’s asset allocation methodology. Through the use of an asset allocation approach, the Firm provides Investment Manage- ment Services based on a personalized understanding of each client’s independent investment objectives. BWM’s Investment Management Services typically begin through the gathering of information vis-à-vis a new Investment Policy Statement, or other similar documentation process. Based upon this information, the Firm selects the appropriate allocation for the client’s assets. The Firm employs a defined process for each step in the investment management cycle including goal setting and risk/return profiling, asset allo- cation modeling, investment selection and implementation, and ongoing monitoring and reporting. This March 25 Page 3 of 19  approach helps to provide a robust process to provide long-term investment solutions. Depending upon the strategy selected by the Firm and the client, BWM may invest client assets in various sectors and securities, including but not limited to: mutual funds, Exchange Traded Funds (“ETFs”), stocks, bonds, treasuries, private funds and/or real estate investment trusts ("REITs"). Please refer to Item 8 for more information on BWM’s investment strategies, methods of analysis and their associated risks of loss. As noted above, BWM manages client assets on a fully discretionary basis. In exercising full discretionary authority, BWM selects, without first obtaining client’s permission, (1) the securities to be bought and sold; and (2) the amounts of securities to be transacted and whether it will be individually or block traded. BWMs discretionary authority may be subject to conditions imposed by a client. This may occur when a client restricts or prohibits transactions in a security for a specific company or for an industry sector. For more information on the Firm’s discretionary authority and brokerage practices please refer to Items 12 and 16. Clients are allowed to impose reasonable restrictions on the types of securities, sectors and/or industries they do not want to be included in their portfolio. Such restrictions must be communicated to the Firm in advance and documented in writing. Once this information is gathered initially, each client is responsible for informing BWM in writing of any changes to these restrictions or to their overall invest- ment objectives. The Firm does not assume any responsibility for the accuracy of the information provided directly by its clients or the failure of clients to inform the Firm of changes to their investment or financial objectives. Advisory Portfolio Agreement (AA) The non-discretionary Advisory Portfolio Agreement (AA) require BWM to provide suitable investment advice and recommendations, however the client takes the investment decision himself. BWM shall provide the Client on request with financial market information, analyses etc. for investment decision making purposes. The advice shall be provided at the Clients request only. BWM advises/recom- mends, within the framework of the investment strategy defined, investments to the Client, which the Client may reject or accept by giving specific investment instructions to BWM. The Client acknowledges that BWM is an SEC registered investment adviser, but is not registered as a broker-dealer. Therefore, BWM will provide investment advice before any investment takes place in the account. BWM will not perform execution only transaction and will not give unsolicited investment advice. BWM has no custody or possession of client’s assets, instead all assets reside with the Custodian chosen by the Client. BWM will advise the Client in accordance with the Client Investment and Risk Profile, how- ever, the Client is free to select any investments he may choose, and any investment decisions in respect of the Client’s portfolio are strictly the Client’s responsibility. It should be expressly noted that BWM is not entering into a discretionary mandate and is not entitled to take investment decisions or carry out any investment management activities, as the Client is solely responsible for making investment decisions. General information BWM does not accept custody of clients’ funds or securities. Client’s assets are held at the Custodian financial institution, depository bank or brokerage firm selected by the client. BWM buys and sells finan- cial instruments under the authority of a limited power of attorney based on an agreed investment profile. The Investment profile is based on the client’s financial situation, needs, and goals and the risk a client can take based on the information provided to ensure to set up a suitable investment strategy as de- scribed above. As explained above, Investment Management Services provided by BWM customizable based upon the individual needs, objectives, and other financial goals of the client. There may be times when certain re- strictions are placed by a client which prevent the Firm from accepting or continuing to service the client’s March 25 Page 4 of 19  account. BWM reserves the right to not accept and/or terminate a client’s account if it feels that the client-imposed restrictions would limit or prevent it from meeting and/or maintaining its objectives. BWM will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other profes- sionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies the Firm of changes in the client’s financial circumstances, BWM will review such changes and may recommend revisions to the client’s portfolio. BWM is held to a fiduciary standard that covers our entire relationship with our clients. As a fiduciary, it is BWM’s duty to always act in the client’s best interest. We are required to identify and eliminate conflicts of interest, or disclose them clearly and understandably to clients, so that a client may decide whether they consent to the conflict Past performance and/or behavior is no guarantee of future performance and/or behavior, but generally our strategies are all subject to conditions agreed upon in the Agreement with the client. The investment strategy will be amended and updated based on information provided by the client. Assets under Management On February 28th, 2025 BWM had USD 286’782’091 in assets under management. The AuM on a discre- tionary basis were USD 141'162'035 and USD 145'620'056 on a non-discretionary, advisory basis. The Asset Management Agreement Prior to engaging BWM to provide investment advisory services, the client will be required to enter into a written Asset Management Agreement (“Agreement”) with the firm setting forth the fees to be charged and the terms and conditions under which it will render its services. The Agreement becomes effective with the acceptance thereof by the client, and BWM. The firm will provide a Brochure and one or more Brochure Supplements to each client or prospective client prior or in parallel with the execution of the Agreement. The agreement begins as of the date of signature, is for an indefinite period, and can be ter- minated in writing by either party any time. The fees shall be charged on a pro rata basis. The agreement and the limited power of attorney do not terminate with the Client’s death, missing person declaration or with the Client’s legal incapacity to act. The limited power of attorney remains in effect until terminated by the heirs, respectively the legal representative in accordance with the terms of this contract. In case of more than one heir or administrator of a will, BWM is obligated to correspond with only one empowered heir or one administrator of a will. The client’s custodian will require the client to designate a “Reference Currency”, which is the currency in which investment performance is measured. If BWM receives written notification that the client waives Qualified Investor status as defined by the Swiss Collective Investment Schemes (“CISA”) and Ordinance on Collective Investment Schemes (“CISO”) the Asset Management Agreement is terminated as of that date. Termination shall not result in the inter- ruption of ongoing transactions. As of the effective date of termination of the Client Agreement, BWM will have no obligation or authority to recommend or take any action with regard to the previously man- aged assets. The client will bear the sole responsibility to work with the applicable custodian for proper liquidation and/or management of the client’s assets upon termination. The client should be aware that for certain types of securities legal and regulatory restrictions of the custodian could complicate liquida- tion and/or management of the client’s assets, which the client should discuss with his or her Investment Advisor prior to termination in order to mitigate associated risks. March 25 Page 5 of 19  The Agreement may not be assigned, as such term is defined in the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”), to any third party by either the Client or BWM without the written con- sent of the other party. Item 5: Fees and Compensation Wrap-Fee Program BWM does not provide portfolio management services to any wrap fee programs, as the term is defined in the instructions to Form ADV Part 2. Fees for Investment Management Services Prior to engaging BWM to provide advisory services, the client will be required to enter into a written Agreement with the Firm setting forth the terms and conditions and the fees under which it will render its services. Fees may be subject to negotiation under certain circumstances as agreed on by the Firm and the client. The following schedule of fees outlines the typical fee structure under which BWM provides its services. The actual schedule of fees, as it applies to a particular client, will be clearly outlined in the Agreement. Clients pay an annualized quarterly advisory fee as a percentage in arrears as of the close of business on the last business day of the proceeding calendar quarter based on the average total market value (in Reference Currency) of the client’s assets under BWM’s management (as reasonably determined by the custodian or other independent third party ) and held with the applicable custodian (total assets including all securities, fiduciary deposits, and precious metals, other assets, and cash positions). BWM calculates the value of the assets in client’s accounts by averaging the asset values that are calcu- lated by the client’s custodian for the last day of each of the three months preceding the month of pay- ment. For example, the first quarterly payment to BWM each year, paid in April, would be the average of the values set on the last day of January, February and March. No fees are deducted in advance. Following the end of the quarter, BWM will request the custodian to debit the applicable portion of the annual fee in the reference Currency chosen from the client’s account and to credit this amount BWM’s account. BWM generally does not accept check payment. The client’s custodian will issue account statements at least quarterly that reflect this deduction of invest- ment advisory fees. Clients are encouraged to review the statements for accuracy and promptly inform BWM of any discrepancies. Management Fee Schedules for Discretionary and Advisory Portfolio Agreements The management fee schedule for Discretionary and Advisory Portfolio Agreements are set forth below: Discretionary Portfolio Agreement 1.00% p.a. Advisory Portfolio Agreement 1.10% p.a. Minimum fee — For Assets under Management less than USD 1 Million, a minimum fee of USD 2’500 per quarter applies (the “Minimum Fee”). The Minimum Fee will continue until Assets under Management increases above $1 Million at which time the Percentage of the fee schedule above applies. All investment advisory fee schedules are current at the time of publication, but BWM can adjust both the investment advisory fee schedules and related minimum annual fees at any time without notice to clients Each BWM client should contact their Investment Advisor if there are any questions regarding the exact margins or fees that are applicable to foreign exchange, precious metal, or other transactions, as well as any other supplementary services or third-party fees charged by the custodians or brokers. March 25 Page 6 of 19  Other Fees and Expenses Clients should be aware that they will be responsible for all fees imposed by the custodian for trading and other related costs, which can include but not be limited to brokerage commissions, transaction costs, custodian fees, transfer fees, redemption fees on short-term investments, cashiering fees and/or taxes or penalties levied by governmental authorities. In addition, BWM may invests in open-end mutual funds and exchange traded funds in client portfolios. These funds charge fees to their shareholders, which are described in their respective prospectus and usually include a management fee, administrative and operations fees, and certain distribution fees (e.g., 12b-1 fees). These fees are generally referred to as a fund’s “expense ratio” and the fees are deducted at the mutual fund level when calculating the fund’s net asset value (“NAV”) and have a direct bearing on the fund’s performance. Certain mutual funds also charge an up-front or back-end sales charge and and/or redemption fees. In addition, some open-end mutual funds offer different share classes of the same fund and one share-class can have a higher expense ratio and sales/redemption fees than another share class. The most economical share class will depend on certain factors, including the amount of time the shares are held by a client and the amount a client will be investing. Mutual fund expense ratios and sales/re- demption fees vary by fund, so it is important for clients to read the mutual fund prospectus to fully un- derstand all the fees charged. BWM strives to purchase, when available, the lowest cost mutual fund share class for clients. However, there may be times, when BWM does not select the lower costs share classes. This mainly happens when the client’s custodian does not offer a lower cost share class for some or all of the mutual funds bought for and/or held in clients’ accounts, or the investment amount does not meet the share class minimum investment requirement, or BWM has determined that a fund with higher expenses is more beneficial for the client. Transaction fees also play an important role in the overall costs when investing in mutual funds. For ex- ample, some broker-dealers will not charge a transaction-based fee on a mutual fund trade, but will charge a flat “penalty” fee if the shares are sold within a short-term time period. Other fees a client can incur include, but are not limited to, custodian fees, brokerage commissions, trans- action fees, sub-advisor fees, cashiering fees and/or taxes/penalties levied by governmental authorities. BWM does not receive any portion of these fees or expenses and seeks to negotiate and minimize these fees wherever possible. When managing clients’ assets, we take into consideration the overall costs to a client, and we strive to make transaction decisions that are the most economical for a client based on the then prevailing facts and circumstances. However, in some situations such as with unexpected cash needs or avoiding capital gain distributions, fees such as short-term redemption fees can be incurred. In these situations, BWM will endeavor to only incur these fees when it is determined to be beneficial to the client. All fees paid to BWM for its services are separate and distinct from the fees and expenses outlined above. Importantly, all the fees charged to a client’s account lowers the overall performance of the account. Therefore, clients should review all applicable direct and indirect fees charged, including but not limited to custodian fees, transaction fees, fees associated with investments (e.g., mutual funds and ETFs), and advisory fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Fees charged by third parties (i.e., custodian, broker, etc.) are not covered by the above-mentioned fees and are part of the contracts and agreements the client has with their respective custodian. Termination of services If either BWM or the client terminate the Client Agreement, the portion of the investment advisory fee due will be calculated up to the date of termination. March 25 Page 7 of 19  No compensation for sale of securities BWM is not registered as a securities broker/dealer and therefore does not accept compensation for the sale of securities or other investment products. Item 12 further describes the factors that BWM considers in selecting broker-dealers for client transac- tions and determining the reasonableness of their compensation (e.g., commissions). Item 6: Performance-Based Fees and Side-By-Side Management BWM 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). Consequently, BWM does not engage in side-by-side management of accounts that are charged a performance-based fee with accounts that are charged another type of fee (such as fees based on the client’s assets under manage- ment). As described above, BWM provides its services for a fixed fee, or based upon a percentage of assets under management. Item 7: Types of Clients BWM specializes in customized asset management services to high-net-worth and ultra-high-net-worth individuals, institutions, corporations, foundations and trusts, estates and other legal entities who are “accredited investors” as defined in Rule 506 of Regulation D, or “Qualified Investors” as defined by CISA and CISO. Generally, these individuals, trusts, estates, charitable organizations and other entities are “U.S. persons,” as defined by the U.S. Internal Revenue Code, or individuals otherwise residing in the U.S. This definition could include, among others, U.S. citizens and permanent U.S. residents. In appropriate circum- stances, BWM also provides advisory services to non-U.S. persons and may serve as a subadvisor for cer- tain pooled investment vehicles. BWM’s investment discretionary advisory service is only available for Discretionary Portfolio Agreements for accounts with a minimum value of USD 1 million. The minimum value for accounts for the Advisory Portfolio Agreement is USD $2 million. BWM reserves the right in its sole discretion to accept a client where the minimum investment amount is not met. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The investment committee of BWM discusses and agrees on macro and market views and formulates investment views. Derived from these investment views model portfolios are constructed. Each model portfolio is a combination of top-down investment views and bottom-up investment selection. To formu- late these investment views BWM uses internal as well as external research sources, containing infor- mation such as general economic conditions, industry and specific security research, market data and other information. The sources of research and information that we use include:  financial publications  corporate earnings calls  company press releases and securities filings  rating services  regulatory and self-regulatory reports  third-party data providers and research consultants  outside consultants, experts and other professionals  Other public sources. March 25 Page 8 of 19  The information covers, among other things, general economic conditions, industries, groups of securities and specific securities, market data, political developments, pricing and appraisal services, credit analysis, risk measurement analysis and other information that may affect the economy and industries. Model as well as client portfolios may include various instruments such as equity securities, debt securi- ties, commercial papers, mutual funds, ETF shares, precious metals and alternative investments. BWM generally focuses on liquid, exchange traded investments. Yet, clients should keep in mind that all types of investments in financial instruments carry risks of loss (see below). Investment Strategies Client investment objectives, guidelines and restrictions are the basis of each client’s risk profile (including information on the individual risk tolerance) which is part of the signed Asset Management Agreement. Global Multi Asset Class Balanced Strategy: Including but not limited to equities, debt securities as well as funds and ETFs investing in equities, bonds, or commodities. Global Multi Asset Class Growth Strategy: Including but not limited to equities, debt securities as well as funds and ETFs investing in equities, bonds, or commodities. Swiss Centric Strategy: Focus mainly on Swiss mid-cap companies Euro Area Centric Strategy: Focus mainly on Euro area large cap companies Important note on investment instruments available to non-discretionary clients: Additionally, due to our obligations under the Swiss Financial Services Act (FinSA), as a Swiss based financial service provider, we are obligated to provide you with a “Key Information Document” when advising you on the purchase of – among others – Funds. As US registered Funds generally do not produce such documents or and their equivalent, for regulatory reasons BWM will not be able to advise proactively on the purchase of ETFs and Mutual Funds unless you decide to be classified as “professional client” on the basis of your wealth and experience. If you wish to be advised on the purchase of ETFs and Mutual Funds, you can do so by entering into a Managed Program with BWM or by “opting-out” to a professional client status (see section 5.2 for additional information about the client classification under Swiss regulation). Risk of Loss Investing in financial instruments including securities involves a risk of financial loss that clients should be prepared to bear. Raising the awareness for this risk and discussing the factors that can potentially lead to financial loss is a key consideration when looking at investment opportunities with clients or prospects. The selection of an appropriate investment strategy –from more conservative to average and higher risk– must fit the client’s personal risk profile and investment objectives. Each such strategy involves invest- ment in a certain type or types of securities, each of which have their own risks. Depending on the specific investments held within the client’s account, a client could face risks including, but not limited to, the following:  Market Risk: Due to general economic and market conditions, the market price of securities will go up or down, sometimes rapidly or unpredictably, and can lead clients to lose up to their entire invest- ment. Factors affecting market risk include interest rates, availability of credit, inflation rates, com- modity prices, economic uncertainty, changes in laws and national and international political circum- stances. Market risk exists in all types of investments.  Liquidity Risk: – The risk of not being able to buy or sell a security due to low trading volume (low liquidity). Therefore, an illiquid asset can reduce returns because the investor is not able to sell it at the time desired for an acceptable price, or is not able to sell it at all. This can be especially the case March 25 Page 9 of 19  for fixed income securities or securities of companies with a smaller market capitalization (“small- caps”), and the value of strategies that purchase these securities may rise and fall substantially, es- pecially during periods of crisis or stress in markets.  Less Accurate Valuation: The absence of a liquid market for securities traded over-the-counter, or derivatives, increases the likelihood that the custodian will not be able to correctly value of clients’ interests in certain funds.  Interest Rate Risk: Fixed income securities fluctuate in value as interest rates change. The general rule is that if interest rates rise, the market prices of fixed income securities will generally decrease. On the other hand, if rates fall, the value of fixed income securities will generally increase. The market value of fixed income securities with longer maturities (or funds holding fixed income securities with longer average maturities) will typically be more sensitive to changes in interest rates and is likely to fluctuate in response to a change to a greater degree than the market value of fixed income securities (or funds, as above) with shorter maturities.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Credit/Counterparty Risk: The risk that the issuer or guarantor of a fixed income security, a bank, or the counterparty of a structured product or a derivative contract will default on its obligation to pay interest and/or principal, or go bankrupt, which could cause an investor to suffer a total or partial loss.  High Yield Risk: Lower-quality debt securities as rated by the major credit rating agencies (those of less than investment grade quality, commonly known as “high yield bonds” or “junk bonds”) are risk- ier, speculative and involve greater risk of default.  Foreign/Emerging Markets: Foreign securities may involve the risk of loss due to political, economic, regulatory, and operational uncertainties, currency fluctuations, and generally higher credit risk for foreign issuers. Clients should be aware that all of these risks might be heightened in Emerging Mar- kets.  Currency Risk: A client’s account can be invested in securities and other investments that are denom- inated in currencies other than the client’s domestic (home) currency. Accordingly, fluctuations in currency exchange rates affect the value of such assets favorably or unfavorably. Currency exchange rates can be extremely volatile, particularly during times of political or economic unrest or because of actions taken by central banks (the intention of which could be to affect prevailing exchange rates). Each strategy under consideration must be reviewed for the currency risk, i.e., the risk (or oppor- tunity) for additional financial loss (or profit) depending on how much of the investments will occur in the client’s domestic versus foreign currency and the rate of the foreign currencies relative to the client’s domestic currency. In addition, the client may have selected a “Reporting Currency” for their account that is different from their domestic currency. The client’s account values as set out in the quarterly or periodic statement of assets reflect this Reporting Currency. When the client selects a Reporting Currency other than their domestic currency, then for purposes of calculating the account’s performance all of the assets in the client’s BWM portfolio are converted to the selected Reporting Currency. Fluctuations in the exchange rate between the selected Reporting Currency and the client’s domestic currency could mean that the performance shown in the account statements (in the Re- porting Currency) is higher or lower than the actual performance of the account in the client’s do- mestic currency.  Political and Legislative Risks: Companies face a complex set of laws and circumstances in each coun- try in which they operate. The political and legal environment can change rapidly and without warn- ing, with significant impact, especially for companies operating outside of the United States. March 25 Page 10 of 19   Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securi- ties.  Risks Related to Equity Investments: Investments in equity securities generally involve a high degree of risk. Prices are volatile and market movements are difficult to predict. These price movements may result from factors affecting individual companies or industries. Price changes may be temporary or last for extended periods. The value of specific equity investments correlates to the fundamentals of each particular security, and prices of equity investments may fall or fail to appreciate regardless of movements in securities markets.  Bulk Risk: The risk of being invested in a single security or issuer is considered and while BWM in general seeks diversification, there is no assurance that this will mitigate or eliminate the risk of loss in every market environment.  Transfer Risk: There is also a risk that a creditor will not be able to exchange a local currency into a foreign currency, and so be unable to make debt-service payments in foreign currency, for example, from exchange restrictions imposed by the government of the creditor’s country.  Small and Mid-Cap Equities Market Risk: The small and mid-cap market segments consist of a greater number of companies, are generally less transparent, are covered by fewer analysts, have less market liquidity than companies with larger market capitalizations and may be prone to higher price fluctu- ations than the large cap market segment.  Geographic and Sector Risk: The same applies as stated under bulk risk, where there are risk-concen- trating investments in geographic regions or business or industry sectors. While BWM generally seeks geographic and sector diversification, there is no assurance that this will mitigate or eliminate risk of loss. In addition, certain strategies necessarily require concentration in a geographic region, and those client accounts invested in accordance with that strategy will be subject to increased risk associated with that region.  Concentration Risk: Certain investment strategies or accounts may be more highly concentrated in certain market segments or in the securities of certain companies than other strategies, though these strategies or accounts will still adhere to the same general investment objectives. Concentration in certain market segments or companies may lead to an increased risk of loss due to lack of diversifi- cation. Concentration also may result in higher volatility. Concentration tends to exacerbate the risks described above.  Risk Related to Derivatives and Leverage: Certain investment instruments such as derivatives may use leverage to achieve returns. The use of leverage could disproportionately increase an account’s ex- posure 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 in general magnifies both the positive impact of successful investment decisions and the negative impact of unsuccessful investment decisions on an account’s performance.  Commodity Risk: Commodity prices can be very volatile and show significant fluctuations over short periods. With the exception of precious metals, BWM does not invest in physical commodities (alt- hough BWM does invest in certain exchange traded products that may be backed by physical com- modities or commodity futures).  Custodian Risk: At the custodian level the two key risks are the risk of the custodian becoming insol- vent and the risk of loss through custodian. All assets other than cash are held by custodians in nom- inee accounts or in the name of the client itself. BWM strives to mitigate the above risks by monitoring, among others, markets, economic conditions, industries and changes to the general outlook on corporate earnings, regulatory developments, and mon- March 25 Page 11 of 19  etary policy by Central Banks, changes to interest or currency rates or adverse investor sentiment in gen- eral. There is no assurance that any investment risk mitigation efforts, or any hedging strategies, under- taken by BWM will be successful or otherwise eliminate the relevant risk. Further, there is no assurance that you will achieve your stated investment objective. Different financial instruments involve different levels of exposure to risk and may therefore be inappro- priate to the client’s circumstances or risk appetite. Additional product and risk disclosures are provided when investments are made. Portfolio manager selection and evaluation BWM employees provide all investment advisory services for the Advisory Agreement Mandates and there are no external investment advisers or portfolio managers and no affiliates that act as investment adviser or portfolio manager for BWM clients in the context for these clients. In certain appropriate cir- cumstances and with client arrangements outside of the regular Agreement, BWM may utilize the services of selected third-party sub-advisors. In these limited circumstances, BWM will conduct due diligence reviews of the selected third-party sub- advisors, or rely on due diligence performed by its affiliates or qualified third parties. BWM requires employees to meet minimum educational, experience and industry standards set forth by the applicable regulatory authorities. Investment Advisors and Investment Managers are generally re- quired to have a bachelor of science, obtain any necessary industry licenses, equivalent designations, or training. These general requirements can be waived, as deemed appropriate, based on, among other things, years of relevant industry experience and assets under management. Investment Committee BWM has an investment committee (the “Investment Committee”) that is responsible for overseeing the prudent management of BWM’s client assets. The Investment Committee is comprised of the Senior In- vestment Managers, as well as certain senior members of BWM, including the Chief Executive Officer. The Investment Committee meets on a monthly basis with interim meetings as necessary to discuss in general terms allocation within each investment strategy, securities selection, risk management, overall investment strategy, and performance. The Investment Committee may also invite others to serve as ad- visors or consultants to the Investment Committee. BWM’s Investment Committee agrees on macro and market environment views, and formulates BWM’s investment outlook. Taking into account the overall investment views and strategic asset allocations for the various investment strategies, the Investment Committee delegates determination of the tactical as- set allocation for each investment strategy and portfolio construction to one or more members of the Investment Management Team. The delegated employee(s) implement the investment views in Model Portfolios, as well as individual client accounts (taking into consideration any specific client guideline re- quirements), and transmit orders to BWM’s relevant broker-dealers for execution and clearance. Risk and Oversight Committee BWM has established a risk and oversight committee (the “Risk and Oversight Committee”), which is led by the Chief Executive Officer. The Risk and Oversight Committee meets regularly, generally on a monthly basis, to review and as necessary to resolve and approve, among other things:  Any compliance risks and issues that have arisen, including but not limited to Code of Ethics violations;  Investment management issues and operational risks, including best execution and evaluation of the broker relationships, as well as any trading issues related to trade errors;  Client related issues, including the onboarding of new client accounts, client complaints, and annual review of client accounts; March 25 Page 12 of 19   Performance of portfolios;  Valuations issues;  Service provider arrangements, including any operational issues; and  Business risk management issues.  the nature and cause of the error,  whether the client has been disadvantaged by the error, and  Suitability of the allocations resulting from an error. Unsuitable trades will always be resolved in the client’s favor (see below for further information on BWM’s trade error procedures). Item 9: Disciplinary Information Form ADV Part 2A requires Registered Investment Advisers, like BWM, to disclose legal or disciplinary events involving the firm or BWM employees that are material to the client’s evaluation of BWM business or integrity of BWM’s management. As of the date of this Firm Disclosure Brochure publication, BWM has no information to report that is applicable to this item. BWM also completes a Form ADV Part 1, which contains additional information about its business and its affiliates, including legal or disciplinary events. This document is filed with the SEC and is publicly available through the SEC’s website: www.advis- erinfo.sec.gov Item 10: Other Financial Industry Activities and Affiliations BWM is a member of the AOOS (www.aoos.ch), a Swiss self-regulatory organization recognized by the Swiss Financial Market Supervisory Authority (“FINMA”) (www.finma.ch). Affiliates BWM’s affiliate company, Belvoir Capital AG is a Swiss financial services organization and both licensed and supervised in Switzerland by FINMA. Belvoir Capital AG business lines range from private banking and wealth management, to developing and distributing investment products and serving as investment man- agers, administrators, distributors, placement agents and/or transfer agents for privately placed funds, funds of funds and mutual funds, structured products and other products or services. BWM is independent of Belvoir Capital AG and does not receive referrals, or provide referrals or have any business dealings with Belvoir Capital AG regarding its financial advisory business. Certain directors and members of Belvoir Capital AG’s executive management serve on the board of directors of BWM. Neither BWM, 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. Other than Belvoir Capital AG 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, ac- counting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. BWM 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 mate- rial conflict of interest. Custodians BWM maintains a custodial or service agreement with third party independent custodians. Factors which BWM considers in recommending Custodian(s) include but are not limited to their financial strength, rep- utation, competitive pricing and range of services including its ability to offer our international clients a multi-currency platform. March 25 Page 13 of 19  The Custodian(s) and Custodian’s platforms provide BWM with certain benefits including custody, clearing and reporting services, online access to client accounts, access to an institutional trading desk, and access to a wide range of investment products and services they make available to us that assist BWM in moni- toring and/or servicing client accounts for which we would otherwise have to pay. These services may include investment-related research, pricing information and market data, marketing support, invitations to educational conferences and events, or other economic benefits useful to BWM in providing invest- ment advisory services to clients. The receipt of economic benefits from the Custodian(s), brokers or other service providers creates a po- tential conflict of interest and an incentive for BWM to recommend a Custodian, broker or service pro- vider to increase assets at the Custodian in order to decrease its expenses, or direct business to a broker or service provider in order to receive these benefits. Clients are not obligated to use the services of any Custodian, broker or service provider we suggest and may select a custodian, broker or service provider of their choice provided that the Custodian, broker or service provider undergoes BWM’s due diligence. Clients should be aware that the commissions, transaction and other fees charged by the Custodian, bro- ker or service provider may be higher or lower than those charged by other Financial Institutions. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading BWM strives to adhere to certain standards of conduct based on principles of professionalism, integrity, honesty and trust, and has adopted a Code of Ethics (“Code”) under Advisers Act Rule 204A–1, the Swiss Banking Code of Conduct (CDB 16), and the code of conduct of OAR-G to help BWM meet these standards and prevent conflicts of interest. Certain BWM employees and employee-related accounts (referred to as Access Persons) must comply with the Code, which contains general ethical principles and personal secu- rities reporting provisions for BWM Access Persons. In summary, the Code prohibits employees of BWM from taking inappropriate advantage of their position and the access to information concerning the in- vestments or investment intentions of BWM on behalf of its clients, or their ability to influence such in- vestment intentions, for personal gain or in a manner detrimental to the interest of its clients. BWM expressly prohibits any employee from profiting at the expense of BWM clients and from competing with its clients. The BWM Code of Ethics, Policies and Procedures Manual, and compliance policies and procedures adopted by BWM contain among others the following provisions to handle conflicts of interest:  Each Access Person of BWM obtains pre-trade approval for transactions (both for certain securities or investments in private placements and initial public offerings) and submits quarterly reports of transactions and securities holdings.  BWM maintains records of all securities holdings for clients and Access Persons.  No individual shall cause or attempt to cause any BWM client to purchase, sell or hold any interest in a security in a manner calculated to create any personal benefit or benefit for any Access Person account. Each employee receives annual compliance training and must acknowledge the BWM’s policies and pro- cedures with respect to the Code of Ethics on an annual basis. Item 12 Brokerage Practices Clients will authorize BWM to transmit trades through the custodian’s brokers, or other brokers selected by BWM. BWM believes that in certain circumstances using the custodian’s broker relationships is in the best interests of its clients. The executing brokers may act on an agency or riskless principal basis for a March 25 Page 14 of 19  variety of securities and other investments. BWM will periodically evaluate the quality and cost of execu- tion services received. BWM will consider the quality and cost of services available from alternative bro- kers, market makers, and market centers. Regardless of the broker used, BWM has an obligation to seek “best execution” for client transactions. The SEC defines best execution as the “best qualitative execution” not necessarily the lowest possible execution cost. In evaluating the quality of execution, BWM considers various factors, such as execution capability, commission rate (or spread), financial responsibility and responsiveness. BWM’s best execution policies generally provide that in evaluating best execution and the reasonableness of broker commissions, the determinant factor is not only the lowest possible commission cost, but also whether the transaction represents the best qualitative execution, taking into consideration many factors. These factors include, among other things, the full range of a broker’s services such as (1) the value of research provided (if any), (2) execution capabilities in international markets block positioning, (3) the institution’s financial strength, stability, reputation and soundness, (4) ability to maintain confidentiality, (5) adequate settlement/delivery capabilities, (6) ability to obtain best price by querying many markets and using smart routers, (7) commission rates, and (8) responsiveness. BWM may also consider the quality of research or assistance provided in evaluating certain investments, industries or products. Certain trans- actions involve specialized services that justify paying higher commissions or their equivalents. BWM does not have authority to negotiate commissions on behalf of BWM’s clients on a trade-by-trade basis; rather, the custodian or executing broker determines these costs. Although the custodian(s) or executing bro- ker(s) will generally seek competitive commission rates, they are not obligated to choose the broker of- fering the lowest available commission rate if, in their reasonable judgment, a higher commission is justi- fied by services provided by the broker, or other considerations, such as those set forth above. Research and Other Soft Dollar Benefits In a soft dollar arrangement, an adviser will direct client transactions to certain brokers that have agreed to provide the adviser with research, or other investment products and/or services that assist the adviser in its investment decision-making process. Those brokers may charge those clients higher trading fees. Advisers and brokers entering into such arrangements are required to comply with the “safe harbor” guid- ance in Section 28(e) of the Securities Exchange Act of 1934, regarding the permissible use of soft dollars. BWM does not receive research and other products or services from soft dollar arrangements. BWM receives research from certain brokers and uses this research to manage client portfolios. Some brokers allocate a portion of the commission paid by BWM’s clients to fund the cost of this research, as permitted by Section 28(e) of the Securities Exchange Act of 1934 (“soft dollars”). Section 28(e) generally provides that a person who exercises investment discretion with respect to an account, such as BWM, is not in breach of a fiduciary duty under federal or state law solely by paying more than the lowest available commission if such person determines in good faith that the amount of commission is reasonable in rela- tion to the value of the brokerage and research services provided. BWM has not entered into any other third-party soft dollar arrangements, although BWM may do so at any time in compliance with the SEC’s guidance regarding permissible soft dollar arrangements. The Cus- todian(s) may have such arrangements directly with third-party brokers to which BWM is not a party. In formulating investment advice, BWM may rely on various sources of information, including third-party research materials, corporate rating services, company press releases, annual reports, prospectuses, fil- ings with the SEC, Thomson Reuters and other financial networks. On occasion, BWM’s Investment Man- agers attend conferences organized by external research firms on various industries or markets. To the extent BWM uses research, or receives soft dollars, it will use these to benefit all clients. BWM formulates its own investment advice and recommendations for its clients. March 25 Page 15 of 19  Brokerage for Client Referrals BWM does not receive client referrals from external brokers, dealers or financial intermediaries in ex- change for brokerage. Trade Aggregation BWM strives to aggregate trades for DA program accounts. However, such aggregation is not mandatory and is made at BWM’s discretion. Aggregation of trades is a method that seeks to increase the consistency in the execution process and support the quality and cost of execution, by aggregating multiple transac- tions into one order. Clients with the same investment strategy having their portfolio at the same custo- dian will be part of order aggregation. Any order emanating from a change in the respective model port- folio will be aggregated per custodian. Each client that participates in an aggregated order participates at the average price. In case of partial execution of an aggregated order, BWM allocates the executed trades on a pro rata basis, as applicable. Should the pro rata allocation lead to uneconomical or unsuitable re- sults, or in the case of securities issued by specific lots, BWM shall modify the allocation. In aggregating orders and allocating such orders, BWM seeks fairness among BWM’s clients over time. Allocation of Investment Opportunities From time to time, two or more accounts may seek to invest in the same securities or pursue a similar strategy. In such cases, BWM seeks to ensure that one account or group of accounts is not favored or preferred over another account or group of accounts. BWM strives to be sensitive to this potential conflict of interest where a particular investment opportunity has limited availability, such as IPOs or new/ sub- sequent issues. Trade Errors From time to time, BWM may make an error in submitting a trade order on a client’s behalf. BWM’s policy and practice is to monitor and reconcile all trading activity, identify and resolve any trade errors promptly, to document each trade error with appropriate supervisory and oversight approval, and to maintain a trade error file. Pursuant to this trade error policy, BWM strives to correct and otherwise resolve trade errors in a manner to make the client whole. The client may retain gains resulting from an error that has affected the client’s account. The Risk and Oversight Committee will review, with regard to trade errors, the facts surrounding each circumstance to determine the root cause of the error. The Risk and Oversight Committee will consider  the nature and cause of the error,  whether the client has been disadvantaged by the error, and  Suitability of the allocations resulting from an error.  Trade errors will always be resolved in the client’s favor. Item 13 Review of Client Accounts BWM’s managed accounts are reviewed on an ongoing basis, with regard to the overall asset allocation of the portfolio and in light of the client’s Investment Policy Statement. Reviews are conducted by BWM’s professional staff, all of whom are Supervised Persons. Reasons for review 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 Policy Statement. Triggers for investment reviews include:  Deposits or withdrawals March 25 Page 16 of 19   Changes in the Firm’s investments as determined by the investment committee depending on market conditions  Changes in the client’s personal and financial situation or in the client’s objectives  Re-balancing of accounts.  Clients risk profile and check whether the existing strategy chosen by the client is still appropriate in light of the client’s current circumstances and/or risk appetite  Client meeting On a periodic and ad hoc basis, the BWM Chief Compliance Officer and other compliance and senior man- agement personnel perform reviews of client relationships. Such reviews are either pursuant to BWM’s internal policies and procedures, which require conducting checks on various aspects of the client rela- tionship, or may be triggered by unusual events in a client’s account. Item 14 – Client Referrals and Other Compensation We pay referral fees to independent persons or firms (Solicitors also known as Referral Agents or Promot- ers) for introducing clients to us in accordance with applicable law and the requirements Advisors Act of Rule 206(4)-1, as amended. Under these arrangements, the referral fee is generally calculated based on a percentage of assets under management and must be disclosed to the client introduced by the Solicitor. Referred clients receive a copy of this document (our Firm Disclosure Brochure) and a separate disclosure statement that includes the following information:  the Solicitor's name and relationship with our Firm;  the fact that the Solicitor is being paid a referral fee; and  the amount of the fee. Item 15 – Custody Pursuant to Rule 206(4)-2 of the Advisers Act, because the Firm has the authority and ability to debit its fees directly from clients’ accounts, BWM is deemed to have “constructive custody” of accounts in which advisory fees are deducted. In some cases, BWM may also be deemed to have constructive custody over accounts in which a “Standing Letter of Authorization” (SLOA) to direct funds to a third party has been added to the account. Our policy is to not have custody of client assets beyond the “constructive custody” arising from debiting fees or accepting a third-party SLOA that meets all the conditions in SEC No-Action Letter 2/21/17, specif- ically that the SLOA does not allow BWM to designate or change the identity, address or any other infor- mation about the third party. With the exception of deduction of BWM’s management fees from the ac- count, BWM will not have the ability to withdraw funds or securities from your account. BWM does not issue client account statements. To mitigate any potential conflicts of interests, all client assets are maintained with an independent custodian. Furthermore, clients will receive statements on at least a quarterly basis (or on a monthly basis if selected by the client) directly from the Custodian financial institution that holds and maintains their assets and may offer clients electronic access to their portfolios. Clients are urged to carefully review all custodial statements and inform us of any discrepancies. Client Account statements typically include an account valuation, transaction details, investment advisory fees, and a performance summary. The account statements typically describe all assets held, the quantity and market price in local currency for each position and the market value of the account expressed in the client’s Reporting Currency translated at current rates of exchange. Clients should carefully review the account statements received from the custodian and inform BWM of any discrepancies, or errors. BWM does not provide any official account statements, tax reports of its own and provides no regular reports to the client other than management fee letters. March 25 Page 17 of 19  BWM does not have discretionary authority to select the client’s custodian. Clients will select a custodian to safeguard client assets. Clients will enter into a separate custodial arrangement directly with the cus- todian, and in the Client Agreement with BWM, the client will acknowledge this arrangement. Custodians have various fee programs with the following fees that might be applicable:  Transactional Fees (Stock exchange fees, brokerage fees, third-party brokerage fees)  Ticket Fee  Foreign Currency Exchange Rate spread  Physical metal price spread, handling and storage fees  Lombard loans interest rate spread (credit facility)  Money transfer fees BWM does not get any referrals from custodians and has therefore no conflict of interest to trade more or less for its clients. Item 16 – Investment Discretion Discretionary Authority: Limitations Unless otherwise agreed upon at the inception of the client relationship and memorialized in writing, most Investment Management Services rendered by BWM are done on a discretionary basis. In exercising its discretionary authority, BWM has the ability to determine the type and number of securities to be trans- acted and whether a client’s purchase or sale should be combined with those of other clients and traded as a “block.” Such discretion is to be exercised in a manner consistent with each client’s stated investment objectives, risk tolerance, and time horizon, as outlined in the client’s Investment Policy Statement. In addition, as discussed above BWM’s authority to trade securities may be limited in certain circumstances by applicable legal and regulatory requirements. Clients are permitted to impose reasonable limitations on BWM’s discretionary authority, including restrictions on investing in certain securities or types of se- curities. All such limitations, restrictions, and investment guidelines must be communicated to BWM in writing Limited Power of Attorney (LPOA) By signing BWM’s Agreement, clients authorize BWM to exercise discretionary authority with respect to all Investment Management Service transactions involving the client’s account (excluding any assets or accounts that are designated as non-discretionary per client direction). Pursuant to such agreement, BWM is designated as the client’s attorney-in-fact with discretionary authority to effect investment trans- actions in the client’s account. This limited power of attorney authorizes the Firm to give instructions to third parties for servicing client’s account. Under this LPOA BWM cannot transfer securities or withdraw cash from the account. Only the client can approve and make this written request to the Custodian. Item 17 – Voting Client Securities BWM's policy and practice is to not vote proxies on behalf of its clients and therefore, the Firm shall have no obligation to take any action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in a client’s account. Consequently, clients retain the responsi- bility for receiving and voting all proxies for securities held within the client's account. While BWM em- ployees may answer client questions regarding proxy voting matters in an effort to assist the client in determining how to vote the proxy, the final decision of how to vote the proxy rests with the client. BWM shall not be deemed to have proxy voting authority solely as a result of providing advice or information about a particular proxy vote to a client. March 25 Page 18 of 19  However, BWM may exercise investment authority for certain corporate actions (including, but not lim- ited to, take-over, dividend in cash or shares, rights offering, offer to redeem, split, reverse split, change in nominal value, etc.) in connection with the discretionary accounts. BWM will not vote or provide advice on other corporate actions, or tender offers, which do not require a proxy, or are not solicited via a proxy. Unless legally required to do so, BWM will not vote or provide any advice about the voting of proxies related to legal proceedings, bankruptcies, or class action litigation. Correspondence related to class action lawsuits, legal proceedings, bankruptcies and proceedings involv- ing an issuer held in the client’s account will be mailed directly to the client and any required action is the responsibility of the client. BWM will provide a copy of its Proxy Policy to clients upon request. Item 18 – Financial Information BWM has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. As of the date of this brochure publication, BWM does not believe it is reasonably likely that any future liability will affect its ability to meet its contractual commitments to its clients. Other Information Cybersecurity BWM utilizes electronic communication networks and electronic media to maintain information regarding its clients and its business. This creates the potential for cyber security incidents or cyber-attacks that can result in the inadvertent disclosure of confidential sensitive information to unintended parties, unauthor- ized access to confidential sensitive information, or operational disruptions by malicious hackers. BWM has policies and procedures in place regarding information technology security, maintains technical and physical safeguards and takes other reasonable precautions to safeguard the confidentiality of sensitive information and internal data. However, despite reasonable precautions, the risk remains that cyberse- curity incidents can occur. If such an event were to occur, BWM will promptly notify the affected parties and take all necessary and appropriate actions. Catastrophic Events Natural disasters, acts of terrorism, pandemics and other unforeseeable and external catastrophic events can disrupt the operations of BWM and our key service providers, as well as the financial markets and economy in BWM’ country of operation, or worldwide. Such events may result in significant losses in cli- ents’ investments and adverse financial consequences. BWM and key service providers have business continuity and disaster recovery policies in place that are reasonably designed to resume operations and ensure that clients have access to their funds and securities. March 25 Page 19 of 19 

Part 2A of Form ADV Information about qualifications of Investment Adviser Representatives of Belvoir Wealth Management AG Part 2B of Form ADV Brochure Supplement March 2025 March 24, 2025 Page 1 of 5  Part 2A of Form ADV Belvoir Wealth Management AG Tödistrasse 16 8002 Zurich, Switzerland www.belvoirwealth.com This brochure supplement provides information about the qualifications of Belvoir Wealth Management AG (“BWM”) Investment Adviser Representatives. If you have any ques- tions about the contents of this brochure supplement, please contact us.Additional information about Deepak Soni, Sabina Weber Sauser and Susanna Giase is available on the SEC’s website at https://adviserinfo.sec.gov/ info@belvoirwealth.com This brochure provides information about the following Su- pervised Persons of BWM: +41 43 244 7550  Deepak Soni, CEO, Managing Partner, and Member of CRD Number 128649 SEC File Number 801-62473   the Board of Directors Sabina Weber Sauser, CIO Managing Partner, and Mem- ber of the Board of Directors Susanna Giase, Director, Senior Relationship Manager The information in this brochure supplement has not been ap- proved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. information at BWM is a registered investment adviser. Registration of an invest- ment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with infor- mation about which you deter- mine to hire or retain an adviser. about Additional BWM is also available on the SEC’s website www.advis- erinfo.sec.gov. Clients and prospective clients should review this brochure sup- plement carefully. March 24, 2025 Page 2 of 5  Deepak Soni Partner, CEO (Chief Executive Officer) and Member of the Board of Directors Educational Background Deepak Soni was born in August 1971 in the US. After high school, he received a Bachelor degree in Industrial Engineering from N.C. State University in 1994. Deepak Soni completed an Executive MBA program from Golden Gate University in San Francisco, CA in 2006. Deepak Soni has successfully passed the Series 66 exam, the Uniform Combined State Law Examination that covers topics rele- vant to providing investment advice and effecting securities transactions for clients. Business Experience Deepak Soni is the CEO of Belvoir Wealth Management (SEC) since June 2021. Deepak Soni has over 20 years of financial services experience. Prior to arriving in Switzerland, Deepak Soni worked for Citigroup in New York and San Francisco in Business Development from 1999 until 2008. From 2008 until 2010, Deepak worked as Director for Credit Suisse Private Advisors (SEC) in Business Development. In 2010, he joined Vontobel Swiss Wealth Advisors (SEC) in Zurich as Markets Head for the U.S. region and became CEO two years later from 2012 until 2018. In 2018, Deepak Soni joined UBP Investment Advisors (SEC) in Zurich, where he took over the CEO position. Disciplinary Information There are no legal or disciplinary events to report. Other Business Activities Adjunct Professor for Golden Gate University. Additional Compensation Golden Gate University San Francisco CA. Supervision Deepak Soni, as BWM’s CEO, reports to the BWM Board of Directors, consisting of Alexandre Wein- traub, Chairman, Sabina Weber Sauser and Deepak Soni himself. Deepak Soni is supervised by Katharina Stumm, CFA, BWM’s Chief Compliance Officer, for any investment advice, he provides through BWM. Each BWM employee has a responsibility for knowing and following BWM’s policies and procedures. Each person in a supervisory role is also responsible for those individuals under his/her supervision. Supervision is ongoing and includes among other things account reviews, trade supervision, annual compliance reviews, including the forensic testing of firm systems, staff meetings and employee reviews. Katharina Stumm, CFA, Chief Compliance Officer (“CCO”), has the overall responsibility for monitoring and testing compliance with BWM’s policies and procedures. Possible violations of these policies or procedures will be documented and reported by the CCO for remedial actions and/or sanctions to the appropriate supervisor, to the BWM Risk and Oversight Committee and/or to the BWM Board of Directors, depending on the repeated nature and/or seriousness of the violation in question. March 25 ADV Part 2B Page 3 of 5  Sabina Weber Sauser Partner, CIO (Chief Investment Officer) and Member of the Board of Directors Educational Sabina Weber Sauser was born in January 1967 in Glarus, Switzerland. She is a graduate of the Uni- versity of Applied Sciences in Zurich (1992). Mrs. Weber Sauser is a Certified EFFAS Financial Analyst (CEFA) (1994) and a member of the Swiss Financial Analyst association. In addition, she is a lecturer and fellow at University of Applied Sciences in Zurich where she teaches banking and finance related topics. Business Experience Mrs. Weber Sauser joined Belvoir Wealth Management in August 2021 as Chief Investment Officer. She has over 30 years of financial services experience and has been working throughout this time in investment management for private and institutional investors. Prior to joining Belvoir Wealth Man- agement, Mrs. Weber Sauser worked as a Managing Director and Senior Investment Manager for UBP Investment Advisors SA from 2018 to 2021. From 2010 to 2016 she was the Chief Investment Officer for Vontobel Swiss Wealth Advisors AG. From 2008 to 2010 she was Head of Asset Manage- ment & Investment Process at AIG Private Bank (Falcon Private Bank). Prior to this experience, Mrs. Weber Sauser was managing the Curriculum at University of Applied Sciences in Zurich for their BSc in Banking & Finance from 2006 to 2007. She previously worked as Head of Portfolio Construction and Senior Fund Manager at Credit Suisse Asset Management from 2003 to 2006. From 2000 to 2003 she served as CEO of Swiss Life Fund Master AG. Prior to this experience she worked as Port- folio Manager for Banque Edouard Constant, Bank Vontobel and Swiss Bank Corporation (UBS AG) where she started her career in 1988. Disciplinary Information None. Other Business Activities Lecturer at University of Applied Sciences in Zurich, Board member of Ragotti & Weber group com- panies in Glarus. Additional Compensation University of Applied Sciences in Zurich, Ragotti & Weber group companies in Glarus. Supervision Sabina is supervised by Katharina Stumm, CFA, BWM’s Chief Compliance Officer, for any investment advice, she provides through BWM. Katharina Stumm, CFA can be reached at +41 43 244 75 50. Each BWM employee has a responsibility for knowing and following BWM’s policies and procedures. Each person in a supervisory role is also responsible for those individuals under his/her supervision. Supervision is ongoing and includes among other things account reviews, trade supervision, annual compliance reviews, including the forensic testing of firm systems, staff meetings and employee reviews. Katharina Stumm, CFA, Chief Compliance Officer (“CCO”), has the overall responsibility for monitoring and testing compliance with BWM’s policies and procedures. Possible violations of these policies or procedures will be documented and reported by the CCO for remedial actions and/or sanctions to the appropriate supervisor, to the BWM Risk and Oversight Committee and/or to the BWM Board of Directors, depending on the repeated nature and/or seriousness of the violation in question. March 25 ADV Part 2B Page 4 of 5  Susanna Giase Director, Senior Relationship Manager Educational Susanna Giase was born in June 1975 in Zurich. She began her career in 1992 with a commercial apprenticeship and additionally she holds a Financial Planner Certificate earned in 2003. Background and Business Experience She was initially in charge of the placements of subscription and redemption orders, providing op- erational support to relationship managers, trouble-shooting into management and reconciliation within the master custodian, broker and fund administrator. She was also in charge of recruiting new employees with knowhow. In order to deepen her banking expertise, Mrs. Giase joined in July 1999 Credit Suisse Private Banking as a junior relationship manager. She had the possibility to gather her experience in servicing ultra-high net worth clients. In 2001, she started at Maerki Baumann & Co. AG a family-owned private bank. She was able to deepen her knowledge in wealth preservation and develop new business areas within private banking. Due to her interest into specific topics, she was able to implement tailor made solutions such as international diversification as well as minimiz- ing systematic risks into the clients’ portfolios. Since then, she has been working successfully to develop new relationships and retain her existing client base within different institutions. In July 2018, Mrs. Giase joined Belvoir Wealth Management AG as a Director and Senior Client Advisor. Mrs. Giase speaks German, English, Italian and French. Disciplinary Information There are no legal or disciplinary events to report. Other Business Activities There are no other business activities to report. Additional Compensation Susanna Giase receives fees from the affiliate company Belvoir Capital AG for referring non-US Per- sons to Belvoir Capital AG. She does not manage or advise these clients. Supervision Susanna Giase is supervised by Katharina Stumm, CFA, BWM’s Chief Compliance Officer, for any investment advice, she provides through BWM. Katharina Stumm, CFA can be reached at +41 43 244 75 50. Each BWM employee has a responsibility for knowing and following BWM’s policies and procedures. Each person in a supervisory role is also responsible for those individuals under his/her supervision. Supervision is ongoing and includes among other things account reviews, trade supervision, annual compliance reviews, including the forensic testing of firm systems, staff meetings and employee reviews. Katharina Stumm, CFA, Chief Compliance Officer (“CCO”), has the overall responsibility for monitoring and testing compliance with BWM’s policies and procedures. Possible violations of these policies or procedures will be documented and reported by the CCO for remedial actions and/or sanctions to the appropriate supervisor, to the BWM Risk and Oversight Committee and/or to the BWM Board of Directors, depending on the repeated nature and/or seriousness of the violation in question. March 25 ADV Part 2B Page 5 of 5