Anchor Capital was established in 1983 to provide investment management services. Approximately eighty percent (80%) of Anchor Capital was owned by Anchor Capital Holdings LLC, which is a wholly- owned subsidiary of publicly-held Boston Private Financial Holdings, Inc. (ticker: BPFH) (“BPFH”). The remaining approximately 20% of Anchor Capital was owned by the Anchor Capital Non- Managing Members LLC, which is wholly-owned by professionals of Anchor Capital. In April 2018, Anchor completed a buy-out from Boston Private Financial Holdings, (“BPFH”) to assume majority ownership and management control of the firm. Anchor professionals own 70% of the firm and Lincoln Peak Capital, a private investment firm holds 30%. BPFH has an interest that terminates once it has received distributions of an agreed-upon amount from Anchor’s gross revenues. Anchor Capital provides investment management services through three principal divisions: the Institutional Division, (“Institutional”), the Managed Accounts Division, (“MA”), and the Private Client Division, (“PC”). Institutional Division The Institutional Division manages investment advisory accounts on a discretionary basis. Clients retain Anchor Capital to formulate an investment program within a selected investment strategy which is deemed prudent and appropriate to the nature of the account and Anchor Capital's understanding of the client’s investment objectives and risk tolerance. The primary investment strategies offered are Mid Cap Value, Small Cap Value, All Cap Value, Balanced Value, Founders, Founder’s Micro, Value Opportunities and Dividend Income Value. The Institutional Division provides investment management with respect to the following types of securities: exchange-listed securities, over-the-counter securities, corporate debt securities, warrants, commercial paper, bank certificates of deposit, municipal securities, U.S. government securities, foreign issuers, ETFs, options, and mutual funds. Anchor Capital will tailor its investment advisory services on the basis of clients’ needs and objectives and will accept restrictions on investing in certain securities or types of securities. The investment management process includes analysis of each client's objectives, requirements, risk tolerance and portfolio holdings. Managed Accounts Division The Managed Accounts Division participates in Separate Managed Account programs, (SMA or Wrap) acting as a sub-adviser to a number of sponsor firms. The sponsor firms include brokerage firms, public accounting firms, the brokerage divisions of banks and other organizations. Through the SMA programs, clients of the sponsor firms are referred to Anchor Capital for discretionary investment management services. The MA Division discretionary investment management process utilizes a set of model investment portfolios for each strategy that is offered to clients of sponsor firms. The MA Division model portfolio strategies will invest in the following types of securities: exchange-listed securities, over­ 3. the-counter securities, corporate debt securities, municipal securities, U.S. government securities, foreign issuers, ETFs, mutual funds. The MA Division will accept only limited restrictions on investing in certain securities or types of securities. The MA Division does

not provide investment advice on any other basis than those described above. When acting as investment sub-adviser to Unified Managed Accounts (UMA) Programs, the MA Division becomes involved after the client executes a contract with the UMA Program sponsor. The sponsor then recommends or directs which sub-advisers will be used in the client's investment program. When chosen, Anchor Capital provides the sponsor with a model portfolio for each strategy that has been selected by the UMA program sponsor. An updated model portfolio is provided to the sponsor whenever a change is made in the model portfolio. Anchor Capital does not enter trades, receive trade reports, perform or have access to recordkeeping, performance data or reporting or any client reporting. Anchor Capital does not generally interface with the sponsors’ clients. For wrap account arrangements, Anchor Capital is compensated by receiving a portion of the wrap fee that is paid to the sponsor. Anchor Capital has contracts with the following SMA and UMA sponsors:
• Adhesion Wealth Advisor Solutions
• Ameriprise Financial Services, Inc.
• Amplify Investments LLC
• Charles Schwab
• CITI
• Edward D. Jones & Co.
• Envestnet
• Fidelity Managed Account Xchange-FMAX
• Folio Dynamix .
• Janney Montgomery Scott LLC
• Lockwood Advisors, Inc
• LPL Financial Corp.
• Merrill Lynch
• Morgan Stanley Wealth Management
• Natixis Global Asset Management
• Raymond James
• RBC Capital Markets Corp.
• SmartX
• Stifel, Nicolaus & Company, Inc.
• TDA Ameritrade
• UBS Financial Services
• Vestmark
• Wells Fargo Advisors
• Wells Fargo Private Bank Private Client Division The Private Client Division provides financial advice and makes investments based on the individual needs of the client. When goals and objectives based on a client’s particular circumstances are established the PC division utilizes an asset allocation model and manages the client’s portfolio based on that model. PC clients will generally fall into two categories. Wealth Advisory Accounts For each Wealth Advisory client, a portfolio is created generally consisting of one or more of the following: non-affiliated mutual funds, affiliated and/or non-affiliated separate accounts, exchange traded funds, limited partnerships and structured notes or a combination of the aforementioned. 4. 5. Investment Advisory Accounts For each Investment Advisory client, an account is created consisting of one individually managed Anchor Capital strategy. Financial Planning The Advisor also offers comprehensive financial planning services to clients requiring such services. These services may include comprehensive financial planning, fact-finding, goal setting, cash flow and expense budgeting, income sustainability, wealth distribution and plan implementation services. Assets Under Management As of December 31, 2023, Anchor Capital had approximately $2.6 billion of client assets on a discretionary basis. Anchor also provides investment advisory services for UMA clients with $5 billion on a non-discretionary basis; these assets are not part of Anchor’s regulatory assets under management.