St. James Investment Advisors, LLC. (“St. James”) is an independent, employee-owned investment advisory firm that was established in April of 2016 in the Port Jefferson, New York area. St. James provides investment management services to a wide array of private individuals, trusts and estates, corporations, pension and profit-sharing plans, charitable organizations, retirement plans and other investment advisers. St. James is wholly-owned by its employees. St. James’s principal owner is Brian Mark, Managing Member and Portfolio Manager along with owner John Spicciatie, Executive Director and owner Jennifer Abbonizio, Chief Compliance Officer. The primary goal of St. James's investment strategies is to provide long-term capital appreciation and income for its clients. St. James currently offers seven primary investment strategies for managing client accounts. These strategies are used for each of the different types of advisory services offered by St. James. St James manages the following strategies:
• The St. James High Dividend Yield Portfolio
• The St. James All Cap Equity Portfolio
• The St. James Balanced Portfolio
• The St. James Aggressive Portfolio
• The St. James Growth Portfolio
• The St. James Moderate Portfolio
• The St. James Conservative Portfolio Some clients also request that St. James invest in bonds such as our New York Municipal Bond Portfolio, some of which may have a lower growth objective than our portfolios described above. Our investment advice is primarily limited to equities, ETFs, mutual funds, fixed income, bonds, absolute return investments, alternative investments, and cash investments. Clients whose accounts are invested in our portfolios are permitted to impose reasonable restrictions such as restrictions regarding investments in specific securities, types of securities, industry sectors, tax sensitivities, etc. Sub-Advisory Services St. James acts as a sub-advisor for several investment advisers. At the direction of the primary investment adviser, St. James invests the assets of the adviser’s clients in one and/or several of our portfolios. While St. James maintains investment discretion over the implementation and investment of the St. James portfolio in those client accounts, St. James does not enter into an investment management agreement or generally maintain direct communication with the adviser’s clients. The primary investment adviser is responsible for determining whether the St. James portfolio is suitable for its clients. St. James acts as sub-advisor for several investment advisers within a wrap fee program. However, this wrap fee program is only offered to a legacy client of ours and is not offered to clients other than our sole client remaining in the wrap program. At the direction of the investment adviser, St. James invests the assets of the adviser’s clients in our High Dividend Yield Portfolio. While St. James maintains investment discretion over the implementation and investment of the St. James High Dividend Yield Portfolio in those client accounts, St. James does not enter into an investment management agreement or maintain direct communication with the adviser’s clients. The investment adviser is responsible for determining whether the St. James portfolio is suitable for its clients. St.

James receives an investment management fee directly from the adviser. Direct Advisory Services St. James acts as an investment adviser for individuals and/or families who become direct clients of our firm. St. James enters into an investment management agreement and maintains direct communication with our clients. St. James is responsible for determining whether the St. James portfolio is suitable for our clients. St. James maintains investment discretion over the implementation and investment of the St. James portfolio in our client accounts. 5 | P a g e Model Distribution Services St. James has contractual relationships with investment advisers where St. James provides a model of our portfolios to the advisers. In these relationships, St. James does not have investment discretion over the investment adviser’s client accounts nor does St. James communicate directly with the investment adviser’s clients. In all matters, St. James’ portfolio management services are analytical and advisory only and do not include legal or other professional services. St. James will work with legal, accounting, insurance, or other professional advisors, if requested by the client, to ensure the coordination of all pieces involved in the investment management process. If a client’s account is a pension or other employee benefit plan governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), St. James acknowledges that it is a “fiduciary” to the plan as that term is defined under Section 3(21)(A) under ERISA. However, St. James does not provide legal, accounting or tax advice, or custodial, insurance, recordkeeping, or brokerage services to the plan. When St. James provides investment advice to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. St. James may recommend that a client roll over their retirement assets into an account to be managed by St. James. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement assets into an account to be managed by St. James, such a recommendation creates a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement assets to an account managed by us. As of December 31, 2023, St. James managed $68,605,489 on a discretionary basis and $68,626 on a non-discretionary basis, with another $345,479,029 in assets under advisement for a total of $414,153,144. 6 | P a g e