The Company Quest Investment Management, LLC ("we," "us" or "Quest") is an investment adviser registered with the SEC. 1 We began conducting business in 1985, and we have been registered with the SEC since that time. We are headquartered in Lake Oswego, Oregon. We are entirely owned (directly or indirectly) by our employees. All of our voting equity interests are owned equally by
• Cameron Johnson, our Chief Executive Officer ("CEO") and Chief Compliance Officer ("CCO")
• Kevin Johnson, our Secretary, Treasurer and Senior Vice President through a corporation directly and equally owned by them called Quest Investment Management Holdings, Inc. In February of 2016, we instituted a program under which six additional employees own our non-voting limited liability company equity interests. Advisory Services We provide traditional discretionary portfolio management to institutional and individual clients. We generally invest our clients' assets in growth stocks, intermediate- and short-term fixed income securities, or a blend of those investments. However, we may use a wide range of different securities to construct client portfolios. Our investment strategies are more fully described below in Item 8. We currently serve as sub-adviser to other firms to assist in the investment of those firms' clients' assets. We also provide investment advisory services to certain real estate pooled trusts and perform related property management services for the properties held by those trusts. Direct Portfolio Management We provide continuous full-time asset management. We use a flexible "fully managed" investment strategy which enables us to vary assets with market trends. We use fundamental, thematic and economic analysis, meaning that we begin our investment process by evaluation of a security in an attempt to measure its intrinsic value, by examining related economic, financial and other qualitative and quantitative factors. We also consider global events including economic, political and social cycles and trends. This process helps us to make asset allocation decisions with respect to long- or short-term maturity debt, cash 1 Registration as an investment adviser does not imply a certain level of skill or training. Form ADV Part 2A – Disclosure Brochure 5 February 29, 2024 equivalents and equity positions. We generally limit investing client assets to the following:
• exchange-listed securities
• securities traded over-the-counter
• corporate debt securities (other than commercial paper)
• commercial paper
• certificates of deposit
• municipal securities
• mutual funds
• exchange-traded funds ("ETFs")
• U.S. government securities
• participation in pooled trusts investing in real estate These investments carry different risks. As a result, we carefully consider an investment's risk profile and only invest in a given instrument when we feel it is suitable for the client and consistent with the client's investment objectives, risk tolerance and liquidity needs. Tailored Advisory Services for Direct Portfolio Management Our investment advice is based on your needs. Institutional clients generally provide us with an investment policy to follow, which we regularly review. We invest your assets in accordance with your investment policy. For our individual clients, we establish investment objectives based on your particular circumstances through personal discussions. Then, we develop your individual investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine your individual objectives, time horizons, risk tolerance and liquidity needs. As appropriate, we also discuss your prior

investment history, tax situation, and family composition and background. Market volatility can sometimes change asset values. When this happens, the values of your assets may become somewhat inconsistent with your desired asset allocation objectives, as stated in your investment policy. If we think it is appropriate, we will rebalance your portfolio to match your allocation objectives. Rebalancing your portfolio can lead to additional trading costs. All of our clients may impose restrictions on investing in certain securities, types of securities, industries or sectors. You must advise us of any such restrictions in writing. Form ADV Part 2A – Disclosure Brochure 6 February 29, 2024 Sub-adviser Services We currently serve as sub-adviser to Bivium Capital. This firm has appointed us to manage a portion of their clients' assets, and those clients have agreed to have us provide them with advisory services. This group has established investment policies for this client. We generally consider individual clients for whom we serve as sub-adviser to be our clients for all purposes, including bonding insurance, suitability and fiduciary liability. Real Estate Pooled Trusts We advise seven separate real estate pooled trusts, called the Quest Group Trusts (the "QGTs"). The QGTs are numbered 1 through 7 and invest only in to-be-built commercial income producing real estate. The QGTs are intended to meet the requirements of IRS Revenue Ruling 81-100, 1981-1 C.B. 326 and Section 401(a)(24) of the Internal Revenue Code. The QGTs were established to provide participating investors (individual retirement trusts) exempt from federal income tax under Section 501(a) of the Internal Revenue Code with a medium for pooling their funds for investment by the QGT in equity real estate. Each QGT takes title to a property upon completion and delivery of a local government's certificate of occupancy. The investment objectives of each QGT include (a) an annual net cash payout to investors competitive with other income-producing commercial real estate; and/or (b) capital appreciation of the properties due to location, cash flow, tenant mix and maintenance. Investments in real estate are confined to the Portland, Oregon metropolitan area. MAI (Member of Appraisal Institute) designated appraisers conduct annual independent appraisals of the properties. Our services to the QGTs include supervision of daily activities, monthly financial analysis and review of each QGT, collection of income, payment of expenses, supervision of property management, timely maintenance, tenant relations, regular reports to investors, preparation of pro-forma budgets, and analysis and recommendations to the QGTs' trustee. If an opportunity for investment in the QGTs becomes available, we may propose that tax-qualified clients participate in the QGTs. However, we do not use our discretion to invest client assets in the QGTs. U.S. Bank, N.A. serves as trustee and custodian for each of the seven QGTs, and the QGTs are audited annually by KPMG LLP. Property Management Our property management department provides the industry standard management functions for each property owned by the QGTs. Our property management department is operated on a nonprofit basis and does not manage any properties other than those owned by the QGTs. Form ADV Part 2A – Disclosure Brochure 7 February 29, 2024 Any property management fees collected in excess of expenses directly incurred by the department, less a prudent reserve, are distributed back to the QGTs. We generate separate financial statements for the department. Assets Under Management As of February 29, 2024 we had $1.5 billion in client assets under management. We manage all client assets on a discretionary basis.