Gravitalix Financial LLC

Item 5 – Fees and Compensation

SMA Platform Fees

Gravitalix charges an annual asset-based platform and advisory fee (the “Platform Fee”) for
SMAs, which is based on the average daily balance of the assets under Gravitalix’s management
as of the last day of the month, as documented in each Client’s Advisory Agreement. The
Platform Fee ranges between twenty basis points (0.20%) for basic custody to up to two hundred
basis points (2.00%) for other products (defined below at “Item 7 - Types of Clients”), billed
monthly in arrears depending upon the size and composition of such Client’s portfolio and the
type of services rendered. The Platform Fee compensates Gravitalix for portfolio management
and monitoring, access to Gravitalix’s digital asset investment platform and technology,
reporting and Client support, and related advisory and non-advisory services.

SMA Platform Fees are calculated as a prorated amount of the Client’s daily balance as of
23:59:59 Coordinated Universal Time (UTC). The Digital Assets in each SMA are valued using
the “closing price” of each Digital Asset in USD as reported by coinmarketcap.com or other
pricing sources pursuant to Gravitalix’s valuation policy on each calendar day, over a month,
and typically charged as of the last business day of each month.

Fees and Compensation for Gravitalix Yield Strategies
In addition to standard Platform Fees, Gravitalix may be compensated for Yield Strategies in
one or more of the following ways, as specified in each Client’s Advisory Agreement or other
program documents:

Asset-Based Platform Fee on Yield Strategies

Platform Fees may apply to assets allocated to Yield Strategies at the same or a different rate
than other assets in the SMA. In such cases, gross yield (after third-party/platform fees) is
generally credited to the Client’s account, and Gravitalix’s compensation is limited to the
applicable Platform Fees. In certain Yield Strategies that utilize lending or trading arrangements
with third-party counterparties, Gravitalix and/or its affiliates may receive a share of revenue, a
spread, or other platform-level compensation from such counterparties. Where applicable,
Clients will be credited with a stated yield or rate for their participation, and Gravitalix and/or
its affiliates may retain all or a portion of any additional compensation received from such
counterparties. These arrangements create conflicts of interest, as Gravitalix may have
an incentive to allocate Client assets to strategies or counterparties that are expected to generate
higher platform compensation. Gravitalix seeks to address these conflicts through disclosure,

Gravitalix Financial, LLC                                             Form ADV Part 2A Brochure

supervisory oversight, and policies and procedures designed to allocate opportunities fairly and
consistently among Clients.

Yield-Linked or Performance-Based Compensation (Qualified Clients only)

For “qualified clients,” as defined in Rule 205-3 under the Investment Advisers Act of 1940, as
amended (the “Advisers Act”), Gravitalix may use yield-linked or performance-based
compensation structures, for example:

    •   Crediting the Client with a stated, non-binding Client Yield or Client Rate (for example,
        an annualized percentage applied to the Client’s daily eligible balance) and retaining all
        or part of any excess yield generated above that Client Rate; and/or

    •   Charging a performance fee or incentive fee on realized or unrealized gains attributable
        to a Yield Strategy over a measurement period.

These arrangements create conflicts of interest because Gravitalix may have an incentive to:

    •   direct assets into strategies that may be expected to produce higher yield or performance,

    •   favor accounts paying performance-based or yield-linked compensation, and

    •   increase risk in those accounts to maximize potential compensation.

Gravitalix has adopted policies and procedures designed to treat Clients fairly and equitably and
to mitigate these conflicts, including procedures for allocation of investment opportunities,
independent review of performance-fee account trading, and supervision of Yield Strategies.
However, such conflicts cannot be entirely eliminated.

Other Fees and Expenses

Clients may also bear transaction fees associated with the trading of Digital Assets, as discussed
in Item 12 – Brokerage Practices.

Gravitalix’s Management Fees and Platform Fees do not include fees or expenses associated
with brokerage, custody, transaction, blockchain network fees (such as gas fees for Ethereum-
based transactions), or similar fees assessed by any third-party service provider. For SMAs,
transaction fees are added and itemized separately in each Client’s SMA statement. Clients
should be aware that blockchain network fees can be substantial and highly variable depending
on network congestion and may significantly impact the cost-effectiveness of transactions,
particularly for smaller account sizes.

Clients pay fees and incur expenses whether they make or lose money on their investments. Fees
and expenses reduce any amount the Client makes on their investments over time. The more
assets there are in a Client’s account, the more such Client pays in fees, and Gravitalix may,
from time to time, have an incentive to encourage Clients to increase assets managed by
Gravitalix.

On the last business day of each month, Gravitalix assesses fees. Platform Fees are either
deducted from the Client’s SMA subject to the Client’s prior agreement or billed and processed
separately.

Gravitalix Financial, LLC                                             Form ADV Part 2A Brochure

If an SMA Client prepays an Platform Fee and then terminates its Advisory Agreement before
the end of the billing period, prepaid fees will be returned to each Client on a prorated basis
based on the termination date of the SMA.
...

Item 7 - Types of Clients

Gravitalix’s Clients include individuals, institutions, trusts, and other legal entities.

The SMAs will have an investment minimum of $5,000.

Gravitalix’s Yield Strategies may require a minimum overall account balance (for example,
$5,000 or equivalent) for participation and minimum per-asset or per-strategy balances for
specific Yield Strategies. Gravitalix may reduce or suspend a Client’s participation if balances
fall below required minimums.

    A. SMA Clients

Gravitalix provides discretionary investment advisory services to Clients in the form of SMAs
based on information provided by Clients regarding, among other things, liquid net worth
(investable assets), risk tolerance, investment goals and investment experience during any
financial consultation call, email or from an onboarding questionnaire. This advice pertains
solely to the Client’s investments in Digital Assets with Gravitalix and is not intended to be
holistic financial advice pertaining to any other asset classes.

SMAs do not currently support crypto forks or airdrops. Forks and airdrops may adversely
impact the value of the original Digital Assets and the successor Digital Assets held in the SMA.

Gravitalix Financial, LLC                                               Form ADV Part 2A Brochure

With regard to Digital Assets held in SMAs, Gravitalix has sole discretion to decide whether or
not to support forks and airdrops for those Digital Assets, and Gravitalix in its sole discretion
may (i) not accommodate the new Digital Asset; (ii) only accommodate the new Digital Asset
after a significant period; or (iii) with advance written consent from the Client, have a
contractual right to claim the new Digital Asset for its own account, provided that any such
arrangement shall be disclosed in the Advisory Agreement. Gravitalix does not currently have
any systems in place to participate in Digital Asset forks or airdrops. As a result, Clients may
not benefit from Digital Assets provided through forks or airdrops, and Digital Assets subject
to forks or airdrops may be rendered useless or of little value. Gravitalix will use commercially
reasonable efforts to notify Clients of material forks or airdrops that may affect their holdings.

Furthermore, some Digital Asset tokens include participation in governance activities, such as
the ability to vote on topics that directly or indirectly may affect return on investment through
on-chain governance. Gravitalix’s infrastructure does not currently support the ability to
participate in such Digital Asset governance activities. As such, Clients may be unable to
participate in such governance activities for Digital Assets held in their SMA.