About Buckley Capital Advisors, LLC (the “Investment Advisor” or “BCA”) The Investment Advisor is a Florida limited liability company. Zachary Buckley founded Buckley Capital Partners, LP (“Fund”), its general partner, Buckley Capital Management, LLC (“General Partner”), and the Investment Advisor in 2010. BCA’s principal owners are Zachary C. Buckley and Kenneth E. Walsh. Buckley Capital Advisors, LLC is a registered investment adviser with the Securities and Exchange Commission (“SEC”). Advisory Services Offered Fund Management The Investment Advisor advises the Fund, a long short hedge fund focused on equities that employs a deep value and special situations approach to investing. The Fund’s primary objective is to build long-term wealth over a period of time using a value investing methodology. The operations of the Fund are managed through the General Partner and the Investment Advisor. Portfolio Management Services The Investment Advisor provides portfolio management services (“PM Services”), on a discretionary basis, to private individuals and institutional clients, such as pension plans, charitable organizations, trusts, corporations, and partnerships. Since we have discretion over your account, this means you have given us the authority to determine the following without your consent:
• Securities to be bought or sold for your account
• Amount of securities to be bought or sold for your account
• Broker or dealer to be used for a purchase or sale of securities for your account BCA provides investment advisory services to clients at all levels of sophistication and complexity. We are a boutique firm that provides responsive and personalized service. We are large enough to have the resources to effectively manage investment portfolios, and small enough so we have the capacity to ensure that every client will receive the attention they expect and deserve. Our value approach is derived from our identification of overlooked

and under-appreciated equities. We focus on discovering and exploiting differences between the market price for individual companies versus what we believe those companies are worth. (hereafter referred to as the “BCA investment program”) The BCA investment program offers a stock portfolio which includes individual company stocks and may include allocations to fixed income securities, Stocks sold short, options, and exchange-traded funds. The BCA investment program is not a broadly diversified portfolio and may not be suitable for all clients. Our accounts do not involve “investment supervisory services” (i.e. giving the client continuous advice as to the investment of assets on the basis of that client’s overall needs). BCA offers a specific equity investment strategy and does not modify its investment strategy based on an individual client’s financial situation, investment experience or investment objective if it differs from the investment objective of BCA’s strategy. The BCA Investment Program specializes in a long-term investment discipline that attempts to uncover significant discrepancies between stock market prices and underlying company values. This search for value generally leads to smaller and mid-capitalization stocks. For investors with a long-term investment horizon seeking capital appreciation in excess of stock market returns, this strategy may appreciably diversify their scope of investment. Separately Managed Accounts We may also serve as the investment adviser for individual separately managed accounts (SMA). This is a program that allows us to create an investment portfolio that is similar to the BCA Investment Program and manage it within the same investment guidelines and financial parameters as the BCA Investment Program. Wrap Fee Programs The Investment Advisor does not participate in or sponsor a third-party wrap fee program. Client Assets under Management As of December 31, 2023, we manage $133,254,690on a discretionary basis.