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 utr:oz

 UNITED
STATES

SECURITIES AND EXCHANGE COMMISSION

 Washington,
D.C. 20549

 Form

 ANNUAL
 REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 For
 the fiscal year ended December 31, 2024

 or

 TRANSITION
 REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 For
 the Transition Period from ________________to _________________

 Commission
File Number: 001-34589

 abrdn

 ( Exact
name of registrant as specified in its charter)

 New
 York

 26-4733157

 (State
or other jurisdiction of incorporation or organization)

 (I.R.S.
 Employer Identification No.)

 c/o
 abrdn ETFs Sponsor LLC

 1900
Market Street, Suite 200

 Philadelphia,
 PA

 19103

 (Address
of principal executive offices)

 (Zip
Code)

 (844) 383-7289

 (Registrant's
telephone number, including area code)

 Securities
registered pursuant to Section 12(b) of the Act:

 Title
 of each class

 Trading
 Symbol(s)

 Name
 of each exchange on which registered

 abrdn
 Physical Palladium Shares ETF

 PALL

 NYSE
 Arca

by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes No

by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Act. Yes No

by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities
Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such
reports), and (2) has been subject to such filing requirements for the past 90 days. Yes No

by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant
to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that
the registrant was required to submit such files). Yes No

by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller
reporting company, or an emerging growth company. See the definitions of "large accelerated filer", "accelerated
filer", "smaller reporting company", and "emerging growth company" in Rule 12b-2 of the Exchange
Act.

 Large
 Accelerated Filer

 Accelerated
 Filer

 Non-Accelerated
 Filer

 Smaller
 Reporting Company

 Emerging
 Growth Company

 If
an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for
complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.

by check mark whether the registrant has filed a report on and attestation to its management's assessment of the effectiveness
of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered
public accounting firm that prepared or issued its audit report.

 If
securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the
registrant included in the filing reflect the correction of an error to previously issued financial statements.

by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation
received by any of the registrant's executive officers during the relevant recovery period pursuant to §240.10D-1(b).

by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes
 No

 Aggregate
market value of the registrant's shares outstanding based upon the closing price of a share on June 30, 2024 as reported
by the NYSE Arca, Inc. on that date: $ 283,974,375.

 As
of February 26, 2025, abrdn Palladium ETF Trust had 3,887,500 abrdn Physical Palladium Shares ETF outstanding.

 DOCUMENTS
INCORPORATED BY REFERENCE: None

 FORWARD
LOOKING STATEMENTS

 This
Annual Report on Form 10-K contains various "forward-looking statements" within the meaning of Section 27A of the
Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and within the Private
Securities Litigation Reform Act of 1995, as amended. Forward-looking statements usually include the words, "anticipates,"
"believes," "estimates," "expects," "intends," "plans," "projects,"
"understands" and other words suggesting uncertainty. We remind readers that forward-looking statements are merely
predictions and therefore inherently subject to uncertainties and other factors and involve known and unknown risks that could
cause the actual results, performance, levels of activity, or our achievements, or industry results, to be materially different
from any future results, performance, levels of activity, or our achievements expressed or implied by such forward-looking statements.
Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date hereof.
The Trust undertakes no obligation to publicly release any revisions to these forward-looking statements to reflect events or
circumstances after the date hereof or to reflect the occurrence of unanticipated events.

 Additional
significant uncertainties and other factors affecting forward-looking statements are presented in the Risk Factors section herein.

 TABLE
OF CONTENTS

 Item 1. Business

 Trust Objective

 Overview of the Palladium Industry

 Operation of the Palladium Bullion Market

 Secondary Market Trading

 Valuation of Palladium and Computation of Net Asset Value

 Trust Expenses

 Creation and Redemption of Shares

 Creation and Redemption Transaction Fee

 The Sponsor

 The Trustee

 The Custodian

 Inspection of Palladium

 Description of Shares

 Custody of the Trust's Palladium

 United States Federal Income Tax Consequences

 ERISA and Related Considerations

 Item 1A. Risk Factors

 Item 1B. Unresolved Staff Comments

 Item 1C. Cybersecurity

 Item 2. Properties

 Item 3. Legal Proceedings

 Item 4. Mine Safety Disclosures

 Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities

 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations

 Item 7A. Quantitative and Qualitative Disclosures about Market Risk

 Item 8. Financial Statements and Supplementary Data

 Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosures

 Item 9A. Controls and Procedures

 Item 9B. Other Information

 Item 10. Directors, Executive Officers and Corporate Governance

 Item 11. Executive Compensation

 Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

 Item 13. Certain Relationships and Related Transactions, and Director Independence

 Item 14. Principal Accounting Fees and Services

 Item 15. Exhibits, Financial Statement Schedule

 Item 16. Form 10-K Summary

 PART
I

 Item
1. Business

 The
purpose of the abrdn Palladium ETF Trust (the "Trust") is to own palladium transferred to the Trust in exchange
for shares issued by the Trust ("Shares"). Each Share represents a fractional undivided beneficial interest in and
ownership of the Trust. The assets of the Trust consist solely of palladium bullion. The Trust was formed on December
30, 2009 when an initial deposit of palladium was made in exchange for the issuance of two Baskets (a "Basket" consisted
of 50,000 Shares).

 The
sponsor of the Trust is abrdn ETFs Sponsor LLC (the "Sponsor"). The trustee of the Trust is The Bank of New York Mellon
(the "Trustee") and the custodian is ICBC Standard Bank Plc (the "Custodian" or "ICBC").

 The
Trust's Shares at redeemable value increased from $219,309,330 at December 31, 2023 to $354,057,800 at December 31, 2024,
the Trust's fiscal year end. Outstanding Shares in the Trust increased from 2,100,000 Shares at December 31, 2023 to 4,262,500
Shares at December 31, 2024.

 The
Trust is not managed like a corporation or an active investment vehicle. The Trust has no directors, officers or employees. It
does not engage in any activities designed to obtain a profit from or to improve the losses caused by changes in the price of palladium.
The palladium held by the Trust will only be delivered to pay the remuneration due to the Sponsor (the "Sponsor's
Fee"), distributed to Authorized Participants (defined below) in connection with the redemption of Baskets or sold (1) on
an as-needed basis to pay Trust expenses not assumed by the Sponsor, (2) in the event the Trust terminates and liquidates its
assets, or (3) as otherwise required by law or regulation.

 The
Trust is not registered as an investment company under the Investment Company Act of 1940 and is not required to register under
such act. The Trust does not and will not hold or trade in commodities futures contracts, "commodity interests" or
any other instruments regulated by the Commodity Exchange Act (the "CEA"), as administered by the Commodity Futures
Trading Commission (the "CFTC") and the National Futures Association ("NFA"). The Trust is not a commodity
pool for purposes of the CEA and the Shares are not "commodity interests," and neither the Sponsor nor the Trustee
is subject to regulation as a commodity pool operator or a commodity trading advisor in connection with the Shares. The Trust
has no fixed termination date.

 The
Sponsor of the registrant maintains an Internet website at www.abrdn.com/us/etf through which the registrant's annual reports
on Form 10-K, quarterly reports on Form 10-Q, and amendments to those reports filed or furnished pursuant to Section 13(a) or
15(d) of the Securities Exchange Act of 1934, as amended, or the Exchange Act, are made available free of charge as soon as reasonably
practicable after they have been filed or furnished to the Securities and Exchange Commission (the "SEC"). The SEC maintains an internet site that contains reports, proxy and information statements, and other information regarding issuers that
file electronically at www.sec.gov.

 Trust
Objective

 The
investment objective of the Trust is for the Shares to reflect the performance of the price of physical palladium, less the
Trust's expenses. The Shares are intended to constitute a simple and cost-effective means of making an investment similar
to an investment in physical palladium. An investment in physical palladium requires expensive and sometimes complicated
arrangements in connection with the assay, transportation, warehousing and insurance of the metal. Traditionally, such expense
and complications have resulted in investments in physical palladium being efficient only in amounts beyond the reach of
many investors.

 The
Shares are intended to provide institutional and retail investors with a simple and cost-efficient means, with minimal credit
risk, of gaining investment benefits similar to those of holding palladium bullion. The Shares offer an investment that:

 Easily
Accessible and Relatively Cost Effective. Investors can access the palladium bullion market through a traditional brokerage
account. The Sponsor believes that investors will be able to more effectively implement strategic and tactical asset allocation strategies
that use palladium bullion by using the Shares instead of using the traditional means of purchasing, trading and holding palladium
bullion and for many investors, transaction costs related to the Shares will be lower than those associated with the purchase, storage
and insurance of physical palladium bullion.

 Exchange
Traded and Transparent. The Shares trade on the NYSE Arca, providing investors with an efficient means to implement various investment
strategies. The Shares are eligible for margin accounts and are backed by the assets of the Trust and the Trust does not hold or employ
any derivative securities. Furthermore, the value of the Trust's holdings are reported on the Trust's website daily.

 Minimal
Credit Risk. The Shares represent an interest in physical palladium owned by the Trust (other than an amount held in unallocated
form which is not sufficient to make up a whole plate or ingot of which is held temporarily to effect a creation or redemption of
Shares). Physical palladium of the Trust in the Custodian's possession is not subject to borrowing arrangements with third
parties. Other than the palladium temporarily being held in an unallocated palladium account with the Custodian, the physical palladium
of the Trust is not subject to counterparty or credit risks. See "Risk Factors—Palladium held in the Trust's unallocated palladium
account and any Authorized Participant's unallocated palladium account is not segregated from the Custodian's assets..."
 This contrasts with most other financial products that gain exposure to palladium through the use of derivatives that are subject
to counterparty and credit risks.

 Investing
in the Shares does not insulate the investor from certain risks, including price volatility. See "Risk Factors."

 Overview
of the Palladium Industry

 This
section provides a brief introduction to the palladium industry by looking at some of the key participants, detailing the primary
sources of demand and supply.

 In
this annual report, the term "ounces" refers to troy ounces.

 Platinum Group
Metals

 Platinum
and palladium are the two best known metals of the six platinum group metals ("PGMs"). Platinum and palladium have
the greatest economic importance and are found in the largest quantities. The other four—iridium, rhodium, ruthenium and
osmium—are produced only as co-products of platinum and palladium. PGMs are known for their purity, high melting points
and unique catalytic properties. In addition to their oxidation and reduction properties, they are also extremely resistant to
corrosion. PGMs are utilized in a number of industrial processes, technologies and commercial applications. Their unique chemical
and physical properties make PGMs an excellent raw material, catalyst and ingredient for manufacturing processes. Consumer and
industrial products made with palladium and other PGMs include flat panel monitors, glass fiber, medical tools, computer hard
drives, nylon and razors, among others. PGMs play a critical role in autocatalysis and pollution control in the automotive sector.

 PGM
mining is heavily concentrated in southern Africa (South Africa and Zimbabwe), with smaller percentages coming from the United
States, Russia and other locations. South Africa is the world's leading platinum producer and one of the largest palladium producers.
Russia is the second largest producer of platinum. All of South Africa's production is sourced from the Bushveld Igneous Complex,
which hosts the world's largest resource of PGMs. Together, South Africa and Russia accounted for over 77% of palladium supply
in 2023.

 World
Palladium Supply and Demand 2014-2023

 The
following table sets forth a summary of the world palladium supply and demand from 2014 - 2023 and is based on information reported
by Johnson Matthey, PGM Market Report.

 (thousands of ounces)

 2014

 2015

 2016

 2017

 2018

 2019

 2020

 2021

 2022

 2023

 Supply

 South Africa

 2,126

 2,683

 2,570

 2,547

 2,543

 2,571

 1,975

 2,645

 2,276

 2,347

 Russia

 2,589

 2,434

 2,781

 2,452

 2,976

 2,987

 2,636

 2,689

 2,300

 2,700

 North America

 1,035

 1,042

 Zimbabwe

 Others

 Total Supply

 6,093

 6,455

 6,793

 6,472

 7,082

 7,119

 6,196

 6,846

 6,026

 6,547

 Secondary supply

 Automotive

 2,077

 1,952

 1,986

 2,357

 2,624

 2,916

 2,691

 2,886

 2,728

 2,334

 Electronics/other

 Jewellery

 Total secondary supply

 2,640

 2,473

 2,488

 2,857

 3,111

 3,405

 3,127

 3,338

 3,193

 2,807

 Total combined supply

 8,733

 8,928

 9,281

 9,329

 10,193

 10,524

 9,323

 10,184

 9,219

 9,354

 Demand by Application

 Auto

 7,487

 7,657

 8,019

 8,423

 8,837

 9,675

 8,570

 8,501

 8,460

 8,745

 Chemical

 Dental & Biomedical

 Electrical & Electronics

 (659
)

 (646
)

 (386
)

 (574
)

 (87
)

 (190
)

 (109
)

 Jewellery

 Pollution Control

 Other

 Total Demand

 10,589

 9,204

 9,473

 10,050

 10,351

 11,485

 10,005

 10,268

 9,975

 10,371

 Movements in stocks

 (1,856
)

 (276
)

 (192
)

 (721
)

 (158
)

 (961
)

 (682
)

 (84
)

 (756
)

 (1,017
)

 Source: Johnson Matthey PGM Market Reports
(2014 – 2023).

 The
following are some of the main characteristics of the palladium market illustrated by the table:

 Russia has traditionally been the largest producer of palladium, providing on average 40% of supply over the past 10 years. South Africa
has, on average, supplied approximately 37% of production over the past 10 years. In 2023, Russia provided 41.2% of mine supplies, while
South Africa produced 35.8%. North America contributed approximately 13.2% of mine supply in 2023. Scrap supply, from recycling of autocatalyst
and other sources, accounted for roughly 30% of total supply in 2023 down from a high of 34.6% in 2022.

 Autocatalysts continue to be the largest component of palladium demand, averaging 84.3% of total demand from 2015 to 2023, compared to
71% in 2014. Jewelry demand for palladium has tapered off considerably over the last 10 years, contributing only 0.8% of total demand
in 2023, down from a high of 2.6% in 2014. Other industrial demand (chemical, dental and electrical) has fallen from 19.8% of total demand
in 2015 to 12% of total demand in 2023. Since 2014, pollution control demand has increased from 0.5% to 1.3% of total demand. Pollution
control demand captures the production demand for emissions control in non-automotive applications.

 Historical
Chart of the Price of Palladium

 The
price of palladium is volatile and fluctuations are expected to have a direct impact on the value of the Shares. However, movements
in the price of palladium in the past are not a reliable indicator of future movements. The following chart illustrates the movements
in the price of an ounce of palladium in U.S. Dollars from December 31, 2014 to December 31, 2024 and is based on information
provided by Bloomberg:

 The following is a discussion of the movements in the price of Palladium illustrated by the table:

 Rising
palladium prices tempered in 2011, but concerns over supply shortages due to labor problems at mines in South Africa and dwindling
Russian stocks provided some price support into mid-2012. Palladium rose to a 13 year high of $907 per ounce in September 2014,
a 27% increase from the start of the year. The rally was driven by supply side concerns following the longest strike in South
African mining history and escalating tensions between Russia and Ukraine. The strong rally in 2014 was completely unwound in
2015, when South African mine supply resumed back to pre-strike levels and pessimism about industrial demand in China overwhelmed
the true tightness in the market. Palladium was then the top performer of the precious metals complex for 3 consecutive years
from 2017 to 2019, where it rose nearly 182% from $676 per troy ounce on December 31, 2016 to $1,905 per troy ounce on December
31, 2019. The price of palladium reached an all-time high of $2,781/oz on February 19, 2020, before closing out the year at a
price of $2,342/oz on December 31, 2020. Similar to other precious metals, palladium took a step back in 2021 as it returned -16%
(as of December 31, 2021). A decline in autocatalyst demand due to the pandemic was a big reason for the negative performance
seen during the year.

 The
price of palladium reached a record high of $3,015 per ounce on March 7, 2022, as Russian's invasion of Ukraine infused uncertainty
into global markets and created additional price pressure that pushed the price of palladium nearly 53% above its 2021 close.
While each of the precious metals (gold, silver, platinum) saw prices fluctuate throughout the year, the price of palladium showed
greater correlation with the price of Platinum during the first quarter. The price of palladium fell by roughly 25% between March
8th and March 31st, ending the first quarter at a price of $2,259 per ounce. On June 14th, 2022 the price of palladium fell as
low as $1,810 per ounce, as aggressive interest rate policies from the U.S. Federal Reserve drove the U.S. Dollar higher. Contrary
to the other three precious metals, the price of palladium increased as high as $2,315 per ounce on October 4th, 2022, as supplies
were further constrained by operational challenges in South African and North American mines, as well as a weaker automotive recycling
market. Throughout the year, tailwinds from supply disruptions were countered by weaker automotive and investment demand, higher
interest rates and the risk of a potential recession. As a result, while the other three precious metals rallied to end the year,
the price of palladium reversed course during the fourth quarter to end the year at $1,775 per ounce, down 10% from the end of
2021.

 In
2023, palladium production in Russia and South Africa have continued to impact global supply. Russian production was relatively
flat compared to 2020 and 2021, however sanctions imposed in 2022 constrained the production capacity of Russian metals producer
Nornickel, the world's largest palladium producer. In contrast, South Africa continues to experience power supply disruptions
along with rising electricity prices. Coupled with labor strikes, political instability, inflation and volatile prices, which
have compressed profit margins and subsequently led to a decrease in expected supply from the world's second leading producer.
However, despite the supply deficit, investors have sold short a large amount of palladium this year, in hopes that electric vehicles
will curtail the demand for palladium in gasoline-powered automobiles. Additionally, while a positive outlook at the beginning
of the year, fueled by China's loosening of COVID-19 related restrictions, drove the price as high as $1,628 per ounce on April
21, 2023, the Chinese economic rebound disappointed investors. As a result of these two factors, the price of palladium continued
on a downward trend throughout most of the year before reaching a low of $957 per ounce on December 6, 2023. Fears of additional
Russian sanctions sparked a year-end rally that saw the price climb as high as $1,221 per ounce on December 20, 2023, but the
precious metal ultimately ended the year at $1,136 per ounce, 36% below its 2022 closing price.

 In 2024, palladium markets continued to be volatile as the market remained net short and prices have not responded to the existing supply
side deficit as the market works through above ground stockpiles. While autocatalyst demand continues to be the largest component of palladium
demand, it has not yet returned to pre-pandemic levels, and the price remained between $850 and $1,050 per ounce for much of the year.
In October, the threat of potential new sanctions on Russian exports, which accounts for roughly 40% of new mined supply, sent the price
as high as $1,222 per ounce on October 29, 2024, as short sellers bought long contracts to reduce their positions. However, once market
fears about disruptions in supply dissipated the spot price retreated and ultimately ended the year at $909 per ounce on December 31,
2024 (-19.98%).

 Operation
of the Palladium Bullion Market

 The
global trade in palladium consists of Over-the-Counter ("OTC") transactions in spot, forwards, and options and
other derivatives, together with exchange-traded futures and options.

 Global
Over-The-Counter Market

 The
OTC market trades on a 24-hour per day continuous basis and accounts for most global palladium trading. Market makers, as well
as others in the OTC market, trade with each other and with their clients on a principal-to-principal basis. All risks and issues
of credit are between the parties directly involved in the transaction. Market makers include the market-making members of the
London Platinum and Palladium Market ("LPPM"), the trade association that acts as the coordinator for activities conducted
on behalf of its members and other participants in the LPPM. Five member participants of the LPPM are currently participating
in the electronic LBMA Palladium Price PM process (as described below) administered by the London Metal Exchange ("LME"). The OTC
market provides a relatively flexible market in terms of quotes, price, size, destinations for delivery and other factors. Bullion
dealers customize transactions to meet clients' requirements. The OTC market has no formal structure and no open-outcry
meeting place.

 The
main centers of the OTC market for palladium are London, New York, Hong Kong and Zurich. Mining companies, manufacturers of jewelry
and industrial products, together with investors and speculators, tend to transact their business through one of these market
centers. Centers such as Dubai and several cities in the Far East also transact substantial OTC market business, typically involving
jewelry and small plates or ingots of palladium (1 kilogram or less) and will hedge their exposure by selling into one of these
main OTC centers. Precious metals dealers have offices around the world and most of the world's major bullion dealers are
either members or associate members of the London Bullion Market Association ("LBMA") and/or the LPPM. In the OTC
market for palladium, the standard size of trades between market makers is 1,000 ounces.

 Liquidity
in the OTC market can vary from time to time during the course of the 24-hour trading day. Fluctuations in liquidity are reflected
in adjustments to dealing spreads—the differential between a dealer's "buy" and "sell" prices.
The period of greatest liquidity in the palladium market generally occurs at the time of day when trading in the European time
zones overlaps with trading in the United States, which is when OTC market trading in London, New York, Zurich and other centers
coincides with futures and options trading on the Commodity Exchange, Inc. ("COMEX"), a designated contract market
within the CME Group. This period lasts for approximately four hours each New York business day morning.

 The
Zurich and London Palladium Bullion Markets

 Although the market for physical palladium is distributed globally, most palladium is stored and most OTC market trades are cleared through
London and Zurich. In addition to coordinating market activities, the LPPM acts as the principal point of contact between the market and
its regulators. A primary function of the LPPM is its involvement in the promotion of refining standards by maintenance of the "London/Zurich
Good Delivery Lists," which are the lists of LPPM accredited refiners of palladium. The LPPM also coordinates market clearing and
vaulting, promotes good trading practices and develops standard documentation.

 Palladium is traded generally on a "loco London" or "loco Zurich" basis, meaning the precious metal is physically
held in vaults in London or Zurich or is transferred into accounts established in London or Zurich. Delivery of the palladium can either
be by physical delivery or through the clearing systems to an unallocated account.

 The
unit of trade in London and Zurich is the troy ounce, whose conversion between grams is: 1,000 grams equals 32.1507465 troy ounces,
and one troy ounce equals 31.1034768 grams. A good delivery palladium plate or ingot on the LPPM approved list is acceptable for
delivery in settlement of a transaction on the OTC market (a "Good Delivery Plate or Ingot"). A Good Delivery Plate
or Ingot must contain between 32 and 192.904 troy ounces of palladium with a minimum fineness (or purity) of 999.5 parts per 1,000
(99.95%), be of good appearance, and be easy to handle and stack. The palladium content of a palladium plate or ingot is calculated
by multiplying the gross weight by the fineness of the plate or ingot. A Good Delivery Plate or Ingot must also bear the stamp
of one of the refiners who are on the LPPM approved list. Unless otherwise specified, the palladium spot price always refers to
that of "Good Delivery Standards" set by the LPPM. Business is generally conducted over the phone and through electronic
dealing systems.

 Since
December 1, 2014, the LME has been administering the operation of electronic palladium bullion price fixing system ("LMEbullion")
that replicate electronically the manual London palladium fix processes previously employed by the London Platinum and Palladium
Fixing Company Ltd ("LPPFCL") as well as providing electronic market clearing processes for palladium bullion transactions
at the fixed prices established by the LME pricing mechanism. The LME's electronic price fixing processes, like the previous
London palladium fix processes, establishes and publishes fixed prices for troy ounces of palladium twice each London trading
day during fixing sessions beginning at 9:45 a.m. London time (the "LBMA Palladium Price AM") and 2:00 p.m. London time (the "LBMA Palladium Price PM"). In
addition to utilizing the same London palladium fix standards and methods, the LME also supervises the palladium electronic price
fixing processes through its market operations, compliance, internal audit and third-party complaint handling capabilities in
order to support the integrity of the "LBMA Palladium Price PM". The LME, in administering LMEbullion, uses a pricing methodology that meets
the administrative and regulatory needs of palladium market participants, including the International Organization of Securities
Commission's (IOSCO) Principles for Financial Benchmark, (the "IOSCO Principles").

 Daily
during London trading hours the LBMA Palladium Price AM and the LBMA Palladium Price PM each provide reference palladium prices for that day's trading.
Many long-term contracts will be priced on the basis of either the LBMA Palladium Price AM or the LBMA Palladium Price PM, and market participants will
usually refer to one or the other of these prices when looking for a basis for valuations. The Trust values its palladium on the
basis of the LBMA Palladium Price PM. If there is no LME PM Price on any day, the Trust will value its palladium on the basis of LBMA Palladium Price AM
announced on that day. If neither price is available for that day, the Trust will value its palladium based on the most recently
announced LBMA Palladium Price PM price or LBMA Palladium Price AM price.

 Formal
participation in the LBMA Palladium Price PM is limited to participating LPPM members. Five LPPM members are currently participating in establishing
the LBMA Palladium Price PM (Goldman Sachs International, HSBC Bank USA NA, ICBC Standard Bank plc, Johnson Matthey plc and BASF Metals Ltd.).
Any other market participant wishing to participate in the trading on the LBMA Palladium Price PM is required to do so through one of the participating
LPPM members.

 Orders
are placed either with one of the participating LPPM member participants or with another precious metals dealer who will then
be in contact with a participating LPPM member during the fixing. The fix begins with the chair reflecting the market price and
other data, prevailing at the opening of the fix. This is relayed by the LPPM member participants to their dealing rooms which
have direct communication with all interested parties. Any market member may enter the fixing process at any time, or adjust or
withdraw his order. The palladium price is adjusted up or down until all the buy and sell orders are electronically matched, at
which time the price is declared fixed. All fixing orders are transacted on the basis of this fixed price, which is instantly
relayed to the market through various media.

 The
LBMA and the LME have asserted that the LME's electronic price fixing processes are similar to the non-electronic processes
previously used to establish the applicable London palladium fix where the London palladium fix process adjusted the palladium
price up or down until all the buy and sell orders entered by the participating LPPM members are matched, at which time the price
was declared fixed. Nevertheless, the LBMA Palladium Price PM has several advantages over the previous London palladium fix. The LME's
electronic price fixing processes are intended to be transparent. The LME asserts that its electronic price fixing processes are
fully auditable by third parties since an audit trail exists from the beginning of each fixing session. The LME also asserts that
the market operation, compliance, internal audit and third-party complaint handling capabilities of the LME supports the integrity
of the LBMA Palladium Price PM.

 Since
December 1, 2014, the Sponsor determined that the London palladium fix, which has been revised based on the new LME method and is
now known as the LBMA Palladium Price PM, is an appropriate basis for valuing palladium bullion received upon purchase of the Trust's
Shares, delivered upon redemption of the Trust's Shares and for determining the value of the Trust's palladium bullion
each trading day. The Sponsor also determined that the LBMA Palladium Price PM fairly represents the commercial value of Palladium
bullion held by the Trust and the "Benchmark Price" (as defined inTrust Agreement) as of any day is such day's
LBMA Palladium Price PM or such day's LBMA Palladium Price AM if such day's LBMA Palladium Price PM is not
available.

 As
of December 1, 2014, the LPPFCL transferred ownership of the historic and future intellectual property of the twice daily "fix"
for platinum and palladium bullion to a subsidiary company of the LBMA.

 Futures
Exchanges

 The
most significant palladium futures exchanges are the COMEX, a designated contract market within the CME Group, and the Tokyo
Commodity Exchange ("TOCOM"). The COMEX is the largest exchange in the world for trading precious metals futures and
options and launched palladium futures in 1968, followed with options in 2010. The TOCOM has been trading palladium since 1992.
Trading on these exchanges is based on fixed delivery dates and transaction sizes for the futures and options contracts traded.
Trading costs are negotiable. As a matter of practice, only a small percentage of the futures market turnover ever comes to physical
delivery of the palladium represented by the contracts traded. Both exchanges permit trading on margin. Margin trading can add
to the speculative risk involved given the potential for margin calls if the price moves against the contract holder. The COMEX
trades palladium futures almost continuously (with one short break in the evening) through its CME Globex electronic trading system
and clears through its central clearing system. On June 6, 2003, the TOCOM adopted a similar clearing system. In each case, the
exchange acts as a counterparty for each member for clearing purposes.

 Market
Regulation

 The
global palladium markets are overseen and regulated by both governmental and self-regulatory organizations. In addition,
certain trade associations have established rules and protocols for market practices and participants. In the United Kingdom,
responsibility for the regulation of the financial market participants, including the major participating members of the LPPM
falls under the authority of the Financial Conduct Authority ("FCA") as provided by the Financial Services
and Markets Act 2000 ("FSM Act"). Under this act, all U.K.-based banks, together with other investment firms, are
subject to a range of requirements, including fitness and properness, capital adequacy, liquidity, and systems and controls.

 The
FCA is responsible for regulating investment products, including derivatives, and those who deal in investment products. Regulation
of spot, commercial forwards, and deposits of palladium not covered by the FSM Act is provided for by The London Code of
Conduct for Non-Investment Products, which was established by market participants in conjunction with the Bank of England.

 The
TOCOM has authority to perform financial and operational surveillance on its members' trading activities, scrutinize positions
held by members and large-scale customers, and monitor the price movements of futures markets by comparing them with cash and
other derivative markets' prices. To act as a Futures Commission Merchant Broker on the TOCOM, a broker must obtain a license
from Japan's Ministry of Economy, Trade and Industry ("METI"), the regulatory authority that oversees the operations
of the TOCOM.

 The
CFTC regulates trading in commodity contracts, such as futures, options and swaps. In addition, under the CEA, the CFTC has jurisdiction
to prosecute manipulation and fraud in any commodity (including precious metals) traded in interstate commerce as spot as well
as deliverable forwards. The CFTC is the exclusive regulator of U.S. commodity exchanges and clearing houses.

 Secondary
Market Trading

 While
the Trust's investment objective is for the Shares to reflect the performance of the price of physical palladium, less
the Trust's expenses, the Shares may trade in the secondary market on the NYSE Arca at prices that are lower or higher relative
to their net asset value (the value of the Trust's assets less its liabilities ("NAV")) per Share. The amount
of the discount or premium in the trading price relative to the NAV per Share may be influenced by non-concurrent trading hours
between the NYSE Arca, COMEX and the London and Zurich palladium markets. While the Shares trade on the NYSE Arca until
4:00 PM New York time, liquidity in the global palladium market is reduced after the close of the COMEX at 1:30 PM New York
time. As a result, during this time, trading spreads, and the resulting premium or discount, on the Shares may widen.

 Valuation
of Palladium and Computation of Net Asset Value

 On
each day that the NYSE Arca is open for regular trading, as promptly as practicable after 4:00 p.m., New York time, on such day
(the "Evaluation Time"), the Trustee evaluates the palladium held by the Trust and determines both the adjusted net
asset value ("ANAV") and the NAV of the Trust. For the purposes of making these calculations, a business day means
any day other than a day when NYSE Arca is closed for regular trading.

 At
the Evaluation Time, the Trustee values the Trust's palladium on the basis of that day's LBMA Palladium Price PM or, if no LBMA Palladium Price PM Fix is made on such day, or has not been announced by the Evaluation Time, the LBMA Palladium Price AM announced on that day will be used.
If neither price is available for that day, the Trust will value its palladium based on the most recently announced LBMA Palladium Price PM
or LBMA Palladium Price AM, unless the Sponsor determines that such price is inappropriate as a basis for evaluation. In the event the Sponsor
determines that the applicable LBMA Palladium Price PM or such other publicly available price as the Sponsor may deem fairly represents the
commercial value of the Trust's palladium is not an appropriate basis for evaluation of the Trust's palladium, it
shall identify an alternative basis for such evaluation to be employed by the Trustee. Neither the Trustee nor the Sponsor shall
be liable to any person for the determination that the LBMA Palladium Price PM or such other publicly available price is not appropriate as
a basis for evaluation of the Trust's palladium or for any determination as to the alternative basis for such evaluation
provided that such determination is made in good faith. See "Operation of the Palladium Market—The Zurich and London
Palladium Bullion Markets" for a description of the LBMA Palladium Price PM.

 Once
the value of the palladium has been determined, the Trustee subtracts all estimated accrued but unpaid fees (other than
the fees accruing for such day on which the valuation takes place which are computed by reference to the value of the Trust
or its assets), expenses and other liabilities of the Trust from the total value of the palladium and any other assets
of the Trust. The resulting figure is the ANAV of the Trust. The ANAV of the Trust is used to compute the Sponsor's Fee.

 All
fees accruing for the day on which the valuation takes place which are computed by reference to the value of the Trust or
its assets are calculated using the ANAV calculated for such day. The Trustee subtracts from the ANAV the amount of accrued fees
so computed for such day and the resulting figure is the NAV of the Trust. The Trustee also determines the NAV per Share
by dividing the NAV of the Trust by the number of the Shares outstanding as of the close of trading on the NYSE Arca (which includes
the net number of any Shares created or redeemed on such evaluation day).

 Any
estimate of the accrued but unpaid fees, expenses and liabilities of the Trust for purposes of computing the NAV of the Trust
and ANAV made by the Trustee in good faith shall be conclusive upon all persons interested in the Trust and no revision or correction
in any computation made under the Trust Agreement will be required by reason of any difference in amounts estimated from those
actually paid.

 The
Sponsor and the Shareholders may rely on any evaluation furnished by the Trustee, and the Sponsor has no responsibility for the
evaluation's accuracy. The determinations the Trustee makes will be made in good faith upon the basis of, and the Trustee
will not be liable for any errors contained in, information reasonably available to it. The Trustee will not be liable to the
Sponsor, The Depository Trust Company ("DTC"), Authorized Participants, the Shareholders or any other person for errors in judgment. However, the preceding liability
exclusion will not protect the Trustee against any liability resulting from bad faith or gross negligence in the performance of
its duties.

 On May 23, 2024, the Sponsor entered into an Amendment (the "Trust Amendment") to the Depositary Trust Agreement (the "Trust
Agreement") with the Trustee. The Trust Amendment reflects the following changes, effective as of June 18, 2024, as approved and
directed by the Sponsor on behalf of the Trust: (1) the amendment of the definition of "Benchmark Price" to mean, "as
of any day, (i) such day's LBMA Palladium Price PM or such day's LBMA Palladium Price AM if such day's LBMA Palladium
Price PM is not available; or (ii) such other publicly available price which is reasonably available to the Trustee at no cost to the
Trustee and which the Sponsor may determine fairly represents the commercial value of palladium held by the Trust and instructs the Trustee
to use as the Benchmark Price"; (2) the deletion and replacement of the defined term for "London PM Fix" with the defined
term "LBMA Palladium Price PM", which means "the price of a troy ounce of palladium as determined by the LME, the third
party administrator of the London palladium price selected by the LBMA, or any successor administrator of the London palladium price,
at or about 2:00 p.m. London, England time"; and (3) the addition of the new definition for "LBMA Palladium Price AM"
which means "the price of a troy ounce of palladium as determined by the LME, the third party administrator of the London palladium
price selected by the LBMA, or any successor administrator of the London palladium price, at or about 9:45 a.m. London, England time.

 Trust
Expenses

 The
Trust's only ordinary recurring expense is the Sponsor's Fee. In exchange for the Sponsor's Fee, the Sponsor
has agreed to assume the following administrative and marketing expenses incurred by the Trust: the Trustee's monthly fee
and out-of-pocket expenses, the Custodian's fee and reimbursement of the Custodian's expenses under the Custody Agreements,
Exchange listing fees, SEC registration fees, printing and mailing costs, audit fees and up to $100,000 per annum in legal expenses.
The Sponsor also paid the costs of the Trust's organization and the initial sale of the Shares, including the applicable SEC registration
fees.

 The
Sponsor's Fee accrues daily at an annualized rate equal to 0.60% of the ANAV of the Trust and is payable monthly in arrears.
The Sponsor, from time to time, may temporarily waive all or a portion of the Sponsor's Fee at its discretion for a stated
period of time. Presently, the Sponsor does not intend to waive any of its fee.

 Furthermore,
the Sponsor may, in its sole discretion, agree to rebate all or a portion of the Sponsor's Fee attributable to Shares held
by institutional investors subject to minimum shareholding and lock up requirements as determined by the Sponsor to foster stability
in the Trust's asset levels. Any such rebate will be subject to negotiation and written agreement between the Sponsor and
the investor on a case by case basis. The Sponsor is under no obligation to provide any rebates of the Sponsor's Fee. Neither
the Trust nor the Trustee will be a party to any Sponsor's Fee rebate arrangements negotiated by the Sponsor. Any Sponsor's
Fee rebate shall be paid from the funds of the Sponsor and not from the assets of the Trust.

 The
Sponsor's Fee is paid by delivery of palladium to an account maintained by the Custodian for the Sponsor on an unallocated
basis, monthly on the first business day of the month in respect of fees payable for the prior month. The delivery is of that
number of ounces of palladium which equals the daily accrual of the Sponsor's Fee for such prior month calculated at the
LBMA Palladium Price PM.

 The
Trustee will, when directed by the Sponsor, and, in the absence of such direction, may, in its discretion, sell palladium
in such quantity and at such times as may be necessary to permit payment in cash of Trust expenses not assumed by the Sponsor.
The Trustee is authorized to sell palladium at such times and in the smallest amounts required to permit such payments as
they become due, it being the intention to avoid or minimize the Trust's holdings of assets other than palladium. Accordingly,
the amount of palladium to be sold will vary from time to time depending on the level of the Trust's expenses and the
market price of palladium. The Custodian is authorized to purchase from the Trust, at the request of the Trustee, palladium
needed to cover Trust expenses not assumed by the Sponsor at the price used by the Trustee to determine the value of the palladium
held by the Trust on the date of the sale.

 The
Sponsor's Fee for the year ended December 31, 2024 was $1,737,833 (December 31, 2023: $1,464,063; December 31, 2022: $2,226,662).

 Cash
held by the Trustee pending payment of the Trust's expenses will not bear any interest. Each delivery or sale of palladium
by the Trust to pay the Sponsor's Fee or other Trust expenses will be a taxable event to Shareholders.

 Creation
and Redemption of Shares

 The
Trust creates and redeems Shares from time to time, but only in one or more Baskets. Effective June 18, 2024, the number of shares in a block that constitutes a basket for the purpose of creations and redemptions in the
Trust was reduced from 25,000 Shares to 12,500 Shares. Prior to May 28, 2024, the number of Shares
that constituted a Basket was 25,000 Shares. Effective April 1, 2019, the Basket size was decreased to 12,500 Shares. The
creation and redemption of Baskets is only made in exchange for the delivery to the Trust or the distribution by the Trust of
the amount of physical palladium represented by the Baskets being created or redeemed, the amount of which is based on the
combined NAV of the number of Shares included in the Baskets being created or redeemed determined on the day the order to create
or redeem Baskets is properly received.

Participants are the only persons that may place orders to create and redeem Baskets. Authorized Participants must be (1) registered
broker-dealers or other securities market participants, such as banks and other financial institutions, which are not required
to register as broker-dealers to engage in securities transactions, and (2) participants in DTC. To become an Authorized Participant,
a person must enter into an Authorized Participant Agreement with the Sponsor and the Trustee. The Authorized Participant Agreement
provides the procedures for the creation and redemption of Baskets and for the delivery of the palladium and any cash required
for such creations and redemptions. The Authorized Participant Agreement and the related procedures attached thereto may be amended
by the Trustee and the Sponsor, without the consent of any Shareholder or Authorized Participant. Authorized Participants pay
a transaction fee of $500 to the Trustee for each order they place to create or redeem one or more Baskets. Authorized Participants
who make deposits with the Trust in exchange for Baskets receive no fees, commissions or other form of compensation or inducement
of any kind from either the Sponsor or the Trust for serving as an Authorized Participant, and no such person has any obligation
or responsibility to the Sponsor or the Trust to effect any sale or resale of Shares.

Participants are cautioned that some of their activities will result in their being deemed participants in a distribution in a
manner which would render them statutory underwriters and subject them to the prospectus-delivery and liability provisions of
the Securities Act.

 Prior
to initiating any creation or redemption order, an Authorized Participant must have entered into an agreement with the Custodian or
a palladium clearing bank to establish an Authorized Participant Unallocated Account in London ("Authorized Participant
Unallocated Bullion Account Agreement"). Authorized Participant Unallocated Accounts may only be used for transactions
with the Trust. Palladium held in Authorized Participant Unallocated Accounts is typically not segregated from the Custodian's
or other palladium clearing bank's assets, as a consequence of which an Authorized Participant will have no proprietary
interest in any specific plates or ingots of palladium held by the Custodian or the clearing bank. Credits to its
Authorized Participant Unallocated Account are therefore at risk of the Custodian's or other palladium clearing
bank's insolvency. No fees will be charged by the Custodian for the use of the Authorized Participant Unallocated Account as
long as the Authorized Participant Unallocated Account is used solely for palladium transfers to and from the Trust Unallocated
Account and the Custodian (or one of its affiliates) receives compensation for maintaining the Trust Allocated Account. Authorized
Participants should be aware that the Custodian's liability threshold under the Authorized Participant Unallocated Bullion
Account Agreement is generally gross negligence, not negligence, which is the Custodian's liability threshold under the
Trust's Custody Agreements.

 As
the terms of the Authorized Participant Unallocated Bullion Account Agreement differ in certain respects from the terms of the
Trust Unallocated Account Agreement, potential Authorized Participants should review the terms of the Authorized Participant Unallocated
Bullion Account Agreement carefully. A copy of the Authorized Participant Agreement may be obtained by potential Authorized Participants
from the Trustee.

 Certain
Authorized Participants are expected to have the facility to participate directly in the physical palladium market and the
palladium futures markets. In some cases, an Authorized Participant may from time to time acquire palladium from or sell palladium
to its affiliated palladium trading desk, which may profit in these instances. Each Authorized Participant must be registered
as a broker-dealer under the Securities Exchange Act of 1934 ("Exchange Act") and regulated by FINRA or be exempt from
being or otherwise not be required to be so regulated or registered, and be qualified to act as a broker or dealer in the
states or other jurisdictions where the nature of its business so requires. Certain Authorized Participants are regulated under
federal and state banking laws and regulations. Each Authorized Participant has its own set of rules and procedures, internal
controls and information barriers as it determines is appropriate in light of its own regulatory regime.

Participants may act for their own accounts or as agents for broker-dealers, custodians and other securities market participants
that wish to create or redeem Baskets. An order for one or more Baskets may be placed by an Authorized Participant on behalf of
multiple clients. As of the date of this report, Goldman Sachs & Co., HSBC Securities (USA) Inc., J.P. Morgan Securities LLC,
Merrill Lynch Professional Clearing Corp., Mizuho Securities USA LLC, Morgan Stanley & Co. Inc., Scotia Capital (USA)
LLC, UBS Securities LLC and Virtu Americas, LLC have each signed an Authorized Participant Agreement with the Trust and,
upon the effectiveness of such agreement, may create and redeem Baskets as described above. Persons interested in purchasing Baskets
should contact the Sponsor or the Trustee to obtain the contact information for the Authorized Participants. Shareholders who
are not Authorized Participants will only be able to redeem their Shares through an Authorized Participant.

 All palladium is
delivered to the Trust and distributed by the Trust in unallocated form through credits and debits between Authorized Participant
Unallocated Accounts and the Trust Unallocated Account. Palladium transferred from an Authorized Participant Unallocated
Account to the Trust in unallocated form will first be credited to the Trust Unallocated Account. Thereafter, the Custodian will
allocate, specific plates or ingots of palladium, in each case representing
the amount of palladium credited to the Trust Unallocated Account (to the extent such amount is representable by palladium
plates or ingots) to the Trust Allocated Account. The movement of palladium is reversed for the distribution of palladium
to an Authorized Participant in connection with the redemption of Baskets.

 All
physical palladium represented by a credit to any Authorized Participant Unallocated Account and to the Trust Unallocated
Account and all physical palladium held in the Trust Allocated Account with the Custodian or for the Custodian by the Zurich
Sub-Custodian must be of at least a minimum fineness (or purity) of 999.5 parts per 1,000 (99.95%) and otherwise conform to the
rules, regulations practices and customs of the LPPM, including the specifications for a Good Delivery Palladium Plate or Ingot.

 Under
the Authorized Participant Agreement, the Sponsor has agreed to indemnify the Authorized Participants against certain liabilities,
including liabilities under the Securities Act.

 The
following description of the procedures for the creation and redemption of Baskets is only a summary and an investor should refer
to the relevant provisions of the Trust Agreement and the form of Authorized Participant Agreement for more detail.

 Creation
Procedures

 On
any business day, an Authorized Participant may place an order with the Trustee to create one or more Baskets. Creation and redemption
orders are accepted on "business days" the NYSE Arca is open for regular trading. Settlements of such orders requiring
receipt or delivery, or confirmation of receipt or delivery, of palladium in the United Kingdom, or another jurisdiction
will occur on "business days" when (1) banks in the United Kingdom, or other jurisdiction and (2) the
London palladium markets are regularly open for business. If such banks or the London palladium markets are
not open for regular business for a full day, such a day will only be a "business day" for settlement purposes if
the settlement procedures can be completed by the end of such day. Redemption settlements including palladium deliveries loco
London may be delayed longer than two, but no more than five, business days following the redemption order date. Settlement of
orders requiring receipt or delivery, or confirmation of receipt or delivery, of Shares will occur, after confirmation of the
applicable palladium delivery, on "business days" when the NYSE Arca is open for regular trading. In the event of
a level 3 market-wide circuit breaker resulting in a trading halt for the remainder of the trading day, the time of the market-wide
trading halt is considered the close of regular trading and no creation orders for the current trade date will be accepted after
that time (the "cutoff"). Orders placed after the cutoff will be deemed to be rejected and will not be processed.
Orders should be placed in proper form on the following business day. Purchase orders must be placed no later than 3:59:59 p.m.
on each business day the NYSE Arca is open for regular trading.

 By
placing a purchase order, an Authorized Participant agrees to deposit palladium with the Trust. Prior to the delivery of Baskets
for a purchase order, the Authorized Participant must also have wired to the Trustee the non-refundable transaction fee due for
the purchase order.

 Determination
of required deposits

 The
amount of the required palladium deposit is determined by dividing the number of ounces of palladium held by the Trust by the
number of Baskets outstanding, as adjusted for the amount of palladium constituting estimated accrued but unpaid fees and expenses
of the Trust.

 Fractions
of a fine ounce of palladium smaller than 0.001 of a fine ounce which are included in the palladium deposit amount are disregarded
in the foregoing calculation. All questions as to the composition of a Creation Basket Deposit will be finally determined by the
Trustee. The Trustee's determination of the Creation Basket Deposit shall be final and binding on all persons interested
in the Trust.

 Delivery
of required deposits

 An
Authorized Participant who places a purchase order is responsible for crediting its Authorized Participant Unallocated Account
with the required palladium deposit amount by the prescribed settlement date in London. Upon receipt of the palladium deposit
amount, the Custodian, after receiving appropriate instructions from the Authorized Participant and the Trustee, will transfer
on the prescribed settlement date the palladium deposit amount from the Authorized Participant Unallocated Account to the Trust
Unallocated Account and the Trustee will direct DTC to credit the number of Baskets ordered to the Authorized Participant's DTC
account. The expense and risk of delivery, ownership and safekeeping of palladium until such palladium has been received by the
Trust shall be borne solely by the Authorized Participant. The Trustee may accept delivery of palladium by such other means as
the Sponsor, from time to time, my determine with the Trustee to be acceptable for the Trust, provided that the same is disclosed
in a prospectus relating to the Trust filed with the SEC pursuant to Rule 424 under the Securities Act. If palladium is to be
delivered other than as described above, the Sponsor is authorized to establish such procedures and to appoint such custodians
and establish such custody accounts in addition to those described in this report, as the Sponsor determines to be desirable.

 Acting
on standing instructions given by the Trustee, the Custodian will transfer the palladium deposit amount from the Trust Unallocated
Account to the Trust Allocated Account by transferring palladium plates and ingots from its inventory to the Trust Allocated Account.
The Custodian uses commercially reasonable efforts to complete the transfer of palladium to the Trust Allocated Account prior
to the time by which the Trustee is to credit the Basket to the Authorized Participant's DTC account; if, however, such
transfers have not been completed by such time, the number of Baskets ordered will be delivered against receipt of the palladium
deposit amount in the Trust Unallocated Account, and all Shareholders will be exposed to the risks of unallocated palladium to
the extent of that palladium deposit amount until the Custodian completes the allocation process. See "Risk Factors—Palladium
held in the Trust's unallocated palladium account and any Authorized Participant's unallocated palladium account is
not segregated from the Custodian's assets "

 Because
palladium is only allocated in multiples of whole plates or ingots, the amount of palladium allocated from the Trust Unallocated
Account to the Trust Allocated Account may be less than the total fine ounces of palladium credited to the Trust Unallocated Account.
Any balance will be held in the Trust Unallocated Account. The Custodian uses commercially reasonable efforts to minimize the
amount of palladium held in the Trust Unallocated Account; no more than 192.904 troy ounces of palladium (maximum weight to make
one Good Delivery Palladium Plate or Ingot) is expected to be held in the Trust Unallocated Account at the close of each business
day.

 Rejection
of purchase orders

 The
Trustee may reject a purchase order or a Creation Basket Deposit if such order or Creation Basket Deposit is not presented in
proper form as described in the Authorized Participant Agreement or if the fulfillment of the order, in the opinion of counsel,
might be unlawful. None of the Trustee, the Sponsor or the Custodian will be liable for the rejection of any purchase order or
Creation Basket Deposit.

 Redemption
Procedures

 The
procedures by which an Authorized Participant can redeem one or more Baskets mirror the procedures for the creation of Baskets.
On any business day, an Authorized Participant may place an order with the Trustee to redeem one or more Baskets. Redemption orders
must be placed no later than 3:59:59 p.m. on each business day the NYSE Arca is open for regular trading. In the event of a level
3 market-wide circuit breaker resulting in a trading halt for the remainder of the trading day, the time of the market wide trading
halt is considered the close of regular trading and no redemption orders for the current trade date will be accepted after that
time (the "cutoff"). Orders placed after the cutoff will be deemed to be rejected and will not be processed. Orders
should be placed in proper form on the following business day. A redemption order so received is effective on the date it is received
in satisfactory form by the Trustee. The redemption procedures allow Authorized Participants to redeem Baskets and do not entitle
an individual Shareholder to redeem any Shares in an amount less than a Basket, or to redeem Baskets other than through an Authorized
Participant.

 By
placing a redemption order, an Authorized Participant agrees to deliver the Baskets to be redeemed through DTC's book-entry system
to the Trust by the prescribed settlement date. Prior to the delivery of the redemption distribution for a redemption order, the
Authorized Participant must also have wired to the Trustee the non-refundable transaction fee due for the redemption order.

 Determination
of redemption distribution

 The
redemption distribution from the Trust consists of a credit to the redeeming Authorized Participant's Authorized Participant
Unallocated Account representing the amount of the palladium held by the Trust evidenced by the Shares being redeemed. Fractions
of a fine ounce of palladium included in the redemption distribution smaller than 0.001 of a fine ounce are disregarded.

 Redemption
distributions will be subject to the deduction of any applicable tax or other governmental charges which may be due.

 Delivery
of redemption distribution

 The
redemption distribution due from the Trust will be delivered to the Authorized Participant on the prescribed settlement date following
a loco London redemption order date if, by 10:00 a.m. New York time on the settlement date, the Trustee's DTC account has been
credited with the Baskets to be redeemed. If a loco swap or physical transfer is necessary to effect a loco London redemption,
the redemption distribution due from the Trust will be delivered to the Authorized Participant on or before the prescribed settlement
date if, by 10:00 a.m. New York time on the prescribed settlement date, the Trustee's DTC account has been credited with the Baskets
to be redeemed. In the event that, by 10:00 a.m. New York time on the prescribed settlement date, the Trustee's DTC account has
not been credited with the total number of Shares corresponding to the total number of Baskets to be redeemed pursuant to such
redemption order, the Trustee shall send to the Authorized Participant and the Custodian via fax or electronic mail message notice
of such fact and the Authorized Participant shall have one business day following receipt of such notice to correct such failure.
If such failure is not cured within such one business day period, the Trustee (in consultation with the Sponsor) will cancel such
redemption order and will send via fax or electronic mail message notice of such cancellation to the Authorized Participant and
the Custodian, and the Authorized Participant will be solely responsible for all costs incurred by the Trust, the Trustee or the
Custodian related to the cancelled order. The Trustee is also authorized to deliver the redemption distribution notwithstanding
that the Baskets to be redeemed are not credited to the Trustee's DTC account by 10:00 a.m. New York time on the prescribed settlement
date if the Authorized Participant has collateralized its obligation to deliver the Baskets through DTC's book entry system on
such terms as the Sponsor and the Trustee may from time to time agree upon.

 The
Custodian transfers the redemption palladium amount from the Trust Allocated Account to the Trust Unallocated Account and, thereafter,
to the redeeming Authorized Participant's Authorized Participant Unallocated Account. The Authorized Participant and the
Trust are each at risk in respect of palladium credited to their respective unallocated accounts in the event of the Custodian's
insolvency. See "Risk Factors—Palladium held in the Trust's unallocated palladium account and any Authorized
Participant's unallocated palladium account is not segregated from the Custodian's assets "

 As
with the allocation of palladium to the Trust Allocated Account which occurs upon a purchase order, if in transferring palladium
from the Trust Allocated Account to the Trust Unallocated Account in connection with a redemption order there is an excess amount
of palladium transferred to the Trust Unallocated Account, the excess over the palladium redemption amount will be held in the
Trust Unallocated Account. The Custodian uses commercially reasonable efforts to minimize the amount of palladium held in the
Trust Unallocated Account; no more than 192.904 ounces of palladium (maximum weight to make one Good Delivery Palladium Plate
or Ingot) is expected to be held in the Trust Unallocated Account at the close of each business day.

 Suspension
or rejection of redemption orders

 The
Trustee may, in its discretion, and will when directed by the Sponsor, suspend the right of redemption, or postpone the redemption
settlement date, (1) for any period during which the NYSE Arca is closed other than customary weekend or holiday closings, or
trading on the NYSE Arca is suspended or restricted or (2) for any period during which an emergency exists as a result of which
delivery, disposal or evaluation of palladium is not reasonably practicable. None of the Sponsor, the Trustee or the Custodian
are liable to any person or in any way for any loss or damages that may result from any such suspension or postponement.

 The
Trustee will reject a redemption order if the order is not in proper form as described in the Authorized Participant Agreement
or if the fulfillment of the order, in the opinion of its counsel, might be unlawful.

 Creation
and Redemption Transaction Fe e

 To
compensate the Trustee for services in processing the creation and redemption of Baskets, an Authorized Participant is required
to pay a transaction fee to the Trustee of $500 per order to create or redeem Baskets. An order may include multiple Baskets.
The transaction fee may be reduced, increased or otherwise changed by the Trustee with the consent of the Sponsor. From time to
time, the Trustee, with the consent of the Sponsor, may waive all or a portion of the applicable transaction fee. The Trustee
shall notify DTC of any agreement to change the transaction fee and will not implement any increase in the fee for the redemption
of Baskets until 30 days after the date of the notice.

 The
Sponsor

 The
Trust's Sponsor is abrdn ETFs Sponsor LLC (known as Aberdeen Standard Investments ETFs Sponsor LLC prior to March 1, 2022 and
ETF Securities USA LLC prior to October 1, 2018), a Delaware limited liability company formed on June 17, 2009.

 The
Sponsor's office is located at c/o abrdn ETFs Sponsor LLC, 1900 Market Street, Suite 200, Philadelphia, PA 19103. Prior
to April 27, 2018, the Sponsor was wholly-owned by ETF Securities Limited, a Jersey, Channel Islands based company. Effective
April 27, 2018, ETF Securities Limited sold its membership interest in the Sponsor to abrdn Inc. (known as Aberdeen Standard Investments
Inc. prior to January 1, 2022), a Delaware corporation. As a result of the sale, abrdn Inc. became the sole member of the Sponsor.
abrdn Inc. is a wholly-owned indirect subsidiary of abrdn plc, which together with its affiliates and subsidiaries, is collectively
referred to as "abrdn." Under the Delaware Limited Liability Company Act and the governing documents of the Sponsor,
the sole member of the Sponsor, abrdn Inc., is not responsible for the debts, obligations and liabilities of the Sponsor solely
by reason of being the sole member of the Sponsor.

 The
Sponsor's Role

 The
Sponsor arranged for the creation of the Trust, and is responsible for the ongoing registration of the Shares for their public
offering in the United States and the listing of the Shares on the NYSE Arca. The Sponsor has agreed to assume generally the
organizational expenses of the Trust and the following administrative and marketing expenses incurred by the Trust: the
Trustee's monthly fee and out-of-pocket expenses, the Custodian's fee and the reimbursement of the Custodian's
expenses under the Custody Agreements, exchange listing fees, SEC registration fees, printing and mailing costs, audit fees and up
to $100,000 per annum in legal expenses. The Sponsor also paid the costs of the Trust's organization and the initial sale of
the Shares, including the applicable SEC registration fees.

 The
Sponsor does not exercise day-to-day oversight over the Trustee or the Custodian. The Sponsor may remove the Trustee and appoint
a successor Trustee (i) if the Trustee ceases to meet certain objective requirements (including the requirement that it have capital,
surplus and undivided profits of at least $150 million), (ii) if, having received written notice of a material breach of its obligations
under the Trust Agreement, the Trustee has not cured the breach within 30 days, or (iii) if the Trustee refuses to consent to
the implementation of an amendment to the Trust's initial Internal Control Over Financial Reporting. The Sponsor also has
the right to replace the Trustee during the 90 days following any merger, consolidation or conversion in which the Trustee is
not the surviving entity or, in its discretion, on the fifth anniversary of the creation of the Trust or on any subsequent third
anniversary thereafter. The Sponsor also has the right to approve any new or additional custodian that the Trustee may wish to
appoint and any new or additional sub-custodian that the Custodian may wish to appoint.

 The
Sponsor or one of its affiliates or agents (1) develops a marketing plan for the Trust on an ongoing basis, (2) prepares marketing
materials regarding the Shares, including the content of the Trust's website and (3) executes the marketing plan for the
Trust.

 The
Trustee

 The
Bank of New York Mellon, a banking corporation organized under the laws of the State of New York with trust powers ("BNYM"),
serves as the Trustee. BNYM has a Trust office at 240 Greenwich Street, New York, NY 10286. BNYM is subject to supervision by
the New York State Financial Services Department and the Board of Governors of the Federal Reserve System. Information regarding
creation and redemption Basket composition, NAV of the Trust, transaction fees and the names of the parties that have each executed
an Authorized Participant Agreement may be obtained from BNYM. A copy of the Trust Agreement is available for inspection at BNYM's
trust office identified above. Under the Trust Agreement, the Trustee is required to have capital, surplus and undivided profits
of at least $150 million.

 The
Trustee's Role

 The
Trustee is generally responsible for the day-to-day administration of the Trust, including keeping the Trust's operational
records. The Trustee's principal responsibilities include (1) transferring the Trust's palladium as needed to pay
the Sponsor's Fee in palladium (palladium transfers are expected to occur approximately monthly in the ordinary course),
(2) valuing the Trust's palladium and calculating the NAV of the Trust and the NAV per Share, (3) receiving and processing
orders from Authorized Participants to create and redeem Baskets and coordinating the processing of such orders with the Custodian
and DTC, (4) selling the Trust's palladium as needed to pay any extraordinary Trust expenses that are not assumed by the
Sponsor, (5) when appropriate, making distributions of cash or other property to Shareholders, and (6) receiving and reviewing
reports from or on the Custodian's custody of and transactions in the Trust's palladium. The Trustee shall, with respect
to directing the Custodian, act in accordance with the instructions of the Sponsor. If the Custodian resigns, the Trustee shall
appoint an additional or replacement Custodian selected by the Sponsor.

 The
Trustee intends to regularly communicate with the Sponsor to monitor the overall performance of the Trust. The Trustee does not
monitor the performance of the Custodian or any other sub-custodian other than to review the reports
provided by the Custodian pursuant to the Custody Agreements. The Trustee, along with the Sponsor, will liaise with the Trust's
legal, accounting and other professional service providers as needed. The Trustee will assist and support the Sponsor with the
preparation of all periodic reports required to be filed with the SEC on behalf of the Trust.

 The
Trustee's monthly fees and out-of-pocket expenses are paid by the Sponsor.

 Affiliates
of the Trustee may from time to time act as Authorized Participants or purchase or sell palladium or Shares for their own
account, as agent for their customers and for accounts over which they exercise investment discretion. Affiliates of the Trustee
are subject to the same transaction fee as other Authorized Participants.

 The
Custodian

 Effective
May 23, 2024, the Trustee, at the direction of the Sponsor, entered into an Allocated Account Agreement and Unallocated Account
Agreement with ICBC providing for the custody of the Trust's palladium. Effective August 8, 2024,
JPMorgan Chase Bank N.A. no longer serves as a custodian of the Trust's palladium.

 ICBC
is a public limited company incorporated under the laws of England and Wales, serves as a Custodian of the Trust's palladium.
ICBC's office is located at 20 Gresham Street, London, EC2V 7JE, United Kingdom.

 The
Custodian's Role

 The
Custodian is responsible for the safekeeping of the Trust's palladium deposited with it by Authorized Participants in connection
with the creation of Baskets. The Custodian facilitates the transfer of palladium in and out of the Trust through the unallocated
palladium accounts it will maintain for each Authorized Participant and the unallocated and allocated palladium accounts it maintains
for the Trust. The Custodian holds at its London, England vault premises that portion of the Trust's allocated palladium
to be held in London. The Custodian is responsible for allocating specific plates or ingots of physical palladium to the Trust's
allocated palladium account. The Custodian provides the Trustee with regular reports detailing the palladium transfers in and
out of the Trust's unallocated and allocated palladium accounts and identifying the palladium plates or ingots held in the
Trust's allocated palladium account.

 The
Custodian's fees and expenses under the Custody Agreements are paid by the Sponsor.

 The
Custodian and its affiliates may from time to time act as Authorized Participants or purchase or sell palladium or Shares for
their own account, as agent for their customers and for accounts over which they exercise investment discretion. The Custodian
and its affiliates are subject to the same transaction fee as other Authorized Participants.

 Inspection
of Palladium

 Under
the Custody Agreements, the Trustee, the Sponsor and the Trust's auditors and inspectors may, only up to twice a year, visit
the premises of the Custodian for the purpose of examining the Trust's palladium and certain related records maintained
by the Custodian. The Trustee and the Sponsor have no right to visit the premises of any sub-custodian for the purposes of examining
the Trust's palladium or any records maintained by the sub-custodian, and no sub-custodian is obligated to cooperate
in any review the Trustee or the Sponsor may wish to conduct of the facilities, procedures, records or creditworthiness of such
sub-custodian.

 The
Sponsor has exercised its right to visit the Custodian in order to examine the palladium and the records maintained by
the Custodian. Inspections were conducted by Bureau Veritas Commodities UK Ltd, a leading commodity inspection and testing
company retained by the Sponsor, as of July 26, 2024 and January 4, 2025. The results can be found on www.abrdn.com/usa/etf.

 There
can be no guarantee that the Sponsor or the Trust's auditors and inspectors will be able to perform physical inspections
of the Trust's palladium as planned. Local policies, regulations, or ordinances, as well as polices or restrictions
adopted by the Custodian or a sub-custodian, may temporarily prevent, or otherwise impair the ability of, the Sponsor or the Trust's
auditors and inspectors, from performing a physical inspection of the Trust's palladium on a desired date. In those
situations, the Sponsor or the Trust's auditors and inspectors may seek to verify the palladium held by the Trust
by alternate means, including through virtual inspections of the Trust's palladium and/or a review of pertinent records.

of the Shares

 General

 The
Trustee is authorized under the Trust Agreement to create and issue an unlimited number of Shares. The Trustee creates Shares
only in Baskets and only upon the order of an Authorized Participant. Effective June 18, 2024, the number of shares in a block that constitutes a basket for the purpose of creations and redemptions in the
Trust was reduced from 25,000 Shares to 12,500 Shares. Prior to June 18, 2024, the number of Shares that constituted a Basket was 25,000
Shares. Effective April 1, 2019, the number of Shares that constitute
a Basket for the purposes of creations and redemptions is 25,000 Shares. Prior to April 1, 2019, a Basket consisted of 50,000
Shares. The Shares represent units of fractional undivided beneficial interest in and ownership of the Trust and have no par value.
Any creation and issuance of Shares above the amount registered on the Trust's then-current and effective registration statement
with the SEC will require the registration of such additional Shares.

of Limited Rights

 The
Shares do not represent a traditional investment and Shareholders should not view them as similar to shares of a corporation operating
a business enterprise with management and a board of directors. Shareholders do not have the statutory rights normally associated
with the ownership of shares of a corporation, including, for example, the right to bring "oppression" or "derivative"
actions. All Shares are of the same class with equal rights and privileges. Each Share is transferable, is fully paid and non-assessable
and entitles the holder to vote on the limited matters upon which Shareholders may vote under the Trust Agreement. The Shares
do not entitle their holders to any conversion or pre-emptive rights, or, except as provided below, any redemption rights or rights
to distributions.

 Distributions

 If
the Trust is terminated and liquidated, the Trustee will distribute to the Shareholders any amounts remaining after the satisfaction
of all outstanding liabilities of the Trust and the establishment of such reserves for applicable taxes, other governmental charges
and contingent or future liabilities as the Trustee shall determine. Shareholders of record on the record date fixed by the Trustee
for a distribution will be entitled to receive their pro rata portion of any distribution.

 Voting
and Approvals

 Under
the Trust Agreement, Shareholders have no voting rights, except in limited circumstances. The Trustee may terminate the Trust
upon the agreement of Shareholders owning at least 75% of the outstanding Shares. In addition, certain amendments to the Trust
Agreement require advance notice to the Shareholders before the effectiveness of such amendments, but no Shareholder vote or approval
is required for any amendment to the Trust Agreement.

 Redemption
of the Shares

 The
Shares may only be redeemed by or through an Authorized Participant and only in Baskets.

 Book-Entry
Form

 Individual
certificates will not be issued for the Shares. Instead, one or more global certificates is deposited by the Trustee with DTC
and registered in the name of Cede & Co., as nominee for DTC. The global certificates evidence all of the Shares outstanding
at any time. Under the Trust Agreement, Shareholders are limited to (1) participants in DTC such as banks, brokers, dealers and
trust companies (DTC Participants), (2) those who maintain, either directly or indirectly, a custodial relationship with a DTC
Participant (Indirect Participants), and (3) those banks, brokers, dealers, trust companies and others who hold interests in the
Shares through DTC Participants or Indirect Participants. The Shares are only transferable through the book-entry system of DTC.
Shareholders who are not DTC Participants may transfer their Shares through DTC by instructing the DTC Participant holding their
Shares (or by instructing the Indirect Participant or other entity through which their Shares are held) to transfer the Shares.
Transfers will be made in accordance with standard securities industry practice.

 Custody
of the Trust's Palladium

 Custody
of the physical palladium deposited with and held by the Trust is provided by the Custodian at its London, England vaults and
by other sub-custodians on a temporary basis. The Custodian is a market maker, clearer and approved weigher under the rules of
the LPPM.

 The
Custodian is the custodian of the physical palladium credited to the Trust Allocated Account in accordance with the Custody Agreements.
The Custodian segregates the physical palladium credited to the Trust's Allocated Account from any other precious metal
it holds or holds for others by entering appropriate entries in its books and records. Under the Custody Agreements, the Trustee,
the Sponsor and the Trust's auditors and inspectors may inspect the vaults of the Custodian. See "Inspection of Palladium".

 The
Custodian, as instructed by the Trustee on behalf of the Trust, is authorized to accept, on behalf of the Trust, deposits of palladium
in unallocated form. Acting on standing instructions specified in the Custody Agreements, the Custodian allocates palladium deposited
in unallocated form with the Trust by selecting plates or ingots of palladium for deposit to the Trust Allocated Account. All
physical palladium allocated to the Trust must conform to the rules, regulations, practices and customs of the LPPM, and the Custodian
must replace any non-conforming palladium with conforming palladium as soon as practical upon a determination by the Custodian
any palladium is non-conforming.

 The
process of withdrawing palladium from the Trust for a redemption of a Basket follows the same general procedure as for depositing palladium
with the Trust for a creation of a Basket, only in reverse. Each transfer of palladium between the Trust Allocated Account
and the Trust Unallocated Account connected with a creation or redemption of a Basket may result in a small amount of palladium
being held in the Trust Unallocated Account after the completion of the transfer. In making deposits and withdrawals between the
Trust Allocated Account and the Trust Unallocated Account, the Custodian will use commercially reasonable efforts to minimize
the amount of palladium held in the Trust Unallocated Account as of the close of each business day. See "Creation and
Redemption of Shares."

 United
States Federal Income Tax Consequences

 The
following discussion of the material US federal income tax consequences generally applies to the purchase, ownership and disposition
of Shares by a US Shareholder (as defined below), and certain US federal income tax consequences that may apply to an investment
in Shares by a Non-US Shareholder (as defined below). The discussion is based on the United States Internal Revenue Code of 1986
as amended (the "Code"). The discussion below is based on the Code, United States Treasury Regulations ("Treasury
Regulations") promulgated under the Code and judicial and administrative interpretations of the Code, all as in effect on
the date of this annual report and all of which are subject to change either prospectively or retroactively. The tax treatment
of Shareholders may vary depending upon their own particular circumstances. Certain Shareholders (including broker-dealers, traders,
banks and other financial institutions, insurance companies, real estate investment trusts, tax-exempt entities, Shareholders
whose functional currency is not the U.S. Dollar or other investors with special circumstances) may be subject to special rules
not discussed below. In addition, the following discussion applies only to investors who hold Shares as "capital assets"
within the meaning of Code section 1221 and not as part of a straddle, hedging transaction or a conversion or constructive sale
transaction. Moreover, the discussion below does not address the effect of any state, local or foreign tax law or any transfer
tax on an owner of Shares. Purchasers of Shares are urged to consult their own tax advisors with respect to all federal, state,
local and foreign tax law or any transfer tax considerations potentially applicable to their investment in Shares.

 For
purposes of this discussion, a "US Shareholder" is a Shareholder that is:

 An
individual who is a citizen or resident of the United States;

 A
corporation (or other entity treated as a corporation for US federal tax purposes) created or organized in or under the laws of the United
States or any political subdivision thereof;

 An
estate, the income of which is includible in gross income for US federal income tax purposes regardless of its source; or

 A
trust, if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more
US persons have the authority to control all substantial decisions of the trust.

 Taxation
of the Trust

 The
Trust is classified as a "grantor trust" for US federal income tax purposes. As a result, the Trust itself is not
subject to US federal income tax. Instead, the Trust's income and expenses "flow through" to the Shareholders,
and the Trustee reports the Trust's income, gains, losses and deductions to the Internal Revenue Service ("IRS")
on that basis.

 A
Shareholder that is not a US Shareholder as defined above (other than a partnership, or an entity treated as a partnership for
US federal tax purposes) generally is considered a "Non-US Shareholder" for purposes of this discussion. For US federal
income tax purposes, the treatment of any beneficial owner of an interest in a partnership, including any entity treated as a
partnership for US federal income tax purposes, generally depends upon the status of the partner and upon the activities of the
partnership. Partnerships and partners in partnerships should consult their tax advisors about the US federal income tax consequences
of purchasing, owning and disposing of Shares.

 Taxation
of US Shareholders

 Shareholders
generally are treated, for US federal income tax purposes, as if they directly owned a pro rata share of the underlying assets
held by the Trust. Shareholders are also treated as if they directly received their respective pro rata share of the Trust's
income, if any, and as if they directly incurred their respective pro rata share of the Trust's expenses. In the case of
a Shareholder that purchases Shares for cash, its initial tax basis in its pro rata share of the assets held in the Trust at the
time it acquires its Shares is equal to its cost of acquiring the Shares. In the case of a Shareholder that acquires its Shares
as part of a creation of a Basket, the delivery of palladium to the Trust in exchange for the Shares is not a taxable event
to the Shareholder, and the Shareholder's tax basis and holding period for the Shares are the same as its tax basis and
holding period for the palladium delivered in exchange therefore (except to the extent of any cash contributed for such Shares).
For purposes of this discussion, it is assumed that all of a Shareholder's Shares are acquired on the same date and at the
same price per Share. Shareholders that hold multiple lots of Shares, or that are contemplating acquiring multiple lots of Shares,
should consult their tax advisors.

 When
the Trust sells or transfers palladium, for example to pay expenses, a Shareholder generally will recognize a gain or loss in
an amount equal to the difference between (1) the Shareholder's pro rata share of the amount realized by the Trust upon
the sale or transfer and (2) the Shareholder's tax basis for its pro rata share of the palladium that was sold or transferred.
Such gain or loss will generally be long-term or short-term capital gain or loss, depending upon whether the Shareholder has a
holding period in its Shares of longer than one year. A Shareholder's tax basis for its share of any palladium sold by the
Trust generally will be determined by multiplying the Shareholder's total basis for its Shares immediately prior to the
sale, by a fraction the numerator of which is the amount of palladium sold, and the denominator of which is the total amount of
the palladium held by the Trust immediately prior to the sale. After any such sale, a Shareholder's tax basis for its pro
rata share of the palladium remaining in the Trust will be equal to its tax basis for its Shares immediately prior to the sale,
less the portion of such basis allocable to its share of the palladium that was sold.

 Upon
a Shareholder's sale of some or all of its Shares, the Shareholder will be treated as having sold a pro rata share of the palladium
held in the Trust at the time of the sale. Accordingly, the Shareholder generally will recognize a gain or loss on the sale
in an amount equal to the difference between (1) the amount realized pursuant to the sale of the Shares, and (2) the Shareholder's
tax basis for the Shares sold, as determined in the manner described in the preceding paragraph.

 A
redemption of some or all of a Shareholder's Shares in exchange for the underlying palladium represented by the Shares
redeemed generally will not be a taxable event to the Shareholder. The Shareholder's tax basis for the palladium received
in the redemption generally will be the same as the Shareholder's tax basis for the Shares redeemed. The Shareholder's
holding period with respect to the palladium received should include the period during which the Shareholder held the Shares
redeemed. A subsequent sale of the palladium received by the Shareholder will be a taxable event.

 An
Authorized Participant and other investors may be able to re-invest, on a tax-deferred basis, in-kind redemption proceeds received
from exchange-traded products that are substantially similar to the Trust in the Trust's Shares. Authorized Participants
and other investors should consult their tax advisors as to whether and under what circumstances the reinvestment in the Shares
of proceeds from substantially similar exchange-traded products can be accomplished on a tax-deferred basis.

 Under
current law, gains recognized by individuals, estates or trusts from the sale of "collectibles," including physical
palladium, held for more than one year are taxed at a maximum federal income tax rate of 28%, rather than the 20% rate applicable
to most other long-term capital gains. For these purposes, gains recognized by an individual upon the sale of Shares held for
more than one year, or attributable to the Trust's sale of any physical palladium which the Shareholder is treated
(through its ownership of Shares) as having held for more than one year, generally will be taxed at a maximum rate of 28%. The
tax rates for capital gains recognized upon the sale of assets held by an individual US Shareholder for one year or less or by
a corporate taxpayer are generally the same as those at which ordinary income is taxed.

 In
addition, high-income individuals and certain trusts and estates are subject to a 3.8% Medicare contribution tax that is imposed
on net investment income and gain. Shareholders should consult their tax advisor regarding this tax.

 Brokerage
Fees and Trust Expenses

 Any
brokerage or other transaction fees incurred by a Shareholder in purchasing Shares is treated as part of the Shareholder's
tax basis in the Shares. Similarly, any brokerage fee incurred by a Shareholder in selling Shares reduces the amount realized
by the Shareholder with respect to the sale.

 Shareholders
will be required to recognize gain or loss upon a sale of palladium by the Trust (as discussed above), even though some or
all of the proceeds of such sale are used by the Trustee to pay Trust expenses. Shareholders may deduct their respective pro rata
share of each expense incurred by the Trust to the same extent as if they directly incurred the expense. Shareholders who are
individuals, estates or trusts, however, may be required to treat some or all of the expenses of the Trust, to the extent that
such expenses may be deducted, as miscellaneous itemized deductions. Miscellaneous itemized deductions, including expenses for
the production of income, will not be deductible for either regular federal income tax or alternative minimum tax purposes for
taxable years beginning after December 31, 2017 and before January 1, 2026 and thereafter generally are (i) deductible only to
the extent that the aggregate of a Shareholder's miscellaneous itemized deductions exceeds 2% of such Shareholder's
adjusted gross income for federal income tax purposes, (ii) not deductible for the purposes of the alternative minimum tax and
(iii) are subject to the overall limitation on itemized deductions under the Code.

by Regulated Investment Companies

 Mutual
funds and other investment vehicles which are "regulated investment companies" within the meaning of Code section
851 should consult with their tax advisors concerning (1) the likelihood that an investment in Shares, although they are a "security"
within the meaning of the Investment Company Act of 1940, may be considered an investment in the underlying palladium for
purposes of Code section 851(b), and (2) the extent to which an investment in Shares might nevertheless be consistent with preservation
of their qualification under Code section 851. In administrative guidance, the IRS stated that it will no longer issue rulings
under Code section 851(b) relating to the determination of whether or not an instrument or position is a "security",
but, instead, intends to defer to guidance from the SEC for such determination.

 United
States Information Reporting and Backup Withholding Tax for US and Non-US Shareholders

 The
Trustee or the appropriate broker will file certain information returns with the IRS, and provides certain tax-related information
to Shareholders, in accordance with applicable Treasury Regulations. Each Shareholder will be provided with information regarding
its allocable portion of the Trust's annual income (if any) and expenses.

 A
US Shareholder may be subject to US backup withholding tax in certain circumstances unless it provides its taxpayer identification
number and complies with certain certification procedures. Non-US Shareholders may have to comply with certification procedures
to establish that they are not a US person in order to avoid the backup withholding tax.

 The
amount of any backup withholding tax will be allowed as a credit against a Shareholder's US federal income tax liability
and may entitle such a Shareholder to a refund, provided that the required information is furnished to the IRS.

 Income
Taxation of Non-US Shareholders

 The
Trust does not expect to generate taxable income except for gains (if any) upon the sale of palladium. A Non-US Shareholder generally
is not subject to US federal income tax with respect to gains recognized upon the sale or other disposition of Shares, or upon
the sale of palladium by the Trust, unless (1) the Non-US Shareholder is an individual and is present in the United States
for 183 days or more during the taxable year of the sale or other disposition, and the gain is treated as being from United States
sources; or (2) the gain is effectively connected with the conduct by the Non-US Shareholder of a trade or business in the United
States.

 Taxation
in Jurisdictions other than the United States

 Prospective
purchasers of Shares that are based in or acting out of a jurisdiction other than the United States are advised to consult their
own tax advisers as to the tax consequences, under the laws of such jurisdiction (or any other jurisdiction not being the United
States to which they are subject), of their purchase, holding, sale and redemption of or any other dealing in Shares and, in particular,
as to whether any value added tax, other consumption tax or transfer tax is payable in relation to such purchase, holding, sale,
redemption or other dealing.

 ERISA
and Related Considerations

 The
Employee Retirement Income Security Act of 1974, as amended ("ERISA"), and/or Code section 4975 impose certain requirements
on certain employee benefit plans and certain other plans and arrangements, including individual retirement accounts and annuities,
Keogh plans, and certain commingled investment vehicles or insurance company general or separate accounts in which such plans
or arrangements are invested (collectively, "Plans"), and on persons who are fiduciaries with respect to the investment
of "plan assets" of a Plan. Government plans and some church plans are not subject to the fiduciary responsibility
provisions of ERISA or the provisions of section 4975 of the Code, but may be subject to substantially similar rules under other
federal law, or under state or local law ("Other Law").

 In
contemplating an investment of a portion of Plan assets in Shares, the Plan fiduciary responsible for making such investment should
carefully consider, taking into account the facts and circumstances of the Plan and the "Risk Factors" discussed above
and whether such investment is consistent with its fiduciary responsibilities under ERISA or Other Law, including, but not limited
to: (1) whether the investment is permitted under the Plan's governing documents, (2) whether the fiduciary has the authority
to make the investment, (3) whether the investment is consistent with the Plan's funding objectives, (4) the tax effects
of the investment on the Plan, and (5) whether the investment is prudent considering the factors discussed in this report. In
addition, ERISA and Code section 4975 prohibit a broad range of transactions involving assets of a plan and persons who are "parties
in interest" under ERISA or "disqualified persons" under section 4975 of the Code. A violation of these rules
may result in the imposition of significant excise taxes and other liabilities. Plans subject to Other Law may be subject to similar
restrictions.

 It
is anticipated that the Shares will constitute "publicly offered securities" as defined in the Department of Labor
"Plan Asset Regulations," §2510.3-101 (b)(2) as modified by section 3(42) of ERISA. Accordingly, pursuant to
the Plan Asset Regulations, only Shares purchased by a Plan, and not an interest in the underlying assets held in the Trust, should
be treated as assets of the Plan, for purposes of applying the "fiduciary responsibility" rules of ERISA and the "prohibited
transaction" rules of ERISA and the Code. Fiduciaries of plans subject to Other Law should consult legal counsel to determine
whether there would be a similar result under the Other Law.

by Certain Retirement Plans

 Code
section 408(m) provides that the acquisition of a "collectible" by an individual retirement account ("IRA")
or a participant-directed account maintained under any plan that is tax-qualified under Code section 401(a) ("Tax Qualified
Account") is treated as a taxable distribution from the account to the owner of the IRA, or to the participant for whom
the Tax Qualified Account is maintained, of an amount equal to the cost to the account of acquiring the collectible. The term
"collectible" is defined to include, with certain exceptions, "any metal or gem". The IRS has issued several
private letter rulings to the effect that a purchase by an IRA, or by a participant-directed account under a Code section 401(a)
plan, of publicly-traded shares in a trust holding precious metals will not be treated as resulting in a taxable distribution
to the IRA owner or Tax Qualified Account participant under Code section 408(m). However the private letter rulings provide that,
if any of the Shares so purchased are distributed from the IRA or Tax Qualified Account to the IRA owner or Tax Qualified Account
participant, or if any precious metal is received by such IRA or Tax Qualified Account upon the redemption of any of the
Shares purchased by it, the Shares or precious metal so distributed will be subject to federal income tax in the year of
distribution, to the extent provided under the applicable provisions of Code sections 408(d), 408(m) or 402. Accordingly, potential
IRA or Tax Qualified Account investors are urged to consult with their own professional advisors concerning the treatment of an
investment in Shares under Code section 408(m).

 Item
1A. Risk Factors

 Shareholders
should consider carefully the risks described below before making an investment decision. Shareholders should also refer to the
other information included in this report, including the Trust's financial statements and the related notes.

 RISKS
RELATED TO PALLADIUM

 The
price of palladium may be affected by the sale of ETVs tracking the palladium markets.

 To
the extent existing exchange traded vehicles ("ETVs") tracking the palladium markets represent a significant proportion
of demand for physical palladium bullion, large redemptions of the securities of these ETVs could negatively affect physical palladium
bullion prices and the price and NAV of the Shares.

 Crises
may motivate large-scale sales of palladium which could decrease the price of palladium and adversely affect an investment in
the Shares.

 The
possibility of large-scale distress sales of palladium in times of crisis may have a short-term negative impact on the price of
palladium and adversely affect an investment in the Shares. For example, the 2008 financial credit crisis resulted in significantly
depressed prices of palladium largely due to forced sales and deleveraging from institutional investors such as hedge funds and
pension funds as expectations of economic growth slumped. Crises in the future may impair palladium's price performance
which would, in turn, adversely affect an investment in the Shares.

 Several
factors may have the effect of causing a decline in the prices of palladium and a corresponding decline in the price of Shares.
Among them:

 A
 significant increase in palladium hedging activity by palladium producers. Should there
 be an increase in the level of hedge activity of palladium producing companies, it could
 cause a decline in world palladium prices, adversely affecting the price of the Shares.

 A
 significant change in the attitude of speculators, investors and central banks towards
 palladium. Should the speculative community take a negative view towards palladium or
 central banking authorities determine to sell national palladium reserves, either event
 could cause a decline in world palladium prices, negatively impacting the price of the
 Shares.

 A
 widening of interest rate differentials between the cost of money and the cost of palladium
 could negatively affect the price of palladium which, in turn, could negatively affect
 the price of the Shares.

 A
 combination of rising money interest rates and a continuation of the current low cost
 of borrowing palladium could improve the economics of selling palladium forward. This
 could result in an increase in hedging by palladium mining companies and short selling
 by speculative interests, which would negatively affect the price of palladium. Under
 such circumstances, the price of the Shares would be similarly affected.

 Autocatalysts,
 automobile components that use palladium, accounted for approximately 85% of the net
 global demand in palladium in 2022. While the automotive sector in China and the US is
 showing signs of recovery, the European market is currently experiencing declining demand
 and, in certain cases, solvency concerns. Reduced automotive industry sales in Europe
 may result in a decline in autocatalyst demand.

 A
 decline in the global automotive industry may impact the price of palladium and affect
 the price of the Shares.

 Conversely,
several factors may trigger a temporary increase in the price of palladium prior to your investment in the Shares. For example,
sudden increased investor interest in palladium may cause an increase in world palladium prices, increasing the price of the Shares.
If that is the case, you will be buying Shares at prices affected by the temporarily high prices of palladium, and you may incur
losses when the causes for the temporary increase disappear.

 A
decline in the automobile industry or a shift from gasoline-powered to electric vehicles may have the effect of causing a decline
in the price of palladium and a corresponding decline in the price of Shares.

 Autocatalysts,
automobile components for emissions control that use palladium, accounted for approximately 85% of the global demand in palladium
in 2022. Increased automotive industry sales may result in an increase in autocatalyst demand. A contraction in the global automotive
industry or more widespread acceptance of electric vehicles may decrease demand, thus impacting the price of palladium and the
price of Shares.

 The
value of the Shares relates directly to the value of the palladium held by the Trust and fluctuations in the price of palladium
could materially adversely affect an investment in the Shares.

 The
Shares are designed to mirror as closely as possible the performance of the price of palladium bullion, and the value of the Shares
relates directly to the value of the palladium held by the Trust, less the Trust's liabilities (including estimated accrued
but unpaid expenses). The price of palladium has fluctuated widely over the past several years. Several factors may affect the
price of palladium, including:

 Global
palladium supply, which is influenced by such factors as production and cost levels in major palladium-producing countries such
as Russia and South Africa. Recycling, autocatalyst demand, industrial demand, jewelry demand and investment demand
are also important drivers of palladium supply and demand. Sales of existing stockpiles of palladium have been a key source of
supply in the past decade and could potentially soon be exhausted, placing a higher burden on new mine supply;

 Currency
exchange rates;

 Interest
rates;

and trading activities of hedge funds and commodity funds;

 Global
or regional political, economic or financial events and situations; and

 A
significant change in investor interest, including in response to online campaigns or other activities specifically targeting
investments in palladium.

 In
addition, investors should be aware that there is no assurance that palladium will maintain its long-term value in terms of purchasing
power in the future. In the event that the price of palladium declines, the Sponsor expects the value of an investment in the
Shares to decline proportionately.

 RISKS RELATED TO PALLADIUM

 The value of the Shares relates directly
to the value of the palladium held by the Trust and fluctuations in the price of palladium could materially adversely affect an investment
in the Shares.

 The Shares are designed to mirror as closely
as possible the performance of the price of physical palladium, and the value of the Shares relates directly to the value of the palladium
held by the Trust, less the Trust's liabilities (including estimated accrued but unpaid expenses). The price of physical palladium
has fluctuated widely over the past several years, as discussed below. Several factors may affect the price of palladium, including:

 •
 Global palladium supply, which is influenced by such factors as production
and cost levels in major palladium-producing countries such as Russia and South Africa. Recycling, autocatalyst demand, industrial
demand, jewelry demand and investment demand are also important drivers of palladium supply and demand. Sales of existing stockpiles of
palladium have been a key source of supply in the past decade and could potentially soon be exhausted, placing a higher burden on new
mine supply;

 •
 Investors' expectations with respect to the rate of inflation;

 •
 Currency exchange rates;

 •
 Interest rates;

 •
 Investment and trading activities of hedge funds and commodity funds;

 •
 Global or regional political, economic or financial events and situations;
and

 •
 A significant change in investor interest, including in response to online
campaigns or other activities specifically targeting investments in palladium.

 In addition, investors should be aware that
there is no assurance that palladium will maintain its long-term value in terms of purchasing power in the future. In the event that the
price of palladium declines, the Sponsor expects the value of an investment in the Shares to decline proportionately.

 The price of
physical palladium has fluctuated widely over the past several years.

 The
price of physical palladium, and the value of the Shares, has been highly volatile and could continue to be subject to wide fluctuations
in response to various factors. See "Overview of the Palladium
Industry – Historical Chart of the Price of Palladium" for discussion of the fluctuation of palladium
prices.

 Several factors may have the effect of causing
a decline in the prices of palladium and a corresponding decline in the price of Shares. Among them:

 •
 A significant increase in palladium hedging activity by palladium producers.
Should there be an increase in the level of hedge activity of palladium producing companies, it could cause a decline in world palladium
prices, adversely affecting the price of the Shares.

 •
 A significant change in the attitude of speculators and investors towards
palladium. Should the speculative community take a negative view towards palladium, it could cause a decline in world palladium prices,
negatively impacting the price of the Shares.

 •
 A widening of interest rate differentials between the cost of money and
the cost of palladium could negatively affect the price of palladium which, in turn, could negatively affect the price of the Shares.

 •
 A combination of rising money interest rates and a continuation of the current
low cost of borrowing palladium could improve the economics of selling palladium forward. This could result in an increase in hedging
by palladium mining companies and short selling by speculative interests, which would negatively affect the price of palladium. Under
such circumstances, the price of the Shares would be similarly affected.

 Conversely, several factors may trigger a temporary
increase in the price of palladium prior to your investment in the Shares. For example, sudden increased investor interest in palladium
may cause an increase in world palladium prices, increasing the price of the Shares. If that is the case, you will be buying Shares at
prices affected by the temporarily high prices of palladium, and you may incur losses when the causes for the temporary increase disappear.

 A decline in the automobile industry may
have the effect of causing a decline in the price of palladium and a corresponding decline in the price of Shares.

 Autocatalysts, automobile components for emissions
control that use palladium, accounted for approximately 84% of the net global demand in palladium in 2023. Reduced automotive
industry sales may result in a decline in autocatalyst demand which may impact the price of palladium and the price of Shares.

 Crises may motivate large-scale sales of
palladium which could decrease the price of palladium and adversely affect an investment in the Shares.

 The possibility of large-scale distress sales
of palladium in times of crisis may have a short-term negative impact on the price of palladium and adversely affect an investment in
the Shares. For example, the 2008 financial credit crisis resulted in significantly depressed prices of palladium largely due to forced
sales and deleveraging from institutional investors such as hedge funds and pension funds as expectations of economic growth slumped.
Crises in the future may impair palladium's price performance which would, in turn, adversely affect an investment in the Shares.

 The price of palladium may be affected by
the sale of ETVs tracking the palladium markets.

 To the extent existing exchange traded vehicles
("ETVs") tracking palladium markets represent a significant proportion of demand for physical palladium bullion, large redemptions
of the securities of these ETVs could negatively affect physical palladium bullion prices and the price and NAV of the Shares.

 RISKS RELATED TO THE SHARES

 Since there is no limit on the amount of
palladium that the Trust may acquire, the Trust, as it grows, may have an impact on the supply and demand of palladium that ultimately
may affect the price of the Shares in a manner unrelated to other factors affecting the global market for palladium.

 The Trust Agreement places no limit on the amount
of palladium the Trust may hold. Moreover, the Trust may issue an unlimited number of Shares, subject to registration requirements, and
thereby acquire an unlimited amount of palladium. The global market for palladium is characterized by supply and demand constraints that
are generally not present in the markets for other precious metals such as gold and silver. From 2019 to 2023, world palladium mine supply
averaged 6.5 million ounces, while world net demand averaged 10.4 million ounces. If the amount of palladium acquired by the Trust is
large enough in relation to global palladium supply and demand, further in-kind creations and redemptions of Shares could have an impact
on the supply and demand of palladium unrelated to other factors affecting the global market for palladium. Such an impact could affect
the price for palladium that would directly affect the price at which Shares are traded on the Exchange or the price of future Baskets
created or redeemed by the Trust. The Trust and the Sponsor cannot provide Shareholders any assurance that increased metal holdings by
the Trust in the future will have no such long-term metal price impact thereby affecting Share trading prices.

 The Shares and their value could decrease
if unanticipated operational or trading problems arise.

 There may be unanticipated problems or issues
with respect to the mechanics of the Trust's operations and the trading of the Shares that could have a material adverse effect
on an investment in the Shares. In addition, although the Trust is not actively "managed" by traditional methods, to the extent
that unanticipated operational or trading problems or issues arise, the Sponsor's past experience and qualifications may not be
suitable for solving these problems or issues.

 Discrepancies, disruptions or unreliability
of the LBMA Price PM could impact the value of the Trust's palladium and the market price of the Shares.

 The Trustee values the Trust's palladium
pursuant to the LBMA Price PM. In the event that the LBMA Price PM proves to be an inaccurate benchmark, or the LBMA Price PM varies materially
from the prices determined by other mechanisms for valuing palladium, the value of the Trust's palladium and the market price of
the Shares could be adversely impacted. Any future developments in the LBMA Price PM, to the extent it has a material impact on the LBMA
Price PM, could adversely impact the value of the Trust's palladium and the market price of the Shares. It is possible that electronic
failures or other unanticipated events may occur that could result in delays in the announcement of, or the inability of the benchmark
to produce, the LBMA Price PM on any given date. Furthermore, any actual or perceived disruptions that result in the perception that the
LBMA Price PM is vulnerable to actual or attempted manipulation could adversely affect the behavior of market participants, which may
have an effect on the price of palladium. If the LBMA Price PM is unreliable for any reason, the price of palladium and the market price
for the Shares may decline or be subject to greater volatility.

 If the process of creation and redemption
of Baskets encounters any unanticipated difficulties, the possibility for arbitrage transactions intended to keep the price of the Shares
closely linked to the price of palladium may not exist and, as a result, the price of the Shares may fall.

 If the processes of creation and redemption
of Shares (which depend on timely transfers of palladium to and by the Custodian) encounter any unanticipated difficulties, potential
market participants who would otherwise be willing to purchase or redeem Baskets to take advantage of any arbitrage opportunity arising
from discrepancies between the price of the Shares and the price of the underlying palladium may not take the risk that, as a result of
those difficulties, they may not be able to realize the profit they expect. If this is the case, the liquidity of Shares may decline and
the price of the Shares may fluctuate independently of the price of palladium and may fall. Additionally, redemptions could be suspended
in any period during which (1) the NYSE Arca is closed (other than customary weekend or holiday closings) or trading on the NYSE Arca
is suspended or restricted, or (2) an emergency exists as a result of which delivery, disposal or evaluation of the palladium is not reasonably
practicable.

 A possible "short squeeze" due
to a sudden increase in demand of Shares that largely exceeds supply may lead to price volatility in the Shares.

 Investors may purchase Shares to hedge existing
palladium exposure or to speculate on the price of palladium. Speculation on the price of palladium may involve long and short exposures.
To the extent aggregate short exposure exceeds the number of Shares available for purchase (for example, in the event that large redemption
requests by Authorized Participants dramatically affect Share liquidity), investors with short exposure may have to pay a premium to repurchase
Shares for delivery to Share lenders. Those repurchases may in turn, dramatically increase the price of the Shares until additional Shares
are created through the creation process. This is often referred to as a "short squeeze." A short squeeze could lead to volatile
price movements in Shares that are not directly correlated to the price of palladium.

 The liquidity of the Shares may be affected
by the withdrawal from participation of one or more Authorized Participants.

 In the event that one or more Authorized Participants
having substantial interests in Shares or otherwise responsible for a significant portion of the Shares' daily trading volume on
the Exchange withdraw from participation, the liquidity of the Shares will likely decrease which could adversely affect the market price
of the Shares and result in Shareholders incurring a loss on their investment.

 Shareholders do not have the protections
associated with ownership of shares in an investment company registered under the Investment Company Act of 1940 or the protections afforded
by the CEA.

 The Trust is not registered as an investment
company under the Investment Company Act of 1940 and is not required to register under such act. Consequently, Shareholders do not have
the regulatory protections provided to investors in investment companies. The Trust does not and will not hold or trade in commodity futures
contracts, "commodity interests" or any other instruments regulated by the CEA, as administered by the CFTC and the NFA. Furthermore,
the Trust is not a commodity pool for purposes of the CEA, and neither the Sponsor nor the Trustee is subject to regulation by the CFTC
as a commodity pool operator or a commodity trading advisor in connection with the Trust or the Shares. Consequently, Shareholders do
not have the regulatory protections provided to investors in CEA-regulated instruments or commodity pools operated by registered commodity
pool operators or advised by registered commodity trading advisors.

 The Trust may be required to terminate and
liquidate at a time that is disadvantageous to Shareholders.

 If the Trust is required to terminate and liquidate,
such termination and liquidation could occur at a time which is disadvantageous to Shareholders, such as when palladium prices are lower
than the palladium prices at the time when Shareholders purchased their Shares. In such a case, when the Trust's palladium is sold
as part of the Trust's liquidation, the resulting proceeds distributed to Shareholders will be less than if palladium prices were
higher at the time of sale.

 The lack of an active trading market for
the Shares may result in losses on investment at the time of disposition of the Shares.

 Although Shares are listed for trading on the
NYSE Arca, it cannot be assumed that an active trading market for the Shares will be maintained. If an investor needs to sell Shares at
a time when no active market for Shares exists, such lack of an active market will most likely adversely affect the price the investor
receives for the Shares (assuming the investor is able to sell them).

 Shareholders do not have the rights enjoyed
by investors in certain other vehicles.

 As interests in an investment trust, the Shares
have none of the statutory rights normally associated with the ownership of shares of a corporation (including, for example, the right
to bring "oppression" or "derivative" actions). In addition, the Shares have limited voting and distribution rights
(for example, Shareholders do not have the right to elect directors or approve amendments to the Trust Agreement and do not receive dividends).

 An investment in the Shares may be adversely
affected by competition from other methods of investing in palladium.

 The Trust competes with other financial vehicles,
including traditional debt and equity securities issued by companies in the palladium industry and other securities backed by or linked
to palladium, direct investments in palladium and investment vehicles similar to the Trust. Market and financial conditions, and other
conditions beyond the Sponsor's control, may make it more attractive to invest in other financial vehicles or to invest in palladium
directly, which could limit the market for the Shares and reduce the liquidity of the Shares.

 The amount of palladium represented by each
Share will decrease over the life of the Trust due to the recurring deliveries of palladium necessary to pay the Sponsor's Fee in-kind
and potential sales of palladium to pay in cash the Trust expenses not assumed by the Sponsor. Without increases in the price of palladium
sufficient to compensate for that decrease, the price of the Shares will also decline proportionately over the life of the Trust.

 The amount of palladium represented by each
Share decreases each day by the Sponsor's Fee. In addition, although the Sponsor has agreed to assume all organizational and certain
administrative and marketing expenses incurred by the Trust (the Trustee's monthly fee and out-of-pocket expenses, the Custodian's
fee and reimbursement of the Custodian's expenses under the Custody Agreements, exchange listing fees, SEC registration fees, printing
and mailing costs, audit fees and up to $100,000 per annum in legal expenses), in exceptional cases certain Trust expenses may need to
be paid by the Trust. Because the Trust does not have any income, it must either make payments in-kind by deliveries of palladium (as
is the case with the Sponsor's Fee) or it must sell palladium to obtain cash (as in the case of any exceptional expenses). The result
of these sales of palladium and recurring deliveries of palladium to pay the Sponsor's Fee in-kind is a decrease in the amount of
palladium represented by each Share. New deposits of palladium, received in exchange for new Shares issued by the Trust, will not reverse
this trend.

 A decrease in the amount of palladium represented
by each Share results in a decrease in each Share's price even if the price of palladium does not change. To retain the Share's
original price, the price of palladium must increase. Without that increase, the lesser amount of palladium represented by the Share will
have a correspondingly lower price. If this increase does not occur, or is not sufficient to counter the lesser amount of palladium represented
by each Share, Shareholders will sustain losses on their investment in Shares.

 An increase in Trust expenses not assumed by
the Sponsor, or the existence of unexpected liabilities affecting the Trust, will require the Trustee to sell larger amounts of palladium,
and will result in a more rapid decrease of the amount of palladium represented by each Share and a corresponding decrease in its value.

 The sale of the Trust's palladium to
pay expenses not assumed by the Sponsor, or unexpected liabilities affecting the Trust, at a time of low palladium prices could adversely
affect the value of the Shares.

 The Trustee sells palladium held by the Trust
to pay Trust expenses not assumed by the Sponsor on an as-needed basis irrespective of then-current palladium prices. The Trust is not
actively managed and no attempt will be made to buy or sell palladium to protect against or to take advantage of fluctuations in the price
of palladium. Consequently, the Trust's palladium may be sold at a time when the palladium price is low, resulting in the sale of
more palladium than would be required if the Trust sold when prices were higher. The sale of the Trust's palladium to pay expenses
not assumed by the Sponsor, or unexpected liabilities affecting the Trust, at a time of low Palladium prices could adversely affect the
value of the Shares.

 The value of the Shares will be adversely
affected if the Trust is required to indemnify the Sponsor or the Trustee under the Trust Agreement.

 Under the Trust Agreement, each of the Sponsor
and the Trustee has a right to be indemnified from the Trust for any liability or expense it incurs without gross negligence, bad faith,
willful misconduct, willful malfeasance or reckless disregard on its part. That means the Sponsor or the Trustee may require the assets
of the Trust to be sold in order to cover losses or liability suffered by it. Any sale of that kind would reduce the NAV of the Trust
and the value of the Shares.

 The Shares may trade at
a price which is at, above or below the NAV per Share and any discount or premium in the trading price relative to the NAV per Share may
widen as a result of non-concurrent trading hours between the NYSE Arca and London, Zurich and COMEX.

 The Shares may trade at,
above or below the NAV per Share. The NAV per Share fluctuates with changes in the market value of the Trust's assets. The trading
price of the Shares fluctuates in accordance with changes in the NAV per Share as well as market supply and demand. The amount of the
discount or premium in the trading price relative to the NAV per Share may be influenced by non-concurrent trading hours between the NYSE
Arca and the major palladium markets. While the Shares trade on the NYSE Arca until 4:00 p.m. New York time, liquidity in the market for
palladium will be reduced after the close of the major world palladium markets, including London, Zurich and the COMEX. As a result, during
these periods, trading spreads, and the resulting premium or discount on the Shares, may widen.

 Purchasing activity in
the palladium market associated with Basket creations or selling activity following Basket redemptions may affect the price of palladium
and Share trading prices. These price changes may adversely affect an investment in the Shares.

 Purchasing activity associated
with acquiring the palladium required for deposit into the Trust in connection with the creation of Baskets may temporarily increase the
market price of palladium, which will result in higher prices for the Shares. Temporary increases in the market price of palladium may
also occur as a result of the purchasing activity of other market participants. Other market participants may attempt to benefit from
an increase in the market price of palladium that may result from increased purchasing activity of palladium connected with the issuance
of Baskets. Consequently, the market price of palladium may decline immediately after Baskets are created. If the price of palladium declines,
the trading price of the Shares may also decline.

 Selling activity associated
with sales of palladium withdrawn from the Trust in connection with the redemption of Baskets may temporarily decrease the market price
of palladium, which will result in lower prices for the Shares. Temporary decreases in the market price of palladium may also occur as
a result of the selling activity of other market participants. If the price of palladium declines, the trading price of the Shares may
also decline.

 The Sponsor is unable to
ascertain whether the palladium price movements since the commencement of the Trust's initial public offering on January 8, 2010
were attributable to the Trust's Basket creation and redemption process or independent metal market forces or both. Nevertheless,
the Trust and the Sponsor cannot assure Shareholders that future Basket creations or redemptions will have no effect on the palladium
metal prices and, consequently, Share trading prices.

 RISKS RELATED TO THE CUSTODY OF PALLADIUM

 The Trust's palladium may be subject
to loss, damage, theft or restriction on access.

 There is a risk that part or all of the Trust's palladium
could be lost, damaged or stolen. Access to the Trust's palladium could also be restricted by natural events (such as an earthquake)
or human actions (such as a terrorist attack). Any of these events may adversely affect the operations of the Trust and, consequently,
an investment in the Shares.

 The Trust's lack of insurance protection
and the Shareholders' limited rights of legal recourse against the Trust, the Trustee, the Sponsor, the Custodian and any sub-custodian
exposes the Trust and its Shareholders to the risk of loss of the Trust's palladium for which no person is liable.

 The Trust does not insure its palladium. The
Custodian maintains insurance with regard to its business on such terms and conditions as it considers appropriate in connection with
its custodial obligations and is responsible for all costs, fees and expenses arising from the insurance policy or policies. The Trust
is not a beneficiary of any such insurance and does not have the ability to dictate the existence, nature or amount of coverage. Therefore,
Shareholders cannot be assured that the Custodian maintains adequate insurance or any insurance with respect to the palladium held by
the Custodian on behalf of the Trust. In addition, the Custodian and the Trustee do not require any direct or indirect sub-custodians
to be insured or bonded with respect to their custodial activities or in respect of the palladium held by them on behalf of the Trust.
Further, Shareholders' recourse against the Trust, the Trustee and the Sponsor under New York law, the Custodian, under English
law, and any other sub-custodians under the law governing their custody operations is limited. Consequently, a loss may be suffered with
respect to the Trust's palladium which is not covered by insurance and for which no person is liable in damages.

 The Custodian's limited liability under
the Custody Agreements and English law may impair the ability of the Trust to recover losses concerning its palladium and any recovery
may be limited, even in the event of fraud, to the market value of the palladium at the time the fraud is discovered.

 The liability of the Custodian is limited under
the Custody Agreements. Under the Custody Agreements between the Trustee and the Custodian which establish the Trust Unallocated Account
and the Trust Allocated Account, the Custodian is only liable for losses that are the direct result of its own negligence, fraud or willful
default in the performance of its duties. Any such liability is further limited to the market value of the palladium lost or damaged at
the time such negligence, fraud or willful default is discovered by the Custodian provided the Custodian notifies the Trust and the Trustee
promptly after the discovery of the loss or damage. Under each Authorized Participant Unallocated Bullion Account Agreement (between the
Custodian and an Authorized Participant establishing an Authorized Participant Unallocated Account), the Custodian is not contractually
or otherwise liable for any losses suffered by any Authorized Participant or Shareholder that are not the direct result of its own gross
negligence, fraud or willful default in the performance of its duties under such agreement, and in no event will its liability exceed
the market value of the balance in the Authorized Participant Unallocated Account at the time such gross negligence, fraud or willful
default is discovered by the Custodian. For any Authorized Participant Unallocated Bullion Account Agreement between an Authorized Participant
and another palladium clearing bank, the liability of the palladium clearing bank to the Authorized Participant may be greater or lesser
than the Custodian's liability to the Authorized Participant described in the preceding sentence, depending on the terms of the
agreement. In addition, the Custodian will not be liable for any delay in performance or any non-performance of any of its obligations
under the Allocated Account Agreement, the Unallocated Account Agreement or the Authorized Participant Unallocated Bullion Account Agreement
by reason of any cause beyond its reasonable control, including acts of God, war or terrorism. As a result, the recourse of the Trustee
or a Shareholder, under English law, is limited. Furthermore, under English common law, the Custodian or any sub-custodian will not be
liable for any delay in the performance or any non-performance of its custodial obligations by reason of any cause beyond its reasonable
control.

 The obligations of the Custodian are governed
by English law, which may frustrate the Trust in attempting to seek legal redress against the Custodian or any other sub-custodian concerning
its palladium.

 The obligations
of the Custodian under the Custody Agreements are, and the Authorized Participant Unallocated Bullion Account Agreements may be, governed
by English law. The Custodian may enter into arrangements with other sub-custodians for the temporary custody of the Trust's palladium,
which arrangements may also be governed by English law. The Trust is a New York common law trust. Any United States, New York or other
court situated in the United States may have difficulty interpreting English law (which, insofar as it relates to custody arrangements,
is largely derived from court rulings rather than statute), LPPM rules or the customs and practices in the London custody market. It may
be difficult or impossible for the Trust to sue any sub-custodian in a United States, New York or other court situated in the United States.
In addition, it may be difficult, time consuming and/or expensive for the Trust to enforce in a foreign court a judgment rendered by a
United States, New York or other court situated in the United States.

 The Trust may not have adequate sources of
recovery if its palladium is lost, damaged, stolen or destroyed.

 If the Trust's palladium is lost, damaged,
stolen or destroyed under circumstances rendering a party liable to the Trust, the responsible party may not have the financial resources
sufficient to satisfy the Trust's claim. For example, as to a particular event of loss, the only source of recovery for the Trust
might be limited to the Custodian or any sub-custodian or, to the extent identifiable, other responsible third parties (e.g., a thief
or terrorist), any of which may not have the financial resources (including liability insurance coverage) to satisfy a valid claim of
the Trust.

 Shareholders and Authorized Participants
lack the right under the Custody Agreements to assert claims directly against the Custodian and any sub-custodian.

 Neither the Shareholders nor any Authorized
Participant have a right under the Custody Agreements to assert a claim of the Trust against the Custodian or any sub-custodian. Claims
under the Custody Agreements may only be asserted by the Trustee on behalf of the Trust.

 Because the Trustee does not, and the Custodian
has limited obligations to, oversee or monitor the activities of sub-custodians who may hold the Trust's palladium, failure by the
sub-custodians to exercise due care in the safekeeping of the Trust's palladium could result in a loss to the Trust.

 Under the Allocated Account Agreement, the Custodian
may appoint from time to time one or more sub-custodians to hold the Trust's palladium on a temporary basis pending delivery to
the Custodian. Any sub-custodian selected by the Custodian shall be a member of the LBMA or any equity member of the London Precious Metals
Clearing Limited, except for the Governor and Company of the Bank of England. The Custodian is not currently using a sub-custodian as
of the date of this report. The Custodian is required under the Allocated Account Agreement to use reasonable care in appointing any sub-custodians,
making the Custodian liable only for negligence or bad faith in the selection of such sub-custodians, and has an obligation to use commercially
reasonable efforts to obtain delivery of the Trust's palladium from any sub-custodians appointed by the Custodian. Otherwise, the
Custodian is not liable for the acts or omissions of its sub-custodians. These sub-custodians may in turn appoint further sub-custodians,
but the Custodian is not responsible for the appointment of these further sub-custodians. The Custodian does not undertake to monitor
the performance by sub-custodians of their custody functions or their selection of further sub-custodians. The Trustee does not monitor
the performance of the Custodian other than to review the reports provided by the Custodian pursuant to the Custody Agreements and does
not undertake to monitor the performance of any sub-custodian. Furthermore, the Trustee may have no right to visit the premises of any
sub-custodian for the purposes of examining the Trust's palladium or any records maintained by the sub-custodian, and no sub-custodian
will be obligated to cooperate in any review the Trustee may wish to conduct of the facilities, procedures, records or creditworthiness
of such sub-custodian. In addition, the ability of the Trustee to monitor the performance of the Custodian may be limited because under
the Allocated Account Agreement and the Unallocated Account Agreement the Trustee has only limited rights to visit the premises of the
Custodian for the purpose of examining the Trust's palladium and certain related records maintained by the Custodian. See "Custody
of the Trust's Palladium" for more information about sub-custodians that may hold the Trust's palladium.

 The obligations of any sub-custodian of the
Trust's palladium are not determined by contractual arrangements but by LPPM rules and London palladium market customs and practices,
which may prevent the Trust's recovery of damages for losses on its palladium custodied with sub-custodians.

 There are expected to be no written contractual
arrangements between sub-custodians that hold the Trust's palladium and the Trustee or the Custodian because traditionally such
arrangements are based on the LPPM's rules and on the customs and practices of the London palladium markets. In the event of a legal
dispute with respect to or arising from such arrangements, it may be difficult to define such customs and practices. The LPPM's
rules may be subject to change outside the control of the Trust. Under English law, neither the Trustee nor the Custodian would have a
supportable breach of contract claim against a sub-custodian for losses relating to the safekeeping of palladium. If the Trust's
palladium is lost or damaged while in the custody of a sub-custodian, the Trust may not be able to recover damages from the Custodian
or the sub-custodian. Whether a sub-custodian will be liable for the failure of sub-custodians appointed by it to exercise due care in
the safekeeping of the Trust's palladium will depend on the facts and circumstances of the particular situation. Shareholders cannot
be assured that the Trustee will be able to recover damages from sub-custodians whether appointed by the Custodian or by another sub-custodian
for any losses relating to the safekeeping of palladium by such sub-custodians.

 Palladium bullion allocated to the Trust
in connection with the creation of a Basket may not meet the London Good Delivery Standards and, if a Basket is issued against such palladium,
the Trust may suffer a loss.

 Neither the Trustee nor the Custodian independently
confirms the fineness of the physical palladium allocated to the Trust in connection with the creation of a Basket. The palladium bullion
allocated to the Trust by the Custodian may be different from the reported fineness or weight required by the LPPM's standards for
palladium plates or ingots delivered in settlement of a palladium trade (London Good Delivery Standards), the standards required by the
Trust. If the Trustee nevertheless issues a Basket against such palladium, and if the Custodian fails to satisfy its obligation to credit
the Trust the amount of any deficiency, the Trust may suffer a loss.

 Palladium held in the Trust's unallocated
palladium account and any Authorized Participant's unallocated palladium account will not be segregated from the Custodian's
assets. If the Custodian becomes insolvent, its assets may not be adequate to satisfy a claim by the Trust or any Authorized Participant.
In addition, in the event of the Custodian's insolvency, there may be a delay and costs incurred in identifying the bullion held
in the Trust's allocated palladium account.

 Palladium which is part of a deposit for a purchase
order or part of a redemption distribution is held for a time in the Trust Unallocated Account and, previously or subsequently in, the
Authorized Participant Unallocated Account of the purchasing or redeeming Authorized Participant. During those times, the Trust and the
Authorized Participant, as the case may be, have no proprietary rights to any specific plates or ingots of palladium held by the Custodian
and are each an unsecured creditor of the Custodian with respect to the amount of palladium held in such unallocated accounts. In addition,
if the Custodian fails to allocate the Trust's palladium in a timely manner, in the proper amounts or otherwise in accordance with
the terms of the Unallocated Account Agreement, or if a sub-custodian fails to so segregate palladium held by it on behalf of the Trust,
unallocated palladium will not be segregated from the Custodian's assets, and the Trust will be an unsecured creditor of the Custodian
with respect to the amount so held in the event of the insolvency of the Custodian. In the event the Custodian becomes insolvent, the
Custodian's assets might not be adequate to satisfy a claim by the Trust or the Authorized Participant for the amount of palladium
held in their respective unallocated palladium accounts.

 In the case of the insolvency of the Custodian,
a liquidator may seek to freeze access to the palladium held in all of the accounts held by the Custodian, including the Trust Allocated
Account. Although the Trust would be able to claim ownership of properly allocated palladium, the Trust could incur expenses in connection
with asserting such claims, and the assertion of such a claim by the liquidator could delay creations and redemptions of Baskets.

 In issuing Baskets, the Trustee relies on
certain information received from the Custodian which is subject to confirmation after the Trustee has relied on the information. If such
information turns out to be incorrect, Baskets may be issued in exchange for an amount of palladium which is more or less than the amount
of palladium which is required to be deposited with the Trust.

 The Custodian's definitive records are
prepared after the close of its business day. However, when issuing Baskets, the Trustee relies on information reporting the amount of
palladium credited to the Trust's accounts which it receives from the Custodian during the business day and which is subject to
correction during the preparation of the Custodian's definitive records after the close of business. If the information relied upon
by the Trustee is incorrect, the amount of palladium actually received by the Trust may be more or less than the amount required to be
deposited for the issuance of Baskets.

 GENERAL
RISKS

 The Trust relies on the information and technology
systems of the Trustee, the Custodian, the Marketing Agent and the Sponsor, which could be adversely affected by information systems interruptions,
cybersecurity attacks or other disruptions which could have a material adverse effect on the Trust's record keeping and operations.

 The Custodian, the Trustee, the Marketing Agent
and the Sponsor depend upon information technology infrastructure, including network, hardware and software systems to conduct their business
as it relates to the Trust. A cybersecurity incident, or a failure to protect their computer systems, networks and information against
cybersecurity threats, could result in a loss of information and adversely impact their ability to conduct their business, including their
business on behalf of the Trust. Despite implementation of network and other cybersecurity measures, their security measures may not be
adequate to protect against all cybersecurity threats.

 War,
a major terrorist attack and other geopolitical events, including but not limited to the war between Russia and Ukraine, outbreaks or
public health emergencies (as declared by the World Health Organization), the continuation or expansion of war or other hostilities, or
a prolonged government shutdown may cause volatility in the price of Bullion due to the importance of a country or region to the Bullion
markets, market access restrictions imposed on some local Bullion producers and refiners, potential impacts to global transportation and
shipping and other supply chain disruptions. These events are unpredictable and may lead to extended periods of price volatility.

 The operations of the Trust,
the exchanges, brokers and counterparties with which the Trust does business, and the markets in which the Trust does business, could
be severely disrupted in the event of war, a major terrorist attack and other geopolitical events, including but not limited to, the war
between Russia and Ukraine, outbreaks or public health emergencies (as declared by the World Health Organization), the continuation or
expansion of war or other hostilities, or a prolonged government shutdown. Such events may cause volatility in the price of Bullion due
to the importance of a country or region to the Bullion markets, market access restrictions imposed on some local Bullion producers and
refiners, or potential impacts to global transportation, shipping, and other supply chain disruptions.

 In late February 2022, Russia
invaded Ukraine, significantly amplifying already existing geopolitical tensions among Russia and other countries in the region and in
the West. The responses of countries and political bodies to Russia's actions, the larger overarching tensions, and Ukraine's
military response and the potential for wider conflict may increase financial market volatility generally, have severe adverse effects
on regional and global economic markets, and cause volatility in the price of palladium and the share price of the Trust. The conflict
in Ukraine, along with global political fallout and implications including sanctions, shipping disruptions, collateral war damage, and
a potential expansion of the conflict beyond Ukraine's borders, could disturb the Bullion markets. Russia is one of the world's
largest producers of several precious metals, including palladium. On April 8, 2022, the LPPM suspended its accreditation of two Russian
refiners of platinum and palladium. The LPPM stated that existing bars produced by the refiners before their suspension will still be
accepted as good delivery. See "Overview of the Palladium Industry – Historical Chart of the
Price of Palladium" for a discussion of how the Russian palladium refiners' accreditation has impacted
the palladium market and how Russia's production levels have impacted palladium prices subsequent to the suspension.

 War and other geopolitical
events in eastern Europe, including but not limited to Russia and Ukraine, may cause volatility in commodity prices including precious
metals prices. These events are unpredictable and may lead to extended periods of price volatility.

 The
Trust may be negatively impacted by the effects of the spread of illnesses or other public health emergencies on the global economy and
the markets and service providers relevant to the performance of the Trust.

 The COVID-19 pandemic has adversely affected the economies
of many nations and the entire global economy as well as individual issuers, assets and capital markets and could continue to, and other
future public health emergencies could, have serious negative effects on social, economic and financial systems, including significant
uncertainty and volatility in the financial markets. For instance, the suspension of operations of mines, refineries and vaults that extract,
produce or store palladium, restrictions on travel that delay or prevent the transportation of palladium and an increase in demand for
palladium may disrupt supply chains for palladium, which could cause secondary market spreads to widen and compromise the Trust's
ability to settle transactions on time. Any inability of the Trust to issue or redeem Shares or the Custodian or any sub-custodian to
receive or deliver palladium as a result of an infectious disease outbreak or public health emergency will negatively affect the Trust's
operations. Future infectious illness outbreaks or other public health emergencies could have similar or other unforeseen impacts and
may exacerbate pre-existing political, social and economic risks in certain countries or globally, which could adversely affect the value
of the Shares.

 A significant resurgence of the COVID-19 pandemic
or other future public health emergencies could increase the Trust's costs and affect liquidity in the market for palladium, as
well as the correlation between the price of the Shares and the net asset value of the Trust, any of which could adversely affect the
value of your Shares. In addition, the COVID-19 pandemic or other future public health emergencies could impair the information technology
and other operational systems upon which the Trust's service providers, including the Sponsor, the Trustee and the Custodian, rely,
and could otherwise disrupt the ability of employees of the Trust's service providers to perform essential tasks on behalf of the
Trust. Governmental and quasi-governmental authorities and regulators throughout the world have at times responded to major economic disruptions
with a variety of fiscal and monetary policy changes, including, but not limited to, direct capital infusions into companies and other
issuers, new monetary tools and lower interest rates. An unexpected or sudden reversal of these policies, or the ineffectiveness of these
policies, is likely to increase volatility in the market for palladium, which could adversely affect the price of the Shares.

 Further, the COVID-19 pandemic or other future public
health emergencies could interfere with or prevent the operation of the electronic auction hosted by IBA to determine the LBMA Palladium
Price PM, which the Trustee uses to value the palladium held by the Trust and calculate the net asset value of the Trust. The COVID-19
pandemic or other future public health emergencies could also cause the closure of futures exchanges, which could eliminate the ability
of Authorized Participants to hedge purchases of Baskets, increasing trading costs of Shares and resulting in a sustained premium or discount
in the Shares. Each of these outcomes would negatively impact the Trust.

 Potential conflicts of
interest may arise among the Sponsor or its affiliates and the Trust.

 Conflicts of interest may
arise among the Sponsor and its affiliates, on the one hand, and the Trust and its Shareholders, on the other hand. As a result of these
conflicts, the Sponsor may favor its own interests and the interests of its affiliates over the Trust and its Shareholders. As an example,
the Sponsor, its affiliates and their officers and employees are not prohibited from engaging in other businesses or activities, including
those that might be in direct competition with the Trust.

 Item
1B. Unresolved Staff Comments

 None.

 Item
1C. Cybersecurity

 Cybersecurity

 The
Trust, through its service providers, has processes in place to assess, identify and manage material risks from cybersecurity
threats. The Trust's business is dependent on the communications and information systems of the Trustee, the Sponsor, the
Custodian and other third-party service providers. The Trustee is responsible for day-to-day administration of the Trust and has
implemented a cybersecurity program that applies to the Trustee and its business, including the administration of the Trust.

 Cybersecurity
Program Overview

 The
Trustee has instituted a cybersecurity program designed to identify, assess and mitigate cyber risks applicable to the administration
by the Trustee of the Trust. The cyber risk management program involves risk assessments, implementation of security measures
and ongoing monitoring of systems and networks, including networks on which the Trust relies. The Trustee actively monitors the
current threat landscape to seek to identify material risks arising from new and evolving cybersecurity threats, including material
risks faced by the Trust.

 The
Trust relies on the Trustee, the Sponsor and the Custodian to engage external experts, including cybersecurity assessors, risk
management and information technology professionals, attorneys, consultants and auditors to evaluate cybersecurity measures and
risk management processes, including those applicable to the Trust.

 Board
Oversight of Cybersecurity Risks

 The
Trust has no board of trustees and is administered by the Trustee pursuant to the Trust Agreement. Accordingly, the Trust relies
on the Trustee, the Sponsor and the Custodian for oversight of cybersecurity risks applicable to the Trust.

 Management's
Role in Cybersecurity Risk Management

 The
Trust has no officers or employees and is administered by the Trustee pursuant to the Trust Agreement. Accordingly, the Trust
relies on the Trustee, the Sponsor and the Custodian for management of cybersecurity risks applicable to the Trust.

 Assessment
of Cybersecurity Risk

 The
potential impact of risks from cybersecurity threats to the Trust are assessed by the Trustee, the Sponsor, the Custodian and
third-party service providers on an ongoing basis, and how such risks could materially affect the Trust's objective, operational
results and financial condition are regularly evaluated. During the reporting period, the Trustee has not identified any risks
from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Trustee believes have materially
affected, or are reasonably likely to materially affect, the Trust, including its objective, operational results and financial
condition.

 Item
2. Properties

 Not
applicable.

 Item
3. Legal Proceedings

 None.

 Item
4. Mine Safety Disclosure

 Not
applicable.

 PART
II

 Item
5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities

 The
Trust's Shares have been listed on the NYSE Arca under the symbol PALL since its initial public offering on January 8, 2010.

 The
following tables set out the range of high and low closing prices for the Shares as reported for NYSE Arca transactions for each
of the quarters during the years ended December 31, 2024 and 2023:

 Fiscal Year Ended December 31, 2024: Quarter Ended

 High

 Low

 March 31, 2024

 $
 101.12

 $
 78.77

 June 30, 2024

 $
 100.29

 $
 80.25

 September 30, 2024

 $
 102.56

 $
 77.61

 $
 113.89

 $
 82.51

 Fiscal
 Year Ended December 31, 2023: Quarter Ended

 High

 Low

 March 31,
 2023

 $
 166.83

 $
 127.51

 June 30, 2023

 $
 150.26

 $
 113.53

 September 30, 2023

 $
 121.72

 $
 110.14

 $
 113.27

 $
 86.43

 The
number of outstanding Shares of the Trust as of February 26, 2025 was 3,887,500.

 Holders

 Monthly
Share Price

 The
following table sets forth, for each of the most recent six months, the high and low closing prices of the Shares, as reported
for NYSE Arca transactions.

 Month

 High

 Low

 August
 2024

 $
 90.08

 $
 77.61

 September 2024

 $
 102.56

 $
 83.41

 October 2024

 $
 113.89

 $
 90.42

 November 2024

 $
 104.51

 $
 85.05

 December 2024

 $
 91.25

 $
 82.51

 January 2025

 $
 93.44

 $
 83.39

 Issuer
Purchase of Equity Securities

 The
Trust issues and redeems Shares only with Authorized Participants in exchange for palladium, only in aggregations of 12,500 Shares (Effective June 18, 2024, the number of shares in a block that was reduced from 25,000 Shares to 12,500 Shares),
referred to as a Basket. A list of current Authorized Participants is available from the Sponsor or the Trustee and is included in
Item 7 of this report. Although the Trust does not purchase Shares directly from its Shareholders, in connection with the redemption
of Baskets, the Trust redeemed as follows during the years ended December 31, 2024 and 2023:

 Month

 Total
 number of
 Shares redeemed

 Average
 ounces of
 palladium per Share

 January 2024

 —

 —

 February
 2024

 75,000

 0.092

 March 2024

 100,000

 0.092

 April 2024

 —

 —

 May 2024

 —

 —

 June 2024

 262,500

 0.092

 July 2024

 87,500

 0.092

 August 2024

 87,500

 0.092

 September 2024

 262,500

 0.092

 October 2024

 —

 —

 November 2024

 650,000

 0.091

 2024

 350,000

 0.091

 Total

 1,875,000

 0.092

 Month

 Total
 number of
 Shares redeemed

 Average
 ounces of
 palladium per Share

 January 2023

 —

 —

 February
 2023

 100,000

 0.092

 March 2023

 75,000

 0.092

 April 2023

 50,000

 0.092

 May 2023

 —

 —

 June 2023

 —

 —

 July 2023

 50,000

 0.092

 August 2023

 —

 —

 September 2023

 —

 —

 October 2023

 —

 —

 November 2023

 —

 —

 December 2023

 —

 —

 Total

 275,000

 0.092

 Item
6. [Reserved]

 Item
7. Management's Discussion and Analysis of Financial Condition and Results of Operations

 This
information should be read in conjunction with the financial statements and notes to the financial statements included with this
report. The discussion and analysis that follows may contain statements that relate to future events or future performance. In
some cases, such forward-looking statements can be identified by terminology such as "may," "should,"
"expect," "plan," "anticipate," "believe," "estimate," "predict,"
"potential" or the negative of these terms or other comparable terminology. We remind readers that forward-looking
statements are merely predictions and therefore inherently subject to uncertainties and other factors and involve known and unknown
risks that could cause the actual results, performance, levels of activity, or our achievements, or industry results, to be materially
different from any future results, performance, levels of activity, or our achievements expressed or implied by such forward-looking
statements. Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the
date hereof. The Trust undertakes no obligation to publicly release any revisions to these forward-looking statements to reflect
events or circumstances after the date hereof or to reflect the occurrence of unanticipated events.

 Introduction

 The
abrdn Standard Palladium ETF Trust (the "Trust") is a trust formed under the laws of the State of New York. The Trust
does not have any officers, directors, or employees, and is administered by The Bank of New York Mellon (the "Trustee")
acting as trustee pursuant to the Depositary Trust Agreement (the "Trust Agreement") between the Trustee and abrdn
ETFs Sponsor LLC, the sponsor of the Trust (the "Sponsor"). The Trust issues shares ("Shares") representing
fractional undivided beneficial interests in its net assets. The assets of the Trust consist of palladium bullion held by a custodian
as an agent of the Trust and responsible only to the Trustee.

 The
Trust is a passive investment vehicle and the objective of the Trust is for the value of each Share to approximately reflect,
at any given time, the price of the palladium bullion owned by the Trust, less the Trust's liabilities (anticipated to be
principally for accrued operating expenses), divided by the number of outstanding Shares. The Trust does not engage in any activities
designed to obtain a profit from, or ameliorate losses caused by, changes in the price of palladium.

 The
Trust issues and redeems Shares only in exchange for palladium, only in aggregations of 12,500 Shares effective June 18, 2024
(Prior to June 18, 2024, the number of Shares that constituted a Basket was 25,000 Shares) or integral multiples thereof (each,
a "Basket"), and only in transactions with registered broker-dealers (or other securities market participants not
required to register as broker-dealers, such as a bank or other financial institution) that (1) are participants in DTC and (2)
have previously entered into an agreement with the Trust governing the terms and conditions of such issuance (such dealers, the
"Authorized Participants").

 As
of the date of this annual report the Authorized Participants that have signed an Authorized Participant Agreement with the Trust
are Goldman Sachs & Co., HSBC Securities (USA) Inc., J.P. Morgan Securities LLC, Merrill Lynch Professional Clearing Corp.,
Mizuho Securities USA LLC, Morgan Stanley & Co. Inc., Scotia Capital (USA) Inc., UBS Securities LLC and Virtu Americas, LLC.

 Shares
of the Trust trade on the NYSE Arca under the symbol "PALL."

 Investing
in the Shares does not insulate the investor from certain risks, including price volatility. The following table illustrates the
movement in the NAV of the Shares against the corresponding palladium price (per 1/10 of an oz. of palladium) since inception:

 NAV
per Share vs. Palladium Price from December 30, 2009 (the Date of Inception) to December 31, 2024

 The
divergence of the NAV per Share from the palladium price over time reflects the cumulative effect of the Trust expenses that arise
if an investment had been held since inception.

 Critical
Accounting Policy

 The
financial statements and accompanying notes are prepared in accordance with accounting principles generally accepted in the United
States of America. The preparation of these financial statements relies on estimates and assumptions that impact the Trust's
financial position and results of operations. These estimates and assumptions affect the Trust's application of accounting
policies. Below we describe the valuation of palladium bullion, a critical accounting policy that we believe is important to understanding
the results of operations and financial position. In addition, please refer to Note 2 to the Financial Statements for further
discussion of the Trust's accounting policies.

 Valuation
of Palladium

 Palladium
is held by the Custodian on behalf of the Trust, at its London, England vaulting premises. Palladium may also be held by UBS AG,
or any other firm selected by the Custodian to hold the Trust's palladium in the Trust's allocated account in the
firm's Zurich vault premises and whose appointment has been approved by the Sponsor. Palladium is recorded at fair value.
The cost of palladium is determined according to the average cost method and the fair value is based on the LBMA Palladium Price PM or the
LBMA Palladium Price AM if no LBMA Palladium Price PM is available. If neither price is available for that day, the Trust will value its palladium based
on the most recently announced LBMA Palladium Price PM or LBMA Palladium Price AM. Realized gains and losses on transfers of palladium, or palladium distributed
for the redemption of Shares, are calculated on a trade date basis as the difference between the fair value and cost of palladium
transferred.

 31, 2024

 31, 2023

 31, 2022

 (Amounts
 in 000's of US$)

 in palladium - cost

 $
 490,759

 $
 356,585

 $
 334,209

 Unrealized
 gain/(loss) on investment in palladium

 (136,516
)

 (137,164
)

 (38,571
)

 in palladium - fair value

 $

 $

 $
 295,638

 Inspection
of Palladium

 Under
the Custody Agreements, the Trustee, the Sponsor and the Trust's auditors and inspectors may, only up to twice a year, visit
the premises of the Custodian for the purpose of examining the Trust's palladium and certain related records maintained
by the Custodian. The Trustee and the Sponsor have no right to visit the premises of any sub-custodian for the purposes of examining
the Trust's palladium or any records maintained by the sub-custodian, and no sub-custodian is obligated to cooperate
in any review the Trustee or the Sponsor may wish to conduct of the facilities, procedures, records or creditworthiness of such
sub-custodian.

 The
Sponsor has exercised its right to visit the Custodian in order to examine the palladium and the records maintained by them. Inspections
were conducted by Bureau Veritas Commodities UK Ltd, a leading commodity inspection and testing company retained by the Sponsor,
as of July 26, 2024 and January 4, 2025.

 There
can be no guarantee that the Sponsor or the Trust's auditors and inspectors will be able to perform physical inspections
of the Trust's palladium as planned. Local policies, regulations, or ordinances, as well as polices or restrictions
adopted by the Custodian or a sub-custodian, may temporarily prevent, or otherwise impair the ability of, the Sponsor or the Trust's
auditors and inspectors, from performing a physical inspection of the Trust's palladium on a desired date. In those
situations, the Sponsor or the Trust's auditors and inspectors may seek to verify the palladium held by the Trust
by alternate means, including through virtual inspections of the Trust's palladium and/or a review of pertinent records.

 Liquidity
and Capital Resources

 The
Trust is not aware of any trends, demands, conditions, events or uncertainties that are reasonably likely to result in material
changes to its liquidity needs. In exchange for the Sponsor's Fee, the Sponsor has agreed to assume most of the expenses
incurred by the Trust. As a result, the only expense of the Trust during the period covered by this report was the Sponsor's
Fee. The Trust's only source of liquidity is its transfers and sales of palladium.

 The
Trustee will, at the direction of the Sponsor or in its own discretion, sell the Trust's palladium as necessary
to pay the Trust's expenses not otherwise assumed by the Sponsor. The Trustee will not sell palladium to pay the Sponsor's
Fee but will pay the Sponsor's Fee through in-kind transfers of palladium to the Sponsor. At December 31, 2024
and 2023, the Trust did not have any cash balances.

 Results of Operations

 Financial
Highlights

 Year
 Ended

 Year
 Ended

 Year
 Ended
 December 31, 2022

 (Amounts
 in 000's of US$)

 Total gain/(loss)
 on palladium

 $
 (65,908
)

 $
 (109,918
)

 $
 (58,254
)

 Net change assets from
 operations

 $
 (67,646
)

 $
 (111,382
)

 $
 (60,481
)

 Net cash provided by
 operating activities

 $
 —

 $
 —

 $
 —

 The net asset value of the Trust will be obtained by subtracting the Trust's expenses and liabilities on any day from the value
of the palladium owned by the Trust on that day; the NAV per Share will be obtained by dividing the net asset value of the Trust on a
given day by the number of Shares outstanding on that day. On each day on which the Exchange is open for regular trading, the Trustee
will determine the net asset value of the Trust and the NAV per Share as promptly as practicable after 4:00 p.m. (New York time). The
Trustee will value the Trust's palladium on the basis of LBMA Palladium Price PM. If there is no LBMA Palladium Price PM on any
day, the Trustee is authorized to use the LBMA Palladium Price AM announced on that day. If neither price is available for that day, the
Trustee will value the Trust's Palladium based on the most recently announced LBMA Palladium Price PM or LBMA Palladium Price AM.
If the Sponsor determines that such price is inappropriate to use, the Sponsor will identify an alternate basis for evaluation to be employed
by the Trustee. Further, the Sponsor may instruct the Trustee to use on an on-going basis a different publicly available price which the
Sponsor determines to fairly represent the commercial value of the Trust's palladium.

 The
year ended December 31, 2024

 The
Trust's NAV increased from $219,309,330 at December 31, 2023 to $354,057,800 at December 31, 2024, a 61.44% increase for
the year. The increase in the Trust's NAV resulted primarily from an increase in outstanding shares, which rose from 2,100,000
at December 31, 2023 to 4,262,500 at December 31, 2024, a result of 4,037500 Shares (323 baskets) being created and 1,875,000
Shares (150 Baskets) being redeemed during the year. There was a decrease in the price per ounce of palladium, which fell 19.98%
from $1,136.00 at December 31, 2023 to $909.00 at December 31, 2024.

 The
NAV per Share decreased 20.46% from $104.43 at December 31, 2023 to $83.06 at December 31, 2024. The Trust's NAV per Share
fell slightly more than the price per ounce of palladium on a percentage basis due to the Sponsor's Fee, which was $1,737,833
for the year, or 0.60% of the Trust's ANAV.

 The
NAV per Share of $111.78 at October 29, 2024 was the highest during the year, compared with a low of $78.04 at August 5, 2024.

 The
decrease in net assets from operations for the year ended December 31, 2024 was $67,646,310, resulting from a realized loss of
$813,307 on the transfer of palladium to pay expenses and a realized loss of $65,743,179 on palladium distributed for the redemption
of Shares, offset by a change in unrealized gain on investment in palladium of $648,009 and the Sponsor's Fee of $1,737,833.
Other than the Sponsor's Fee, the Trust had no expenses during the year ended December 31, 2024.

 The
year ended December 31, 2023

 The
Trust's NAV decreased from $295,490,794 at December 31, 2022 to $219,309,330 at December 31, 2023, a 25.78% decrease for
the year. The decrease in the Trust's NAV resulted primarily from an increase in outstanding shares, which rose from 1,800,000
at December 31, 2022 to 2,100,000 at December 31, 2023, a result of 575,000 Shares (23 baskets) being created and 275,000 Shares
(11 Baskets) being redeemed during the year. There was a decrease in the price per ounce of palladium, which fell 36.00% from
$1,775,000 at December 31, 2022 to $1,136.00 at December 31, 2023.

 The
NAV per Share decreased 36.39% from $164.16 at December 31, 2022 to $104.43 at December 31, 2023. The Trust's NAV per Share
fell slightly more than the price per ounce of palladium on a percentage basis due to the Sponsor's Fee, which was $1,464,063
for the year, or 0.60% of the Trust's ANAV.

 The
NAV per Share of $166.63 at January 10, 2023 was the highest during the year, compared with a low of $88.01 at December 6, 2023.

 The
decrease in net assets from operations for the year ended December 31, 2023 was $111,381,953, resulting from a realized loss of
$578,564 on the transfer of palladium to pay expenses and a realized loss of $10,746,737 on palladium distributed for the redemption
of Shares, offset by a change in unrealized loss on investment in palladium of $98,592,589 and the Sponsor's Fee of $1,464,063.
Other than the Sponsor's Fee, the Trust had no expenses during the year ended December 31, 2023.

 The
year ended December 31, 2022

 The
Trust's NAV decreased from $357,971,468 at December 31, 2021 to $295,490,794 at December 31, 2022, a 17.45% decrease for
the year. The decrease in the Trust's NAV resulted primarily from a decrease in outstanding shares, which fell from 1,950,000
at December 31, 2021 to 1,800,000 at December 31, 2022, a result of 625,000 Shares (25 baskets) being created and 775,000 Shares
(31 Baskets) being redeemed during the year. There was a decrease in the price per ounce of palladium, which fell 9.38% from $1,973.00
at December 31, 2021 to $1,775,000 at December 31, 2022.

 The
NAV per Share decreased 10.58% from $183.58 at December 31, 2021 to $164.16 at December 31, 2022. The Trust's NAV per Share
fell slightly more than the price per ounce of palladium on a percentage basis due to the Sponsor's Fee, which was $2,226,662
for the year, or 0.60% of the Trust's ANAV.

 The
NAV per Share of $280.22 at March 7, 2022 was the highest during the year, compared with a low of $154.94 at December 20, 2022.

 The
decrease in net assets from operations for the year ended December 31, 2022 was $60,480,880, resulting from a realized gain of
$154,729 on the transfer of palladium to pay expenses and a realized gain of $3,889,466 on palladium distributed for the redemption
of Shares, offset by a change in unrealized loss on investment in palladium of $62,298,413 and the Sponsor's Fee of $2,226,662.
Other than the Sponsor's Fee, the Trust had no expenses during the year ended December 31, 2022.

 Off-Balance
Sheet Arrangements

 The
Trust is not a party to any off-balance sheet arrangements.

 Item
7A. Quantitative and Qualitative Disclosures about Market Risk

 The
Trust Agreement does not authorize the Trustee to borrow for payment of the Trust's ordinary expenses. The Trust does not
engage in transactions in foreign currencies which could expose the Trust or holders of Shares to any foreign currency related
market risk. The Trust invests in no derivative financial instruments and has no foreign operations or long-term debt instruments.

 Item
8. Financial Statements and Supplementary Data (Unaudited)

 Quarterly
Income Statements

 Year
 Ended December 31, 2024

 Three
 months ended

 Year
 ended

 March

 June

 September

 (Amounts in 000's of US$, except for Share and per Share data)

 EXPENSES

 Sponsor's
 Fee

 $

 $

 $

 $

 $
 1,738

 Total expenses

 1,738

 Net
 investment loss

 (315
)

 (396
)

 (416
)

 (611
)

 (1,738
)

 REALIZED
 AND UNREALIZED GAINS / (LOSSES)

 Realized gain on palladium
 transferred to pay expenses

 (228
)

 (213
)

 (229
)

 (143
)

 (813
)

 Realized gain / (loss)
 on palladium distributed for the redemption of Shares

 (11,719
)

 (11,584
)

 (16,344
)

 (26,096
)

 (65,743
)

 in unrealized gain on investment in Bullion

 (8,862
)

 26,905

 (18,379
)

 Total
 gain / (loss) on investment in palladium

 (20,809
)

 (10,813
)

 10,332

 (44,618
)

 (65,908
)

 in net assets from operations

 $
 (21,124
)

 $
 (11,209
)

 $
 9,916

 $
 (45,229
)

 $
 (67,646
)

 Net
 increase in net assets per Share

 $
 (9.02
)

 $
 (3.81
)

 $
 3.13

 $
 (10.38
)

 $
 (21.10
)

 Weighted
 average number of Shares

 2,342,582

 2,942,857

 3,166,304

 4,356,929

 3,205,255

 Year Ended December
 31, 2023

 Three
 months ended

 Year
 ended

 March

 June

 September

 (Amounts
 in 000's of US$, except for Share and per Share data)

 EXPENSES

 Sponsor's
 Fee

 $

 $

 $

 $

 $
 1,464

 Total expenses

 1,464

 Net
 investment loss

 (419
)

 (382
)

 (356
)

 (307
)

 (1,464
)

 REALIZED
 AND UNREALIZED GAINS / (LOSSES)

 Realized gain on palladium
 transferred to pay expenses

 (73
)

 (125
)

 (171
)

 (210
)

 (579
)

 Realized gain / (loss)
 on palladium distributed for the redemption of Shares

 (6,533
)

 (1,352
)

 (2,863
)

 (10,746
)

 in unrealized gain on investment in Bullion

 (41,035
)

 (41,069
)

 9,482

 (25,971
)

 (98,593
)

 Total
 gain / (loss) on investment in palladium

 (47,641
)

 (42,546
)

 6,448

 (26,179
)

 (109,918
)

 in net assets from operations

 $
 (48,060
)

 $
 (42,928
)

 $
 6,092

 $
 (26,486
)

 $
 (111,382
)

 Net
 increase in net assets per Share

 $
 (24.83
)

 $
 (21.68
)

 $
 3.10

 $
 (13.00
)

 $
 (56.28
)

 Weighted average
 number of Shares

 1,935,833

 1,979,945

 1,962,500

 2,036,957

 1,979,041

 Note:
Quarterly balances may not add to totals due to independent rounding.

 The
financial statements required by Regulation S-X, together with the report of the Trust's independent registered public accounting
firm appear on pages F-1 to F-13 of this filing.

 Item
9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosures

 None.

 Item
9A. Controls and Procedures

 The
Trust maintains disclosure controls and procedures that are designed to ensure that information required to be disclosed in its
Exchange Act reports is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange
Commission's rules and forms, and that such information is accumulated and communicated to the Chief Executive Officer and
Chief Financial Officer of the Sponsor, and to the audit committee, as appropriate, to allow timely decisions regarding required
disclosure.

 Under
the supervision and with the participation of the Chief Executive Officer and the Chief Financial Officer of the Sponsor, the
Sponsor conducted an evaluation of the Trust's disclosure controls and procedures, as defined under Exchange Act Rules 13a-15(e)
and 15d-15(e). Based on this evaluation, the Chief Executive Officer and the Chief Financial Officer of the Sponsor concluded
that, as of December 31, 2024, the Trust's disclosure controls and procedures were effective.

 Internal
controls over financial reporting have been maintained throughout the Trust's fiscal year ended December 31, 2024. There
have been no changes that have materially affected, or are reasonably likely to materially affect, the Trust's or Sponsor's
internal control over financial reporting.

 Management's
Report on Internal Control over Financial Reporting

 The
Sponsor's management is responsible for establishing and maintaining adequate internal control over financial reporting,
as defined under Exchange Act Rules 13a-15(f) and 15d-15(f). The Trust's internal control over financial reporting is a
process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial
statements for external purposes in accordance with accounting principles generally accepted in the United States. Internal control
over financial reporting includes those policies and procedures that:

 (1)
 pertain
 to the maintenance of records that, in reasonable detail, accurately and fairly reflect
 the transactions and dispositions of the Trust's assets;

 (2)
 provide
 reasonable assurance that transactions are recorded as necessary to permit preparation
 of financial statements in accordance with generally accepted accounting principles,
 and that the Trust's receipts and expenditures are being made only in accordance
 with appropriate authorizations; and

 (3)
 provide
 reasonable assurance regarding prevention or timely detection of unauthorized acquisition,
 use, or disposition of the Trust's assets that could have a material effect on
 the financial statements.

 Because
of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections
of any evaluation of effectiveness to future periods are subject to the risk that controls may become ineffective because of changes
in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

 The
Chief Executive Officer and Chief Financial Officer of the Sponsor assessed the effectiveness of the Trust's internal control
over financial reporting as of December 31, 2024. In making this assessment, they used the criteria set forth by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control—Integrated Framework (2013). Their
assessment included an evaluation of the design of the Trust's internal control over financial reporting and testing of
the operational effectiveness of its internal control over financial reporting. Based on their assessment and those criteria,
the Chief Executive Officer and Chief Financial Officer of the Sponsor concluded that the Trust maintained effective internal
control over financial reporting as of December 31, 2024.

 KPMG
LLP, the independent registered public accounting firm that audited and reported on the financial statements included in this
Form 10-K, as stated in their report which is included herein, issued an attestation report on the effectiveness of the Trust's
internal control over financial reporting as of December 31, 2024.

 KPMG LLP

 345 Park Avenue

New York, NY 10154-0102

 Report of Independent Registered Public Accounting
Firm

 To the Sponsor, Trustee and Shareholders

abrdn Palladium ETF Trust:

 Opinion on
Internal Control Over Financial Reporting

 We have audited abrdn Palladium ETF
Trust's (known as Aberdeen Standard Palladium ETF Trust prior to March 31, 2022) (the Trust) internal control over financial
reporting as of December 31, 2024, based on criteria established in Internal Control – Integrated Framework (2013) issued
by the Committee of Sponsoring Organizations of the Treadway Commission. In our opinion, the Trust maintained, in all material respects,
effective internal control over financial reporting as of December 31, 2024, based on criteria established in Internal Control
– Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway
Commission.

 We also have audited, in accordance
with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the statements of assets and liabilities
of the Trust, including the schedules of investments, as of December 31, 2024 and 2023, the related statements of operations and changes
in net assets and the financial highlights for each of the years in the three-year period ended December 31, 2024, and the related notes
(collectively, the financial statements), and our report dated February 28, 2025 expressed an unqualified opinion on those financial statements.

 Basis for
Opinion

 The Trust's management is responsible
for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over
financial reporting, included in the accompanying Management's Report on Internal Control over Financial Reporting. Our responsibility
is to express an opinion on the Trust's internal control over financial reporting based on our audit. We are a public accounting
firm registered with the PCAOB and are required to be independent with respect to the Trust in accordance with the U.S. federal securities
laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

 We conducted our audit in accordance
with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether
effective internal control over financial reporting was maintained in all material respects. Our audit of internal control over financial
reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness
exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audit also
included performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable
basis for our opinion.

 Definition
and Limitations of Internal Control Over Financial Reporting

 A company's internal control
over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company's
internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that,
in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable
assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management
and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition,
use, or disposition of the company's assets that could have a material effect on the financial statements.

 Because of its inherent limitations,
internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness
to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.

 /s/ KPMG LLP

 New York, New York

February 28, 2025

 KPMG LLP, a Delaware limited liability partnership and a member firm of

the KPMG global organization of independent member firms affiliated with

KPMG International Limited, a private English company limited by guarantee.

 Item
9B. Other Information

 No
officers or directors of the Trust have adopted, modified or terminated trading plans under either a Rule 10b5-1 or non-Rule 10b51
trading arrangement for the year ended December 31, 2024.

 Item
9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

 Not applicable.

 PART
III

 Item
10. Directors, Executive Officers and Corporate Governance

 The Trust has no officers, employees or board of trustees and is administered by the Trustee pursuant to the Trust Agreement. Accordingly,
the Trust has not adopted a code of ethics or an insider trading policy governing the purchase, sale and other disposition of the Trust's
securities. The biographies of the President and Chief Executive Officer of the Sponsor and
the Chief Financial Officer and Treasurer of the Sponsor are set out below:

 Steven
Dunn – President and Chief Executive Officer

 Mr.
Dunn, CIMA, is the Head of Exchange Traded Funds at abrdn Inc. Mr. Dunn guides the firm's strategic direction and distribution
strategy for ETFs. Previously, he was a Director with Deutsche Asset and Wealth Management in charge of managing relationships
with US ETF Strategists and overseeing the Eastern Division sales team. Prior to that, Mr. Dunn was a consultant at Brandywine
Global Investment Management and has also held sales and distribution strategy positions at iShares, Blackrock and Vanguard. Mr.
Dunn holds a B.A. degree in Public Administration from Shippensburg University of Pennsylvania and has completed his MBA at Pennsylvania
State University. He holds the Series 7, 24, and 63 registrations as well as the Certified Investment Management Analyst
(CIMA).

 Sharon
Ferrari – Chief Financial Officer and Treasurer

 Sharon
Ferrari is currently a Director, Product Management at abrdn Inc. (the parent company of the Sponser). Ms. Ferrari joined abrdn in
2008. Prior to working at abrdn, Ms. Ferrari worked at Delaware Investments for about 3 years and began her career at SEI Investments.
Ms. Ferrari holds a BS in Business Administration from University of Pittsburgh and a MBA from Villanova University.

 Departure
of Directors or Principal Officers; Election of Directors; Appointment of Principal Officers.

 Effective
November 12, 2024, Brian Kordeck resigned as Chief Financial Officer and Treasurer of the Sponsor. Mr. Kordeck served as Principal
Financial Officer of the Registrant.

 Sharon
Ferrari was appointed as Chief Financial Officer and Treasurer of the Sponsor, effective on November 12, 2024. Ms. Ferrari serves
as Principal Financial Officer of the Registrant.

 As
described under Item 1 above, abrdn Inc. is the parent of the Sponsor.

 Item
11. Executive Compensation

 The
Trust has no directors or executive officers. The only ordinary expense paid by the Trust is the Sponsor's Fee.

 Item
12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

 Security
Ownership of Certain Beneficial Owners

 There
are no persons known by the Trust to own directly or indirectly beneficially more than 5% of the outstanding Shares of the Trust.

 Security
Ownership of Management

 Not
applicable.

in Control

 Neither
the Sponsor nor the Trustee knows of any arrangements which may subsequently result in a change in control of the Trust.

 Item
13. Certain Relationships and Related Transactions, and Director Independence

 The
Trust has no directors or executive officers.

 Item
14. Principal Accounting Fees and Services

 Fees
for services performed by KPMG LLP for the years ended December 31, 2024 and 2023

 New York, NY Auditor ID: 185

 31,

2024

 31,

2023

 Audit fees
 – KPMG

 $
 94,000

 $
 85,000

 Audit
 related fees - KPMG

 19,500

 $
 94,000

 $
 104,500

 Audit
Fees are fees paid by the Sponsor to KPMG LLP for professional services for the audit of the Trust's financial statements
included in the Form 10-K and review of financial statements included in the Form 10-Qs, and for services that are normally provided
by the accountants in connection with regulatory filings or engagements. Audit Related Fees are paid by the Sponsor to KPMG LLP
for assurance and related services that are reasonably related to the performance of the audit or review of the Trust's
financial statements. These services include the accountant providing a consent letter related to the Trust's registration statement
filing.

 Pre-Approval
Policies and Procedures

 As
referenced in Item 10 above, the Trust has no board of directors, and as a result, has no pre-approval policies or procedures
with respect to fees paid to KPMG LLP. Such determinations are made by the Sponsor.

 PART
IV

 Item
15. Exhibits, Financial Statement Schedules

 1.
Financial Statements

 See
Index to Financial Statements on Page F-1 for a list of the financial statements being filed herein.

 2.
Financial Statement Schedules

 Schedules
have been omitted since they are either not required, not applicable, or the information has otherwise been included.

 Exhibit
 No.

 4.1(a)

 Depositary
 Trust Agreement, incorporated by reference to Exhibit 4.1 filed with Registration Statement No. 333-158380 on December 31,
 2009

 4.1(b)

 Amendment
 to the Depositary Trust Agreement, incorporated by reference to Exhibit 4.1(b) filed with the Trust's Annual Report
 on Form 10-K for the year ended December 31, 2019 filed on February 28, 2020

 4.1(c)

 Second
 Amendment to the Depositary Trust Agreement, incorporated by reference to Exhibit 4.1
 filed with the Trust's Current Report on Form 8-K on March 14, 2022

 4.1(d)

 Third Amendment to the Depositary Trust Agreement, incorporated by reference to Exhibit 4.1 filed with the Trust's Current Report on Form 8-K on May 28, 2024

 4.2

 Form of Authorized Participant Agreement, is filed herewith

 4.3

 Certificate
 of Beneficial Interest, incorporated by reference to Exhibit 4.3 filed with Registration Statement No. 333-158380 on December
 31, 2009

 10.1

 Allocated Account Agreement, incorporated by reference to Exhibit 10.1 filed with the Trust's Current Report on Form 8-K on May 28, 2024

 10.2

 Unallocated Account Agreement, incorporated by reference to Exhibit 10.2 filed with the Trust's Current Report on Form 8-K on May 28, 2024

 10.3

 Depository
 Agreement, incorporated by reference to Exhibit 10.3 filed with Registration Statement No. 333-158380 on December 31, 2009

 10.4(a)

 Marketing
 Agent Agreement, incorporated by reference to Exhibit 10.4 filed with Registration Statement No. 333-158380 on December 31,
 2009

 10.4(b)

 Novation
 of and Amendment No. 1 to the Marketing Agent Agreement effective as of October 1, 2018, incorporated by reference to Exhibit
 10.4(b) filed with the Trust's Annual Report on Form 10-K on March 1, 2019

 23.1

 Consent
 of KPMG LLP, Independent Registered Public Accounting Firm

 31.1

 Chief Executive Officer's Certificate, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

 31.2

 Chief Financial Officer's Certificate, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

 32.1

 Chief Executive Officer's Certificate, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

 32.2

 Chief Financial Officer's Certificate, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

 97.1

 Policy for Recovery of Erroneously Awarded Compensation, incorporated by reference to Exhibit 97.1 filed with the Trust's Annual Report of Form 10-K on February 29, 2024.

 The
 following financial statements from the Trust's Annual Report on Form 10-K for the year ended December 31, 2024, formatted
 Assets, and (iv) Notes to the Financial Statements.

 101.SCH

 101.CAL

 101.DEF

 101.LAB

 101.PRE

 The
 (included as Exhibit 101).

 Item
16. Form 10-K Summary

 Not
applicable.

 ABRDN
PALLADIUM ETF TRUST
 FINANCIAL STATEMENTS AS OF DECEMBER 31, 2024

 Page

 Report
 of Independent Registered Public Accounting Firm

 of Assets and Liabilities at December 31, 2024 and 2023

 Schedules
 of Investments at December 31, 2024 and 2023

 of Operations for the years ended December 31, 2024, 2023 and 2022

 of Changes in Net Assets for the years ended December 31, 2024, 2023 and 2022

 Financial
 Highlights for the years ended December 31, 2024, 2023 and 2022

 Notes

 F- 1

 KPMG LLP

 345 Park Avenue

New York, NY 10154-0102

 REPORT
OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 To the Sponsor, Trustee and Shareholders

abrdn Palladium ETF Trust:

 Opinion on
the Financial Statements

 We have audited the accompanying statements of assets and liabilities
of abrdn Palladium ETF Trust (known as Aberdeen Standard Palladium ETF Trust prior to March 31, 2022) (the Trust), including the schedules
of investments, as of December 31, 2024 and 2023, the related statements of operations and changes in net assets and the financial highlights
for each of the years in the three-year period ended December 31, 2024, and the related notes (collectively, the financial statements). In
our opinion, the financial statements present fairly, in all material respects, the financial position of the Trust as of December 31,
2024 and 2023, and the results of its operations, changes in its net assets and financial highlights for each of the years in the three-year
period ended December 31, 2024, in conformity with U.S. generally accepted accounting principles.

 We also have audited, in accordance with the standards of the Public
Company Accounting Oversight Board (United States) (PCAOB), the Trust's internal control over financial reporting as of December
31, 2024, based on criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring
Organizations of the Treadway Commission, and our report dated February 28, 2025 expressed an unqualified opinion on the effectiveness
of the Trust's internal control over financial reporting.

 Basis for
Opinion

 These financial statements are the responsibility of the Trust's
management. Our responsibility is to express an opinion on these financial statements based on our audits. We are a public accounting
firm registered with the PCAOB and are required to be independent with respect to the Trust in accordance with the U.S. federal securities
laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

 We conducted our audits in accordance with the standards of the PCAOB.
Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free
of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement
of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included
examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating
the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial
statements. We believe that our audits provide a reasonable basis for our opinion.

 Critical
Audit Matter

 The critical audit matter communicated below is a matter arising from
the current period audit of the financial statements that was communicated or required to be communicated to the audit committee and that:
(1) relates to accounts or disclosures that are material to the financial statements and (2) involved our especially challenging, subjective,
or complex judgments. The communication of a critical audit matter does not alter in any way our opinion on the financial statements,
taken as a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the critical audit
matter or on the accounts or disclosures to which it relates.

 Evaluation of the evidence pertaining to the existence of the palladium
holdings

 As presented on the December 31, 2024 schedule of investments and in
 Note 2.2, the fair value of the Trust's investment in palladium is $354,243 thousand, representing
100.05% of the Trust's net assets, and 389,706.3 ounces of palladium holdings. The investment i n
 palladium was held by a third-party custodian (the custodian).

 We identified the evaluation of the evidence pertaining to the existence
of the palladium holdings as a critical audit matter. Given the nature and volume of the
 palladium holdings, subjective auditor judgment was required to evaluate the extent and nature
of evidence obtained to assess the existence of palladium held by the custodian.

 The following are the primary procedures we performed to address this
critical audit matter. We evaluated the design and tested the operating effectiveness of certain internal controls related to the critical
audit matter. This included controls over (1) the comparison of the Trust's records of palladium
 held to the custodian's records, (2) the approval of palladium deposits and withdrawals
by the trustee of the Trust and (3) the physical counts of the Trust's palladium holdings
performed at the custodian's locations by a third party engaged by the Trust's sponsor. We obtained a schedule directly from the custodian
of the Trust's palladium holdings held by the custodian as of December 31, 2024. We compared
the total ounces on such schedule to the Trust's record of palladium holdings. We also attended
and observed a part of the physical counts of the Trust's palladium holdings. We obtained
and read the physical counts results reports of the third party and reconciled those reports to both the Trust's and custodian's records.

 /s/ KPMG LLP

 We have served as the Trust's auditor since 2015.

 New York, New York

February 28, 2025

 KPMG LLP, a Delaware limited liability partnership and a member firm of

the KPMG global organization of independent member firms affiliated with

KPMG International Limited, a private English company limited by guarantee.

 F- 2

 abrdn

of Assets and Liabilities

 At
December 31, 2024 and 2023

 (Amounts in 000's of US$, except for Share and per Share data)

 ASSETS

 Investment in palladium (cost: December 31, 2024: $ 490,759; December 31, 2023: $ 356,585)

 $

 $

 Total assets

 LIABILITIES

 Fees payable to Sponsor

 Total liabilities

 NET ASSETS (1)

 $
 354,058

 $
 219,309

 (1)

 share capital is Unlimited with no par value per Share. Shares issued and outstanding at December 31, 2024 were 4,262,500
 and at December 31, 2023 were 2,100,000. Net asset values per Share at December 31, 2024 and December 31, 2023 were $ 83.06
 and $ 104.43, respectively.

 See

 F- 3

 abrdn

 Schedules
of Investments

 At
December 31, 2024 and 2023

 oz

 Cost

 Fair Value

 % of Net Assets

 Investment in palladium (in 000's of US$, except
for oz and percentage data)

 Palladium

 389,706.3

 $
 490,759

 $

 100.05
 %

 Total investment in palladium

 389,706.3

 $
 490,759

 $

 100.05
 %

 Less liabilities

 ( 185
)

 ( 0.05
)%

 Net Assets

 $
 354,058

 100.00
 %

 oz

 Cost

 Fair Value

 % of Net Assets

 Investment in palladium (in 000's of US$, except
for oz and percentage data)

 Palladium

 193,152.2

 $
 356,585

 $

 100.05
 %

 Total investment in palladium

 193,152.2

 $
 356,585

 $

 100.05
 %

 Less liabilities

 ( 112
)

 ( 0.05
)%

 Net Assets

 $
 219,309

 100.00
 %

 See

 F- 4

 abrdn

of Operations

 For
the years ended December 31, 2024, 2023, and 2022

 December 31, 2022

 (Amounts in 000's of US$, except for Share and per Share data)

 EXPENSES

 Sponsor's Fee

 $
 1,738

 $
 1,464

 $
 2,227

 Total expenses

 1,738

 1,464

 2,227

 ( 1,738
)

 ( 1,464
)

 ( 2,227
)

 REALIZED AND UNREALIZED GAINS / (LOSSES)

 Realized (loss) / gain on palladium transferred to pay expenses

 ( 813
)

 ( 579
)

 Realized (loss) / gain on palladium distributed for the redemption of Shares

 ( 65,743
)

 ( 10,746
)

 3,889

 Change in unrealized gain / (loss) on investment in palladium

 ( 98,593
)

 ( 62,298
)

 Total (loss) on investment in palladium

 ( 65,908
)

 ( 109,918
)

 ( 58,254
)

 Change in net assets from operations

 $
 ( 67,646
)

 $
 ( 111,382
)

 $
 ( 60,481
)

 Net (decrease) in net assets per Share

 $
 ( 21.10
)

 $
 ( 56.28
)

 $
 ( 32.12
)

 Weighted average number of Shares

 3,205,225

 1,979,041

 1,882,740

 See

 F- 5

 abrdn

of Changes in Net Assets

 For
the years ended December 31, 2024, 2023 and 2022

 Year Ended December 31, 2024

 Shares

 Amount

 (Amounts in 000's of US$, except for Share data)

 Opening balance at January 1, 2024

 2,100,000

 $
 219,309

 ( 1,738
)

 Realized (loss) on investment in palladium

 ( 66,556
)

 Change in unrealized gain on investment in palladium

 4,037,500

 372,697

 ( 1,875,000
)

 ( 170,302
)

 Closing balance at December 31, 2024

 4,262,500

 $
 354,058

 Year Ended December 31, 2023

 Shares

 Amount

 (Amounts in 000's of US$, except for Share data)

 Opening balance at January 1, 2023

 1,800,000

 $
 295,491

 ( 1,464
)

 Realized (loss) on investment in palladium

 ( 11,325
)

 Change in unrealized (loss) on investment in palladium

 ( 98,593
)

 575,000

 73,610

 ( 275,000
)

 ( 38,410
)

 Closing balance at December 31, 2023

 2,100,000

 $
 219,309

 Year Ended December 31, 2022

 Shares

 Amount

 (Amounts in 000's of US$, except for Share data)

 Opening balance at January 1, 2022

 1,950,000

 $
 357,971

 ( 2,227
)

 Realized gain on investment in palladium

 4,044

 Change in unrealized (loss) on investment in palladium

 ( 62,298
)

 625,000

 145,623

 ( 775,000
)

 ( 147,622
)

 Closing balance at December 31, 2022

 1,800,000

 $
 295,491

 See

 F- 6

 abrdn

 Financial
Highlights

 For
the years ended December 31, 2024, 2023 and 2022

 December 31, 2022

 Per Share Performance (for a Share outstanding throughout the entire period)

 Net asset value per Share at beginning of period

 $
 104.43

 $
 164.16

 $
 183.58

 Income from investment operations:

 ( 0.54
)

 ( 0.74
)

 ( 1.18
)

 Total realized and unrealized gains or losses on investment in palladium

 ( 20.83
)

 ( 58.99
)

 ( 18.24
)

 Change in net assets from operations

 ( 21.37
)

 ( 59.73
)

 ( 19.42
)

 Net asset value per Share at end of period

 $
 83.06

 $
 104.43

 $
 164.16

 Weighted average number of Shares

 3,205,225

 1,979,041

 1,882,740

 Expense ratio

 0.60
 %

 0.60
 %

 0.60
 %

 Net investment loss ratio

 ( 0.60
)%

 ( 0.60
)%

 ( 0.60
)%

 Total return, net asset value

 ( 20.46
)%

 ( 36.39
)%

 ( 10.58
)%

 See

 F- 7

 abrdn

 Notes

 1.
 Organization

 The abrdn
Palladium ETF Trust (the "Trust") is a common law trust formed on December 30, 2009 under New York
law pursuant to a depositary trust agreement (the "Trust Agreement") executed by abrdn ETFs Sponsor LLC (the
"Sponsor") and The Bank of New York Mellon as Trustee (the "Trustee"). The Trust holds palladium and effective June 18, 2024, issues abrdn Physical Palladium Shares ETF ("Shares") in minimum blocks
of 12,500 Shares (also referred to as "Baskets") in exchange for deposits of palladium and distributes palladium in connection
with the redemption of Baskets. Prior to June 18, 2024, the number of Shares that constituted a Basket was 25,000. Shares represent units of fractional undivided beneficial interest in and ownership of the Trust
which are issued by the Trust. The Sponsor is a Delaware limited liability company and a wholly-owned subsidiary of abrdn Inc.,
which is a wholly-owned indirect subsidiary of abrdn plc. The Trust is governed by the Trust Agreement.

 Effective November 12, 2024, Brian Kordeck resigned as Treasurer and Chief Financial Officer of the Sponsor. Mr. Kordeck had served as Principal Financial Officer of the Registrant. Effective November 12, 2024, Sharon Ferrari was appointed Treasurer and Chief Financial Officer of the Sponsor. Ms. Ferrari serves as Principal Financial Officer of the Registrant.

 The
investment objective of the Trust is for the Shares to reflect the performance of the price of physical palladium, less the
Trust's expenses. The Trust is designed to provide an individual owner of beneficial interests in the Shares (a "Shareholder")
an opportunity to participate in the palladium market through an investment in securities.

 2.
 Significant
Accounting Policies

 The
preparation of financial statements in accordance with U.S. GAAP requires those responsible for preparing financial statements
to make estimates and assumptions that affect the reported amounts and disclosures. Actual results could differ from those estimates.
The following is a summary of significant accounting policies followed by the Trust.

 2.1.
 Basis
of Accounting

 The
Sponsor has determined that the Trust falls within the scope of Financial Accounting Standards Board ("FASB") Accounting
Standards Codification ("ASC") 946, Financial Services—Investment Companies, and has concluded that for
reporting purposes, the Trust is classified as an Investment Company. The Trust is not registered as an investment company under
the Investment Company Act of 1940 and is not required to register under such act.

 2.2.
 Valuation
of Palladium

 The
Trust follows the provisions of ASC 820, Fair Value Measurement ("ASC 820"). ASC 820 provides guidance for
determining fair value and requires increased disclosure regarding the inputs to valuation techniques used to measure fair value.
ASC 820 defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly
transaction between market participants at the measurement date.

 Effective
May 23, 2024, the Trustee, at the direction of the Sponsor, entered into an Allocated Account Agreement and Unallocated
Account Agreement with ICBC Standard Bank Plc ("ICBC"), providing for the custody of the Trust's palladium. Effective
August 8, 2024, JPMorgan
Chase Bank N.A. no longer serves as a custodian of the Trust's palladium. At December 31, 2024, all of the Trust's palladium was held
at ICBC.

 At the Evaluation Time, the Trustee will value the Trust's palladium on the basis of the London Bullion Market Association ("LBMA") Palladium Price PM. If there is no LBMA
Palladium Price PM on any day, the Trustee is authorized to use the LBMA Palladium Price AM announced on that day. If neither price is
available for that day, the Trustee will value the Trust's palladium based on the most recently announced LBMA Palladium Price PM
or LBMA Palladium Price AM. Realized gains and losses on transfers of palladium, or palladium
distributed for the redemption of Shares, are calculated on a trade date basis as the difference between the fair value and average cost
of palladium transferred.

 F- 8

 abrdn Palladium ETF Trust

 Notes

 The
LME is responsible for the administration of the electronic palladium price fixing system ("LMEbullion") that
replicates electronically the manual London palladium fix processes previously employed by the London Platinum and Palladium Fixing
Company Ltd ("LPPFCL"), as well as providing electronic market clearing processes for palladium bullion transactions
at the fixed prices established by the LME pricing mechanism. LMEbullion, like the previous London palladium fix processes, establishes
and publishes fixed prices for troy ounces of palladium twice each London trading day during fixing sessions beginning at 9:45
a.m. London time (the "LBMA Palladium Price AM") and 2:00 p.m. London time (the LBMA Palladium Price PM).

 Once
the value of palladium has been determined, the net asset value (the "NAV") is computed by the Trustee by deducting
all accrued fees, expenses and other liabilities of the Trust, including the remuneration due to the Sponsor (the "Sponsor's
Fee"), from the fair value of the palladium and all other assets held by the Trust.

 The
Trust recognizes changes in fair value of the investment in palladium as changes in unrealized gains or losses on investment
in palladium through the Statement of Operations.

 The
per Share amount of palladium exchanged for a purchase or redemption is calculated daily by the Trustee using the LBMA Palladium Price PM to calculate the palladium amount in respect of any liabilities for which covering palladium sales have not yet
been made, and represents the per Share amount of palladium held by the Trust, after giving effect to its liabilities, to
cover expenses and liabilities and any losses that may have occurred.

 Fair
Value Hierarchy

 ASC
820 establishes a hierarchy that prioritizes inputs to valuation techniques used to measure fair value. The three levels of inputs
are as follows:

 –
 Level
1. Unadjusted quoted prices in active markets for identical assets or liabilities that the Trust has the ability to access.

 –
 Level
2. Observable inputs other than quoted prices included in level 1 that are observable for the asset or liability either directly
or indirectly. These inputs may include quoted prices for the identical instrument on an inactive
market, prices for similar instruments and similar data.

 –
 Level
3. Unobservable inputs for the asset or liability to the extent that relevant observable inputs are not available, representing
the Trust's own assumptions about the assumptions that a market participant would use in valuing the asset or liability, and that
would be based on the best information available.

 To
the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination
of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining fair value is greatest for
instruments categorized in level 3.

 The
inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes,
the level in the fair value hierarchy within which the fair value measurement falls in its entirety is determined based on the
lowest level input that is significant to the fair value measurement in its entirety.

 F- 9

 abrdn

 Notes

 The
Trust's investment in palladium is classified as a level 1 asset, as its value is calculated using unadjusted
quoted prices from primary market sources.

 The
categorization of the Trust's assets is as shown below:

 (Amounts in 000's of US$)

31,

 2024

31,

 2023

 Level 1

 Investment in palladium

 $

 $

 There were no transfers between levels during the years ended December 31, 2024 and 2023.

 2.3.
 Palladium
Receivable and Payable

 Palladium receivable
or payable represents the quantity of palladium covered by contractually binding orders for the creation or redemption of
Shares respectively, where the palladium has not yet been transferred to or from the Trust's account. Generally, ownership
of palladium is transferred within one business days of the trade date. At December 31, 2024, the Trust had no palladium receivable
or payable for the creation or redemption of Shares. At December 31, 2023, the Trust had no palladium receivable
or payable for the creation or redemption of Shares.

 2.4.
and Redemptions of Shares

 The
Trust expects to create and redeem Shares from time to time, but only in one or more Baskets (Effective June 18, 2024, the number of Shares in a block that constitutes a Basket was reduced from 25,000 Shares to 12,500 Shares).
The Trust issues Shares in Baskets to Authorized Participants on an ongoing basis. Individual investors cannot purchase or redeem
Shares in direct transactions with the Trust. An Authorized Participant is a person who (1) is a registered broker-dealer or other
securities market participant such as a bank or other financial institution which is not required to register as a broker-dealer
to engage in securities transactions; (2) is a participant in The Depository Trust Company; (3) has entered into an Authorized
Participant Agreement with the Trustee and the Sponsor; and (4) has established an Authorized Participant Unallocated Account
with the Trust's Custodian or other palladium bullion clearing bank. An Authorized Participant Agreement is an agreement
entered into by each Authorized Participant, the Sponsor and the Trustee which provides the procedures for the creation and redemption
of Baskets and for the delivery of the palladium required for such creations and redemptions. An Authorized Participant
Unallocated Account is an unallocated palladium account established with the Custodian or a palladium bullion clearing
bank by an Authorized Participant.

 The
creation and redemption of Baskets is only made in exchange for the delivery to the Trust or the distribution by the Trust of
the amount of palladium represented by the Baskets being created or redeemed, the amount of which is based on the combined
NAV of the number of Shares included in the Baskets being created or redeemed determined on the day the order to create or redeem
Baskets is properly received.

Participants may, on any business day, place an order with the Trustee to create or redeem one or more Baskets. Effective May
28, 2024, the settlement period for Shares is one business day. Prior to May 28, 2024, the standard settlement period for Shares
was two business days. In the event of a trade date at period end, where a settlement is pending, a respective account receivable
and/or payable will be recorded. When palladium is exchanged in settlement of a redemption, it is considered a sale of palladium
for financial statement purposes.

 F- 10

 abrdn

 Notes

 The
amount of palladium represented by the Baskets created or redeemed can only be settled to the nearest 1/1000th of an ounce.
As a result, the value attributed to the creation or redemption of Shares may differ from the value of palladium to
be delivered or distributed by the Trust. In order to ensure that the correct amount of palladium is available at all times
to back the Shares, the Sponsor accepts an adjustment to its Sponsor's Fee in the event of any shortfall or excess on each
transaction. For each transaction, this amount is not more than 1/1000th of an ounce of palladium.

 As
the Shares of the Trust are subject to redemption at the option of Authorized Participants, the Trust has classified the outstanding
Shares as Net Assets. Changes in the number of Shares outstanding are presented in the Statement of Changes in Net Assets.

 2.5.
 Income
Taxes

 The
Trust is classified as a "grantor trust" for U.S. federal income tax purposes. As a result, the Trust itself will
not be subject to U.S. federal income tax. Instead, the Trust's income and expenses will "flow through" to the
Shareholders, and the Trustee will report the Trust's proceeds, income, deductions, gains, and losses to the Internal Revenue
Service on that basis.

 The
Sponsor has evaluated whether or not there are uncertain tax positions that require financial statement recognition and has determined
that no reserves for uncertain tax positions are required as of December 31, 2024 or December 31, 2023.

 2.6.

 Investment in Palladium

 Changes
in ounces of palladium and their respective values for the years ended December 31, 2024 and 2023 are set
out below:

 December 31,

2024

 December 31,

2023

 (Amounts in 000's of US$, except for ounces data)

 Ounces of palladium

 Opening balance

 193,152.2

 166,556.4

 369,832.6

 53,072.5

 ( 171,620.1
)

 ( 25,394.5
)

 Transfers of palladium to pay expenses

 ( 1,658.4
)

 ( 1,082.2
)

 Closing balance

 389,706.3

 193,152.2

 Investment in palladium

 Opening balance

 $

 $
 295,638

 372,697

 73,610

 ( 170,302
)

 ( 38,410
)

 Realized (loss) / gain on palladium distributed for the redemption of Shares

 ( 65,743
)

 ( 10,746
)

 Transfers of palladium to pay expenses

 ( 1,665
)

 ( 1,499
)

 Realized gain on palladium transferred to pay expenses

 ( 813
)

 ( 579
)

 Change in unrealized gain/(loss) on investment in palladium

 ( 98,593
)

 Closing balance

 $

 $

 F- 11

 abrdn

 Notes

 2.7.
 Expenses
/ Realized Gains / Losses

 The primary expense of the Trust is the Sponsor's Fee, which is paid by the Trust through in-kind transfers of palladium
to the Sponsor.

 The
Trust will transfer palladium to the Sponsor to pay the Sponsor's Fee that accrues daily at an annualized rate equal
to 0.60 % of the adjusted daily net asset value ("ANAV") of the Trust, paid monthly in arrears.

 The
Sponsor has agreed to assume administrative and marketing expenses incurred by the Trust, including the Trustee's monthly
fee and out of pocket expenses, the Custodian's fee and the reimbursement of the Custodian's expenses, exchange listing
fees, United States Securities and Exchange Commission (the "SEC") registration fees, printing and mailing costs,
audit fees and up to $ 100,000 per annum in legal expenses.

 For
the years ended December 31, 2024, 2023 and 2022, the Sponsor's Fee was $ 1,737,833, $ 1,464,063 and
$ 2,226,662, respectively.

 At December
31, 2024 and at December 31, 2023, the fees payable to the Sponsor were $ 185,243 and $ 111,606, respectively.

 With
respect to expenses not otherwise assumed by the Sponsor, the Trustee will, at the direction of the Sponsor or in its own discretion,
sell the Trust's palladium as necessary to pay these expenses. When selling palladium to pay expenses, the Trustee
will endeavor to sell the smallest amounts of palladium needed to pay these expenses in order to minimize the Trust's
holdings of assets other than palladium. Other than the Sponsor's Fee, the Trust had no expenses during the years ended December
31, 2024 and 2023.

 Unless
otherwise directed by the Sponsor, when selling palladium the Trustee will endeavor to sell at the price established by the
LBMA Palladium Price PM. The Trustee will place orders with dealers (which may include the Custodian) through which the Trustee expects to
receive the most favorable price and execution of orders. The Custodian may be the purchaser of such palladium only if the
sale transaction is made at the next LBMA Palladium Price PM or such other publicly available price that the Sponsor deems fair, in each case
as set following the sale order. A gain or loss is recognized based on the difference between the selling price and the average
cost of the palladium sold. Neither the Trustee nor the Sponsor is liable for depreciation or loss incurred by reason of
any sale.

 Realized
gains and losses result from the transfer of palladium for Share redemptions and / or to pay expenses and are recognized
on a trade date basis as the difference between the fair value and average cost of palladium transferred.

 2.8.
 Segment Reporting

 In this reporting period, the Trust adopted FASB Accounting Standards Update 2023-07, Segment Reporting (Topic 280) - Improvements to
Reportable Segment Disclosures ("ASU 2023-07"). Adoption of the new standard impacted disclosures only and did not affect
the Trust's financial position nor the results of its operations. Operating segments are components of a public entity that engage in
business activities from which it may recognize revenues and incur expenses, have discrete financial information available, and have their
operating results regularly reviewed by the public entity's chief operating decision maker ("CODM") when assessing segment
performance and making decisions about segment resources. The Chief Financial Officer of the Sponsor acts as the Fund's CODM. The CODM
monitors the operating results of the Trust as a whole, and the Trust's asset allocation is managed in accordance with its Prospectus.
The Trust operates as a single operating and reporting segment pursuant to its investment objective and principal investment strategy.
The Trust's prospectus describes the Trust's fees, investment objective, principal investment strategy and principal risks, among other
items. The Fund's portfolio composition, total returns, expense ratios and changes in net assets used by the CODM to assess segment performance
and make resource allocations are consistent with the information presented within the Trust's financial statements. The accompanying
financial statements detail the Fund's segment assets, liabilities, revenues, and expenses. Segment assets are reflected on the Fund's
Statement of Assets and Liabilities as "Total Assets" and significant segment expenses are listed on the Statement of Operations.

 2.9.
 Subsequent
Events

 In
accordance with the provisions set forth in FASB ASC 855-10, Subsequent Events, the Trust's management has evaluated
the possibility of subsequent events impacting the Trust's financial statements through the filing date. During this period,
no material subsequent events requiring adjustment to or disclosure in the financial statements were identified.

 3.
 Related
Parties

 The
Sponsor and the Trustee are considered to be related parties to the Trust. The Trustee and the Custodian and their affiliates
may from time to time act as Authorized Participants and purchase or sell Shares for their own account, as agent for their customers
and for accounts over which they exercise investment discretion. In addition, the Trustee and the Custodian and their affiliates
may from time to time purchase or sell palladium directly, for their own account, as agent for their customers and for accounts
over which they exercise investment discretion. The Trustee's and Custodian's fees are paid by the Sponsor and are
not separate expenses of the Trust.

 F- 12

 abrdn

 Notes

 4.
 Concentration
of Risk

 The
Trust's sole business activity is the investment in palladium, and substantially all the Trust's assets are holdings
of palladium, which creates a concentration of risk associated with fluctuations in the price of palladium. Several factors
could affect the price of palladium, including: (i) global palladium supply and demand, which is influenced by factors such as
production and cost levels in major palladium-producing countries, recycling, autocatalyst demand, industrial demand, jewelry
demand, investment demand, and sales of existing stockpiles of palladium, which have been a key source of supply and are likely
to be exhausted soon, placing a higher burden on new mine supply; (ii) investors' expectations with respect to the rate
of inflation; (iii) currency exchange rates; (iv) interest rates; (v) investment and trading activities of hedge funds and commodity
funds; and (vi) global or regional political, economic or financial events and situations. In addition, there is no assurance
that palladium will maintain its long-term value in terms of purchasing power in the future. In the event that the price
of palladium declines, the Sponsor expects the value of an investment in the Shares to decline proportionately. Each of these
events could have a material effect on the Trust's financial position and results of operations.

 5.
 Indemnification

 Under
the Trust's organizational documents, the Trustee (and its directors, employees and agents) and the Sponsor (and its members,
managers, directors, officers, employees and affiliates) are indemnified by the Trust against any liability, cost or expense it
incurs without gross negligence, bad faith, willful misconduct or willful malfeasance on its part and without reckless disregard
on its part of its obligations and duties under the Trust's organizational documents. The Trust's maximum exposure
under these arrangements is unknown as this would involve future claims that may be made against the Trust that have not yet occurred.

 F- 13

 ABRDN PALLADIUM ETF TRUST

 SIGNATURES

 Pursuant to the requirements of the Securities
Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned in the capacities
thereunto duly authorized.

 abrdn
 ETFs Sponsor LLC

 Date:
 February 28, 2025

 /s/
 Steven Dunn*

 Steven
 Dunn **

 President
 and Chief Executive Officer

 (Principal
 Executive Officer)

 Date:
 February 28, 2025

 /s/
 Sharon Ferrari*

 Sharon
 Ferrari **

 Chief
 Financial Officer and Treasurer

 (Principal
 Financial Officer and Principal Accounting Officer)

 *
 The
originally executed copy of this Certification will be maintained at the Sponsor's offices and will be made available for inspection
upon request.

 **
 The
Registrant is a trust and the persons are signing in their capacities as officers of abrdn ETFs Sponsor LLC, the Sponsor of the
Registrant.

 EXHIBIT INDEX

 Exhibit
 No.

 4.2

 Form of Authorized Participant Agreement

 23.1

 Consent of KPMG LLP, Independent Registered Public Accounting Firm

 31.1

 Chief Executive Officer's Certificate, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

 31.2

 Chief Financial Officer's Certificate, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

 32.1

 Chief Executive Officer's Certificate, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

 32.2

 Chief Financial Officer's Certificate, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

 97.1

 Policy for Recovery of Erroneously Awarded Compensation

 The following financial statements from the
 Assets and Liabilities, (ii) Statements of Operations, (iii) Statements of Changes in Net Assets, and (iv) Notes to the Financial
 Statements.

 101.SCH

 101.CAL

 101.DEF

 101.LAB

 101.PRE

 The cover page from the Trust's Annual