Accessibility Compliance Policy

1. Purpose

Penserra Wealth Management (the “Firm”) is committed to providing clients, prospective clients, and the public with equal and meaningful access to the Firm’s services, communications, and digital properties, regardless of disability. This policy establishes the standards, responsibilities, and procedures the Firm follows to identify, remediate, and prevent accessibility barriers, and to document its compliance with applicable law and regulatory expectations.

As a fiduciary registered with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”), the Firm recognizes that its duty of care and duty of loyalty to clients extend to ensuring that no client is disadvantaged in receiving advice, disclosures, or services because of a disability.

2. Scope

This policy applies to:

• All public-facing and client-facing digital properties owned or operated by the Firm, including its website, client portal, and any mobile applications;
• All written and electronic client communications, including account statements, performance reports, Form ADV Part 2A/2B, Form CRS, privacy notices, and marketing materials;
• All in-person, telephonic, and virtual interactions between Firm personnel and clients or prospective clients; and
• Third-party vendors and service providers whose platforms or materials are used to deliver services to clients on the Firm’s behalf.

3. Regulatory & Legal Framework

This policy is informed by, and intended to support compliance with, the following:

• Investment Advisers Act of 1940 and related SEC rules, which impose a fiduciary duty of care requiring the Firm to reasonably understand and act in accordance with each client’s objectives, circumstances, and needs — including needs arising from a disability;
• Title III of the Americans with Disabilities Act (“ADA”), which prohibits discrimination on the basis of disability by places of public accommodation, a standard that courts and regulators have increasingly applied to commercial websites and digital services;
• Section 504 of the Rehabilitation Act and Section 508 of the Rehabilitation Act, referenced here as voluntary best-practice benchmarks the Firm elects to follow even though these provisions apply directly to federal agencies and their contractors rather than private advisory firms; and
• The Web Content Accessibility Guidelines (“WCAG”), currently version 2.1, Level AA, which the Firm adopts as its technical accessibility standard for digital properties.

This policy is a Firm compliance standard and does not constitute legal advice. The CCO, in consultation with outside counsel as needed, is responsible for monitoring legal and regulatory developments that may require this policy to be updated.

4. Policy Statement

It is the policy of Penserra Wealth Management that no client or prospective client will be denied full and equal access to the Firm’s services, communications, or digital properties on the basis of disability. The Firm will take reasonable, proactive, and documented steps to identify and remove accessibility barriers and to provide reasonable accommodations upon request.

5. Digital & Website Accessibility

The Firm targets WCAG 2.1 Level AA conformance for its website, client portal, and any mobile applications. To support this standard, the Firm will:

• Conduct an accessibility audit of all public- and client-facing digital properties at least annually, and following any significant redesign or platform migration;
• Remediate identified barriers according to a risk-based timeline, prioritizing issues that block core account access or disclosure delivery;
• Require any third-party website, portal, or application vendor to represent its conformance with WCAG 2.1 AA (or a successor standard) as part of vendor due diligence and, where feasible, contractual terms; and
• Maintain a visible mechanism on the Firm’s website for visitors to report accessibility barriers, routed to the process described in Section 8.

6. Accessible Client Communications & Disclosures

Upon request, the Firm will provide required disclosures and routine client communications — including Form ADV Part 2A/2B, Form CRS, privacy notices, account statements, and performance reports — in an alternative format reasonably suited to the client’s needs, which may include:

• Large-print or high-contrast print formats;
• Screen-reader-compatible electronic formats (e.g., tagged PDF or accessible HTML rather than scanned images);
• Audio recording or text-to-speech-compatible files; or
• Braille, arranged through a qualified third-party transcription service.

Requests for alternative formats should be directed to the client’s advisor or to the CCO and will be fulfilled within a reasonable time, consistent with any applicable regulatory delivery deadlines.

7. Client Meetings & Service Accommodations

Firm personnel will provide reasonable accommodations for clients and prospective clients with disabilities during meetings, calls, and onboarding, which may include:

• Use of qualified interpreters (including sign language interpreters) or assistive listening devices, upon advance request;
• Selecting or adapting meeting locations to ensure physical accessibility;
• Allowing a client’s authorized representative, caregiver, or trusted contact to participate in meetings, consistent with the Firm’s privacy and authorization procedures; and
• Adjusting pace, format, or medium of communication (e.g., written follow-up after a call) to support client understanding.

Advisors should document accessibility-related accommodations provided to a client in the client relationship management (“CRM”) system so that preferences are honored consistently across the relationship.

8. Suitability & Know-Your-Client Considerations

Consistent with the Firm’s fiduciary duty and Know-Your-Client procedures, advisors must consider whether a client’s disability affects how the client receives, processes, or acts on investment advice and disclosures, and must adapt the delivery of advice and information accordingly. This consideration should be documented as part of the client’s suitability and onboarding records.

9. Accommodation Requests & Compliance Intake

Clients, prospective clients, or members of the public may request an accommodation or report an accessibility barrier by contacting the Firm’s Chief Compliance Officer. The CCO will:

• Log the request or complaint in the Firm’s compliance tracking system;
• Acknowledge receipt within five (5) business days;
• Coordinate with the relevant business unit, advisor, or vendor to fulfill the request or remediate the barrier; and
• Provide the requester with a status update and expected resolution timeframe.

No client or prospective client will be subject to retaliation for requesting an accommodation or reporting an accessibility concern.

10. Training

All client-facing personnel will receive training, at least annually, on this policy, on recognizing and responding to accommodation requests, and on the accessibility standards applicable to client communications. Training completion will be tracked by Compliance as part of the Firm’s annual compliance training program.

11. Roles & Responsibilities

• Chief Compliance Officer: owns this policy, oversees implementation, maintains records, and reports material accessibility matters to the Firm’s management as appropriate.
• Advisors and Client-Facing Staff: identify client accommodation needs, document them in the CRM, and escalate requests they cannot fulfill directly to the CCO.
• Technology/Vendor Management: ensures digital properties and third-party platforms meet the standards in Section 5 and supports remediation efforts.

Penserra Wealth Management LLC | Last Updated: August 2026