A. Description of Firm DRHI is a Los Angeles-based investment management firm incorporated in 2006. DRHI is registered as an investment adviser with the SEC. DRHI’s sole owner is David R. Hansen, CFA, who also serves as President and Chief Investment Officer. Jon Wieman, CFA, serves as DRHI’s Chief Compliance Officer (“CCO”). DRHI offers investment management services on a discretionary basis to individuals, high net worth clients, business entities, retirement plans, and non-profit organizations. DRHI offers to appropriate clients a concentrated investment strategy (the “Focused Strategy”), which focuses on investing in a limited number of long equity positions (typically 10 or fewer common stock positions or depositary receipts (e.g., ADRs)), coupled with options to implement hedges and short positions. The Focused Strategy is generally not tailored to the individual needs of clients; however, the Focused Strategy is only offered to appropriate clients based upon individual needs and investment criteria, and clients may impose reasonable mandates or restrictions in writing to satisfy legal, regulatory, or other special concerns. For example, certain clients have restrictions from investing in specific companies or industries and certain other clients restrict the use of options. In addition to the Focused Strategy, DRHI advises its clients on investment instruments including, but not limited to: common stocks, depositary receipts, fixed income securities, options, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), individual equites, individual bonds, real estate investment trusts (“REITs”), mutual funds, and cash equivalent instruments. Please refer to Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for additional information relating to the investment strategies pursued by DRHI and the associated risks. B. Types of Advisory Services Offered DRHI provides clients with discretionary investment management services on a continuous basis, according to the investment objectives and strategies approved by the client. All accounts are separately managed and maintained with an independent third party custodian for transparency. DRHI generally invests client assets in common stocks, depositary receipts, fixed income securities, options, ETFs, ETNs, REITs, mutual funds, and/or cash equivalent instruments. Depending on each client’s investment objectives and risk tolerance, DRHI may use covered or uncovered put and call options and other derivative instruments in connection with its advisory services and may purchase securities on margin or other forms of leverage. As noted above, DRHI may employ or recommend alternative strategies and investment products, such as the use of leverage, hedging or derivatives. Leverage is the use of debt to finance an activity. For example, leverage is used when one uses margin to buy a security. Hedging occurs when an investment is made in order to reduce the risk of adverse price movements in a security. For example, hedging is used when one takes an offsetting position in a related security, such as an option or other derivative instrument. Derivatives, such as options, may be riskier than other types of investments because they may be more sensitive to changes in economic or market conditions and could result in losses that significantly exceed the original investment. The use of derivatives may not be successful, resulting in investment losses, and the cost of such strategies may reduce investment returns. While leverage or hedging can operate to increase rates of return, it also increases the amount of risk inherent in an investment. Please refer to Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for additional associated risks. C. Important Information Relating to DRHI’s Services 1. Information Received by Each Client To determine if the Focused Strategy or another strategy is appropriate for the client’s risk tolerance, return objectives, time horizon, tax concerns, legal and regulatory factors, liquidity constraints, and unique circumstances, DRHI memorializes the foregoing and any other important or relevant information provided by the client (collectively, the “Information”). At the onset of the client relationship the Information provided by the client, together with any other Information relating to the client’s overall financial circumstances, will be used by DRHI to determine if the Focused Strategy, or another strategy or asset allocation is appropriate for the client. DRHI will not assume any responsibility for the accuracy of the Information provided by the client. DRHI is not obligated to verify any Information received from the client or from the client’s other professional service providers (e.g., attorney, accountant, etc.) and DRHI is expressly authorized to rely on such Information. Under all circumstances, clients are responsible for promptly notifying DRHI in writing of any material changes to the client’s Information. In the event that the client notifies DRHI of changes in the client’s Information, DRHI will review such changes and implement any necessary revisions to the client’s portfolio. 2. Advisory Services, Agreements and Disclosures Prior to engaging DRHI to provide investment advisory services, the client will be required to enter into a written investment advisory agreement with DRHI setting forth the terms and conditions under which DRHI shall render its services (the “Agreement”). In accordance with applicable laws and regulations, DRHI will provide this Brochure (Form ADV Part 2A) and one or more brochure supplements (Form ADV Part 2B) to each client prior to or contemporaneously with the execution of the Agreement. The Agreement between DRHI and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. DRHI’s annual fee shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither DRHI nor the client may assign the Agreement without the prior written consent of the other party, which may be withheld in either party’s sole discretion. Transactions that do not result in a change of actual control or management of DRHI shall not be considered an assignment. DRHI will provide

investment management services but will not provide custodial or other administrative services. At no time will DRHI accept or maintain custody of the client’s funds or securities. The client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer, unless otherwise negotiated, and agreed in writing. DRHI does not provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. DRHI does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, DRHI does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). Clients are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation that we make. Furthermore, if the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. 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 DRHI recommends that a client roll over their retirement plan assets into an account to be managed by DRHI, such a recommendation creates a conflict of interest if DRHI will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, DRHI serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to rollover retirement plan assets to an account managed by DRHI. DRHI may also serve as a sub-adviser to unaffiliated registered investment advisers per the terms and conditions of a written Sub-Advisory Agreement. With respect to its sub-advisory services, the unaffiliated investment advisers that engage DRHI 's sub-advisory services maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for DRHI’s designated investment strategies. If the custodian/broker-dealer is determined by the unaffiliated investment adviser, DRHI will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, the underlying client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by DRHI. Higher transaction costs adversely impact account performance. DRHI has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, DRHI will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when DRHI determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by DRHI will be profitable or equal any specific performance level(s). In limited circumstances, DRHI may engage in a cross-transaction pursuant to which DRHI may effect transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when DRHI believes that such transactions are beneficial to its clients). For all such transactions, neither DRHI nor any affiliate will be acting as a broker, and will not receive any commission or transaction-based compensation. The client may revoke DRHI’s cross- transaction authority at any time upon written notice to DRHI. DRHI has made arrangements to be designated as the investment manager for clients of other investment advisers (the “Sub-Adviser”). In such instances, clients are enrolled in one of DRHI’s investment management strategies or a customized solution through executing the Agreement with DRHI. As investment manager, DRHI provides DRHI’s standard investment management services to a portion of the client’s assets and DRHI has full investment discretion. 3. Restrictions/Guidelines Imposed by Clients The client may impose reasonable guidelines and/or restrictions on investing in specific companies, industries, certain securities or types of securities. For example, certain clients have restrictions from investing in specific companies or industries and certain other clients restrict the use of options. All such guidelines and restrictions must be communicated to DRHI in writing. There may be times when certain restrictions are placed by the client, which prevents DRHI from accepting or continuing to manage the client’s account. DRHI reserves the right to not accept and/or terminate management of the client’s account if DRHI feels that the client imposed restrictions would limit or prevent DRHI from carrying out its investment strategies. D. Assets Under Management As of March 29, 2023, the following represents the amount of client assets under management by DRHI on a discretionary and non-discretionary basis: Type of Account Assets Under Management Discretionary: $190,027,622 Non-Discretionary: $0 Total: $190,027,622 E. Wrap Programs DRHI does not participate in any wrap programs at this time.