Investment Advisor Disclosures

Regulatory Status

Otodus Global is an investment adviser. This disclosure document provides important information about our advisory services, business practices, fees, and conflicts of interest. Clients and prospective clients should carefully review this information before engaging our services.

Form ADV

Our Form ADV Part 2A (Firm Brochure) and Part 2B (Brochure Supplement) contain detailed information about our firm, services, fees, and disciplinary history. These documents are available upon request and should be reviewed carefully before entering into an advisory relationship.

Fiduciary Duty

As a registered investment adviser, Otodus Global acts as a fiduciary to our clients. This means we are legally obligated to act in your best interest and to provide advice that is suitable for your individual circumstances, investment objectives, and risk tolerance.

Investment Risks

All investments involve risk, and clients should be prepared to bear the loss of their entire investment. Specific risks include but are not limited to:

• Market Risk: The value of investments may decline due to market conditions
• Liquidity Risk: Certain investments may be difficult to sell quickly at fair value
• Concentration Risk: Focused investment strategies may increase volatility
• Leverage Risk: Use of borrowed funds can amplify both gains and losses
• Strategy Risk: Our investment strategies may not perform as anticipated
• Counterparty Risk: Risk that other parties may default on obligations

Performance Disclosures

Past performance is not indicative of future results. When reviewing performance information, clients should consider:

• Historical returns may not reflect future performance
• Performance results are presented net of fees unless otherwise stated
• Individual client returns may vary based on timing of investments and withdrawals
• Benchmark comparisons may not reflect the same risk profile as client portfolios
• Performance results may not include the impact of taxes

Fees and Compensation

Our compensation structure and fee arrangements are fully disclosed in our advisory agreements. Key points include:

• Advisory fees are typically based on a percentage of assets under management
• Fees are negotiable based on account size and service level
• Clients may incur additional costs such as custodial fees, transaction costs, and fund expenses
• Fee arrangements are detailed in each client's investment advisory agreement
• Clients may terminate the advisory relationship at any time

Conflicts of Interest

We are committed to disclosing all material conflicts of interest. Potential conflicts include:

• Our fee structure may create an incentive to recommend certain investments or strategies
• We may invest in the same securities as our clients, which could create conflicts regarding timing and allocation
• Affiliated entities or relationships may present conflicts that are disclosed in our Form ADV

We maintain policies and procedures designed to identify and mitigate conflicts of interest in accordance with our fiduciary duty.

Custody of Assets

Client assets are held by qualified custodians. We do not take physical custody of client assets. Clients receive regular account statements directly from their custodian and should carefully review these statements.

Voting Client Securities

Our policy regarding proxy voting is disclosed in our Form ADV. Clients may contact us to obtain information about how we voted proxies for their securities or to obtain a copy of our proxy voting policies and procedures.

Code of Ethics and Personal Trading

We have adopted a Code of Ethics that governs the personal trading activities of our employees. The Code of Ethics is designed to ensure that the interests of our clients are placed ahead of the interests of our firm and our employees.

Account Reviews

Client accounts are monitored on an ongoing basis. The frequency and nature of reviews depend on the services provided and are detailed in the advisory agreement. Clients receive periodic reports regarding their accounts and investment performance.

Client Referrals

We may compensate third parties for client referrals in accordance with applicable regulations. Any such arrangements are fully disclosed to clients, and referred clients are not charged higher fees as a result of the referral arrangement.

Disciplinary Information

Investment advisers are required to disclose material facts about legal or disciplinary events that would be material to your evaluation of the firm. There are no legal or disciplinary events to report at this time. Complete disciplinary information is available in our Form ADV.

Other Financial Industry Activities

Neither Otodus Global nor its management persons are registered as, or have pending applications to become, a broker-dealer or a registered representative of a broker-dealer. Information about other financial industry activities and affiliations, if any, is disclosed in our Form ADV.

Investment Strategy and Risk of Loss

Our investment philosophy emphasizes concentrated, long-term holdings in undervalued securities. This approach involves significant risks, including higher volatility and concentration risk compared to diversified investment strategies. Clients should carefully consider whether this approach aligns with their risk tolerance and investment objectives.

Accredited Investor Requirement

Our services are generally limited to accredited investors as defined by SEC regulations. Clients are responsible for ensuring they meet and maintain the accredited investor qualifications. Misrepresentation of accredited status may result in termination of the advisory relationship and potential legal consequences.