KAILIX ADVISORS LLC

Kailix Advisors LLC Form ADV Part 2A – Disclosure Brochure Effective: March 24, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Kailix Advisors LLC (“Kailix” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (305) 897-0252. Kailix is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Kailix to assist you in determining whether to retain the Advisor. Additional information about Kailix and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 311094. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Kailix. For convenience, we have combined these documents into a single disclosure document. Kailix believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. Kailix encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on January 17, 2024: • The Advisor has changed its primary office location to 2980 NE 207th Street Suite 300 Aventura, FL 33180. • The Advisor has updated its phone number to (305) 897-0252. • The Advisor has amended Item 4, Item 5, and Item 10 to reflect their Sub-Advisor services. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 311094. You may also request a copy of this Disclosure Brochure at any time by contacting us at (305) 897-0252. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................ 1 Item 2 – Material Changes ...................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services..................................................................................................................................... 4 A. Firm Information ..............................................................................................................................................................4 B. Advisory Services Offered ...............................................................................................................................................4 C. Client Account Management ...........................................................................................................................................5 D. Wrap Fee Programs ........................................................................................................................................................5 E. Assets Under Management .............................................................................................................................................5 Item 5 – Fees and Compensation .......................................................................................................................... 5 A. Fees for Advisory Services ..............................................................................................................................................6 B. Fee Billing ........................................................................................................................................................................6 C. Other Fees and Expenses...............................................................................................................................................6 D. Advance Payment of Fees and Termination ...................................................................................................................7 E. Compensation for Sales of Securities .............................................................................................................................7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 7 Item 7 – Types of Clients ........................................................................................................................................ 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ........................................................................................................................................................8 B. Risk of Loss .....................................................................................................................................................................8 Item 9 – Disciplinary Information .......................................................................................................................... 9 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 9 A. Code of Ethics .................................................................................................................................................................9 B. Personal Trading with Material Interest ...........................................................................................................................9 C. Personal Trading in Same Securities as Clients .............................................................................................................9 D. Personal Trading at Same Time as Client.....................................................................................................................10 Item 12 – Brokerage Practices ............................................................................................................................. 10 A. Recommendation of Custodian[s] .................................................................................................................................10 B. Aggregating and Allocating Trades ...............................................................................................................................10 Item 13 – Review of Accounts.............................................................................................................................. 11 A. Frequency of Reviews ...................................................................................................................................................11 B. Causes for Reviews.......................................................................................................................................................11 C. Review Reports .............................................................................................................................................................11 Item 14 – Client Referrals and Other Compensation ......................................................................................... 11 A. Compensation Received by Kailix .................................................................................................................................11 B. Compensation for Client Referrals ................................................................................................................................12 Item 15 – Custody.................................................................................................................................................. 12 Item 16 – Investment Discretion .......................................................................................................................... 12 Item 17 – Voting Client Securities ....................................................................................................................... 12 Item 18 – Financial Information ........................................................................................................................... 12 Form ADV 2B - Brochure Supplement ................................................................................................................ 13 Privacy Policy ........................................................................................................................................................ 15 Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 3  Item 4 – Advisory Services A. Firm Information Kailix Advisors LLC (“Kailix” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Kailix, which is organized as a Limited Liability Company (“LLC”) under the laws of the state of Florida. Kailix was founded in October 2020. Kailix is owned and operated by Manish Mittal (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Kailix. B. Advisory Services Offered Kailix offers investment advisory to individuals and high net worth individual (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. This is achieved through regular personal Client contact. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Kailix provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Kailix works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Kailix will then construct an investment portfolio, consisting primarily of exchange-traded funds (“ETFs”), and individual stocks to achieve the Client’s investment goals. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client Kailix’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Kailix will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Kailix evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Kailix may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Kailix may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Kailix may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee- based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 4  At no time will Kailix accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Private Fund Sub-Advisory Services Kailix also serves as a sub-advisor to Ascent Focused Equity LP, a pooled investment vehicle (“Private Fund”). Kailix is responsible for sub-advisory services to the Private Fund. Such services may include reviewing information related to co-investment opportunities, conducting diligence on the co-investment opportunities and reporting and consulting with the advisor to the Private Fund in connection with such due diligence analysis. The respective services are further detailed in the offering documents for the Private Fund, which include as applicable, operating agreements, private placement memorandum, and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor provides sub-advisory services to the Private Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Private Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Private Fund and further acknowledges and accepts the various risk factors associated with such an investment. C. Client Account Management Prior to engaging Kailix to provide investment advisory services, each Client is required to enter into a written agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Kailix, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Kailix will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. • Portfolio Construction – Kailix will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Kailix will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Kailix does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Kailix. E. Assets Under Management As of December 31, 2024, Kailix manages approximately $217,452,000 in Client assets, $ 119,887,000 of which are managed on a discretionary basis, and $ 97,565,000 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 5  A. Fees for Advisory Services Investment Management/Sub-Advisory Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are billed at an annual rate of up to 2.00% and are based on the market value of assets under management at the end of the prior calendar quarter. “Qualified Clients”, as described in Item 6 below are also charged an annual performance fee, if applicable. Please see Item 6. Fees are based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. The Advisor requires a $5,000,000 minimum for new investors, subject to the Advisor’s discretion. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. All securities held in accounts managed by Kailix will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed fee not to exceed the annual rate above. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Kailix will be independently valued by the Custodian. Kailix will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. B. Fee Billing Investment Management/Sub-Advisory Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter-end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Kailix at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Kailix to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Kailix, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The fees charged by Kailix are separate and distinct from these custody and execution fees. In addition, all fees paid to Kailix for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Kailix, but would not receive the services provided by Kailix which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Kailix to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 6  D. Advance Payment of Fees and Termination Investment Management/Sub-Advisory Services Kailix may be compensated for its investment advisory services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Kailix does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Kailix may receive a performance fee in addition to its investment management/sub-advisory services fee based upon any gains obtained in the accounts of “Qualified Clients” pursuant to the terms an investment advisory agreement. Only Qualified Clients with either $1,100,000 under management with the Advisor or a net worth of $2,200,000 may be offered a performance-based fee option. The performance fee will be calculated at the close of the calendar year and deducted from Client accounts directly by the Custodian. The performance fee charged may be up to 20.0% of any gains in the Client account[s] for the year, subject to a high-water mark calculation. Only gains above the high-water mark shall be subject to the performance fee. The Advisor will receive the performance fee only to the extent that there are cumulative gains since the last performance fee calculation in the Client's account[s]. Performance fee may be negotiable at the discretion of the Advisor. Who is a “Qualified Client”? The Investment Advisers Act of 1940 (the “Advisers Act”), Rule 205-3(d)(1) defines a “Qualified Client” who is financially sophisticated and meets one or more of the following conditions: • Client is a natural person who, or a company that, immediately after entering into the contract has at least $1,100,000 under the management of the Advisor; • Client is a natural person who, or a company that, immediately prior to entering into the contract has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 at the time the contract is entered into. The receipt of a performance fee by certain Clients results in a potential conflict of interest, where the Advisor has the potential for higher compensation from a Client. Qualified Clients that are charged a performance fee may be offered a lower investment advisory fee. Kailix does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Kailix offers investment advisory services to individuals and high net worth individuals. Additionally, Kailix serves as a sub-advisor to Ascent Focused Equity LP, a pooled investment vehicle. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 7  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Kailix primarily employs fundamental analysis methods in developing investment strategies for its Clients. Research and analysis from Kailix are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. As noted above, Kailix generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Kailix will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Kailix may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Kailix will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 8  Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Kailix or its owner. Kailix values the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 311094. Item 10 – Other Financial Industry Activities and Affiliations Sub-Advisor to a Private Fund As noted in Item 6, the Advisor serves as a sub-advisor to Ascent Focused Equity LP, a pooled investment vehicle (“Private Fund”). The fact that the Advisor is entitled to receive performance-based compensation creates a conflict of interest in that it creates an incentive for the Advisor to recommend the Private fund to Clients. Clients are under no obligation to invest in the Private Fund and the Advisor will always provide investment recommendations that are in the best interest of Clients. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Kailix has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all persons associated with Kailix (our “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. Kailix and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Kailix’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (305) 897-0252. B. Personal Trading with Material Interest Kailix allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Kailix does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Kailix does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Kailix allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Kailix by conducting a coordinated review of personal accounts and the accounts of the Clients. We have also adopted written policies and procedures to detect the misuse of material, non-public information. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 9  D. Personal Trading at Same Time as Client While Kailix allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Kailix, or any Supervised Person of Kailix, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Kailix does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Kailix to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Kailix does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. Where Kailix does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Kailix. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Kailix may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Kailix will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), FINRA-registered broker-dealer and member of SIPC. The Client’s selected Custodian will serve as the Client’s “qualified custodian”. Kailix maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Kailix does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from Schwab. Please see Item 14 below. 2. Brokerage Referrals - Kailix does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Kailix will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Kailix will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Kailix will execute its transactions through the Custodian as authorized by the Client. Kailix may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 10  of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Mr. Mittal. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Kailix if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Kailix Kailix is a fee-only advisory firm, that is compensated solely by its Clients and not from any investment product. Kailix does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. Kailix may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Kailix may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform Kailix has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Kailix. As a registered investment advisor participating on the Schwab Advisor Services platform, Kailix receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 11  Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and support to Kailix that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Kailix believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. Item 15 – Custody Kailix does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Kailix exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Kailix to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Kailix to ensure accuracy, as the Custodian does not perform this review Item 16 – Investment Discretion Kailix generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Kailix. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Kailix will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Kailix does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Kailix, nor its management, have any adverse financial situations that would reasonably impair the ability of Kailix to meet all obligations to its Clients. Neither Kailix, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Kailix is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $500 or more for services to be performed six months or more in the future. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 12  Form ADV Part 2B – Brochure Supplement for Manish Mittal Principal and Chief Compliance Officer Effective: March 24, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Manish Mittal (CRD# 2526691) in addition to the information contained in the Kailix Advisors LLC (“Kailix Advisors” or the “Advisor”, CRD# 311094) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Kailix Advisors Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (305) 897-0252. Additional information about Mr. Mittal is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2526691. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 13  Item 2 – Educational Background and Business Experience Manish Mittal, born in 1972, is dedicated to advising Clients of Kailix Advisors as its Principal and Chief Compliance Officer. Mr. Mittal earned a B.S. in Economics concentration in Finance and Accounting from University of Pennsylvania - The Wharton School in 1994. Additional information regarding Mr. Mittal’s employment history is included below. Employment History: Principal and Chief Compliance Officer, Kailix Advisors LLC Private Investor, Kailix Advisors LLC Portfolio Manager, Pine River Capital Management Portfolio Manager, Kingdon Capital Management Founder and Chief Investment Officer, Blackstone/Kailix Advisors Managing Director & Portfolio Manager, Perry Capital Portfolio Manager, SAC Capital Management Portfolio Manager, Kingdon Capital Management Analyst, Principal Investment Area, Goldman Sachs & Co. 10/2020 to Present 06/2012 to 10/2020 02/2015 to 04/2017 06/2010 to 06/2012 03/2006 to 04/2010 10/2003 to 01/2006 10/2001 to 06/2003 05/1996 to 10/2001 09/1994 to 05/1996 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Mittal. Mr. Mittal has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Mittal. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Mittal. However, we do encourage you to independently view the background of Mr. Mittal on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2526691. Item 4 – Other Business Activities Guard Hill Capital, LLC Mr. Mittal serves as a Partner of Guard Hill Capital, LLC, Guard Hill Capital, LLC was formed to invest in ideas which are in the Kailix Advisors portfolio. Mr. Mittal spends less than 1 hour per month on activities specifically related to his role at Guard Hill Capital LLC. Item 5 – Additional Compensation Mr. Mittal has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Mittal serves as the Principal and Chief Compliance Officer of Kailix Advisors. Mr. Mittal can be reached at (305) 897-0252. Kailix Advisors has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Kailix Advisors. Further, Kailix Advisors is subject to regulatory oversight by various agencies. These agencies require registration by Kailix Advisors and its Supervised Persons. As a registered entity, Kailix Advisors is subject to examinations by regulators, which may be announced or unannounced. Kailix Advisors is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 14  Privacy Policy Effective: March 24, 2025 Our Commitment to You Kailix Advisors LLC (“Kailix” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Kailix (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Kailix does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 15  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes Kailix does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Kailix or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Kailix does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (305) 897-0252 . Kailix Advisors LLC 2980 NE 207th Street Suite 300 Aventura, FL 33180 Phone: (305) 897-0252 Page 16