Chatham Capital Group’s principal office is in Savannah, GA, with a second office on Hilton Head Island, SC. The firm was founded in 1996 by Frederick L. Muller; L. Guy Palmer, II; and Bruce D. Fielitz. Chatham has been a registered investment adviser with the Securities and Exchange Commission since 1996. Chatham has always been 100% owned by its operating principals. The present owners are Frederick R. Muller, Philip B. Palmer, William J. Fielitz, and Jason G. Allen. Frederick L. Muller and Bruce D. Fielitz remain involved in the business as non-owner principals. All principals act as portfolio managers. Chatham manages investment portfolios for clients. As of December 31, 2023, Chatham managed $658,215,299.32 of client assets on a discretionary basis. Most clients are high net worth individuals for whom Chatham manages one or more personal portfolios including trusts and retirement accounts. Chatham also manages some endowment/foundation portfolios, pension and profit-sharing plans, and corporate portfolios. The standard minimum account size for separately-managed portfolios is $1 million. In addition, Chatham also manages private funds. Qualified investors can invest in the private funds with amounts less than $1 million. Each private fund imposes a standard minimum investment amount as specified in the respective offering document. Separately-managed portfolios are tailored to the individual financial needs of each client. Based on a client’s risk tolerance, income requirements, and other factors, Chatham establishes an asset allocation policy spelled out in the client’s Financial Policy Statement and manages the portfolio in line with

that policy. Individual securities are selected based on the purpose they serve in meeting a client’s needs and objectives. Portfolio managers have periodic meetings with clients during the year to stay abreast of any changes that might be relevant to long-term planning, risk tolerance, portfolio diversification, and asset allocation decisions. If a client wishes to impose specific restrictions on Chatham’s management of his or her portfolio (e.g., no tobacco stocks), he or she must inform Chatham of this restriction in advance and a notation to that effect will be made in the client’s Financial Policy Statement. If Chatham tracks (but does not manage or otherwise provide advice on or charge a fee for) other assets of certain clients to be aware of such clients’ overall asset allocation and risk profile, it is able to depict that client’s complete holdings on consolidated reports. Chatham offers its Chatham Small Company investment strategy on a non-discretionary basis through certain Model Programs sponsored by unaffiliated brokers/dealers, whereby Chatham provides these sponsors with trading signals for the model portfolio on a periodic basis. It is the Sponsor’s responsibility to implement trades in participant accounts based on the model portfolio. Model Program participants are not clients of Chatham and Chatham does not trade on behalf of, or have any contact with, participants or their accounts. Either Chatham or a client may terminate an advisory agreement upon written notice at any time. However, if Chatham’s registration as an investment adviser under the Advisers Act is suspended or revoked, the agreement will be terminated automatically.