Services Provided The Wrap Fee Program The Adviser is the sponsor and investment adviser of the Adviser’s Wrap Fee Program, which is referred to in this Brochure as the “Program.” A “Wrap Fee” program is one that provides the client with advisory and brokerage execution services, plus account reporting, for one all- inclusive fee. The client is not charged separate fees for the components of the Program except for the fees described below in Item 4 – “Services, Fees and Compensation - Fees - General.” The Program may cost clients more or less than purchasing such services separately. The client’s participation in the Program requires that the client enter into an investment advisory agreement with the Adviser and the appointment of Robotti Securities, LLC (“Robotti BD,” which was, until June 2017, named Robotti & Company, LLC), a broker-dealer affiliated with the Adviser by being under common ownership and control, as the sole introducing broker, and Robotti BD’s clearing broker, as the client’s clearing broker and custodian. Accordingly, Robotti BD will not seek best execution of the client’s transactions through other broker-dealers. Although Robotti BD’s execution procedures are designed to endeavor to obtain the best execution possible for its Wrap Fee accounts (each, a “Wrap Fee Account”), since Robotti BD is the sole broker-dealer for the client’s Wrap Fee Account, there can be no assurance that executions will be as favorable as those that would be obtained if the Adviser were able to place transactions with other broker-dealers. The client should consider whether or not the appointment of Robotti BD as the sole broker may or may not result in certain costs or disadvantages to the client as a result of possibly less favorable executions. The Adviser will consider a delivery versus payment (“DVP”) arrangement under which the client’s assets will be held with its own custodian. Clients are free to consult with the investment adviser representative at the Adviser at any time concerning their portfolios. Robotti BD is a broker-dealer registered under Section 15 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), with the SEC and the Financial Industry Regulatory Authority (“FINRA”). Both Mr. Robert Robotti, who is the principal of the Adviser and of Robotti BD, and certain other employees of the Adviser are separately licensed as registered representatives of Robotti BD. Other Accounts In addition to managing Wrap Fee Accounts, the Adviser offers discretionary and non- discretionary investment management services for separately managed accounts on a non-Wrap Fee basis (“Managed Accounts”) and for customized portfolios of private investment funds formed by its affiliates pursuant to value investing and/or other strategies as discussed in each fund’s offering documents (the “Robotti Funds”). Strategies Offered Prior to the clients' initial investment in the Program, the investment adviser representative will assess the client's current financial situation, investment objectives, risk tolerance and investment time horizon. This evaluation will permit the representative to assess the suitability of the Adviser’s strategies for the client. In the Program, clients will participate in a specific strategy. Each strategy is designed to meet a particular investment goal which the Adviser will determine is suitable to the client's circumstances. The Adviser currently offers two strategies within the Program: Value Equity Strategy and Concentrated Value Strategy (collectively referred to herein as the “Strategies”). Value Equity Strategy Mr. Robert Robotti is the Portfolio Manager for the Adviser’s Value Equity Strategy. The strategy focuses primarily on small- to mid-capitalization (“small cap” and “mid cap”) companies that are overlooked, out-of-favor or misunderstood by the market and which the Portfolio Manager believes are undervalued. While small to mid-cap at time of purchase these companies may, through merger and/or growth, become larger cap. The Adviser believes that holding larger cap companies is a natural evolution of its buy-and-hold approach with respect the Value Equity Strategy. The Portfolio Manager’s investment selection is based on identifying the underlying value within companies. The Portfolio Manager looks for investments where the market price of a security is below what the Portfolio Manager believes is its intrinsic value. Although this strategy is primarily focused on small to mid-cap companies, the Portfolio Manager also seeks to be opportunistic within its core competencies and will consider larger companies when appropriate. The Portfolio Manager is not limited to securities trading in particular markets. The Adviser does not claim to be able to forecast general stock market movements or other macroeconomic trends, but instead maintains a long-term investment horizon in its securities selection. The Adviser will allocate the portfolio assets among various investments taking into consideration the objectives of the strategy. While the Adviser’s Value Equity Strategy focuses primarily on equity securities, such Wrap Fee Accounts may also own one or more of the following: convertible stocks, bonds, warrants, corporate, municipal, or government debt, commercial paper, CDs, mutual funds, exchange traded funds, other investment products, and cash and cash equivalents. Concentrated Value Strategy Mr. Robert Robotti is the Portfolio Manager for the Adviser’s Concentrated Value Strategy. The investment strategy is for investors interested in a concentrated portfolio of equity securities. While small to mid-cap at time of purchase these companies may, through merger and/or growth, become larger cap. The primary emphasis is on equities that are selling for significantly less than their intrinsic value or those that may grow their intrinsic value at above average rates. The strategy is highly concentrated, typically owning between 5 and 10 securities at any given time, but may temporarily hold more securities in special situations. The strategy is focused on long-term capital appreciation. Client Restrictions For either the Value Equity Strategy or the Concentrated Value Strategy, the Adviser requires that it be provided with written discretionary authority from the client so that the Adviser may determine which securities and the amounts of securities that are bought or sold. Any investment policies, guidelines or reasonable restrictions on this discretionary authority are included in the written agreement between each client and the Adviser. Clients may change/amend these policies, guidelines and reasonable restrictions at any time by written notice to the Adviser. To the extent that there are restrictions on securities that may be purchased for the client’s Wrap Fee Account, the client’s Wrap Fee Account may not perform as anticipated. Fees The Adviser charges a “Wrap Fee” for participation in the Program. An asset-based Wrap Fee is calculated using a percentage of the value of the amount invested by the client in the Wrap Fee Account, as set forth in the client’s Wrap Fee Account agreement and described below. The Wrap Fee percentage rate will not change based on increases or decreases in the value of the client’s Wrap Fee Account or additions to or withdrawals from the Wrap Fee Account absent a written agreement between the Adviser and the client. The Wrap Fee will be generally charged as a percentage of assets under management, as shown below: ASSETS ANNUAL FEE $0-$2,499,999 2% on all assets $2.5 mill-$4,999,999 1.75% on all assets $5 mill-$9,999,999 1.50% on all assets $10 mill-$14,999,999 1.25% on all assets $15 mill-$24,999,999 1.10% on all assets $25 mill + 1.00% on all assets Certain Wrap Fee Accounts may be charged a Performance Fee. The specific terms of each Performance Fee may be different for each Account and are detailed in the Advisory Agreement relating to the Wrap Fee Account. Fee Computation. Wrap Fees are generally billed quarterly in an amount equal to one quarter of the contractual annual fee, based on the value of assets under management. Generally, Wrap Fees are debited from the client’s Wrap Fee Account in accordance with the client authorization in the agreement with the Adviser. For the initial quarter in which the Wrap Fee Account is opened, the value of the Wrap Fee Account on the last business day of such quarter is used to calculate the initial Wrap Fee which is paid following the end of such quarter. The initial Wrap Fee is prorated for such portion of the quarter that the Wrap Fee Account was open if opened following the beginning of a quarter. In the Adviser’s discretion, however, when a Wrap Fee Account has been funded in the week preceding a quarter

end, there will be no Wrap Fee charged for that week. For each succeeding quarter, the Wrap Fee is paid to the Adviser in advance based upon the value of the Wrap Fee Account on the last business day of the preceding calendar quarter. When the first quarter’s Wrap Fee is paid in arrears, the first and second quarter Wrap Fees are paid at the same time and the value of the Wrap Fee Account on which the second quarter’s Wrap Fee is calculated includes the amount payable for the first quarter’s Wrap Fee. A pro rata refund to the Client of prepaid Wrap Fees is made if the Wrap Fee Account is closed within a quarter and all of the proceeds or assets are withdrawn by the Client. However, when one or more accounts are closed and the assets thereof are transferred to a new or existing Wrap Fee Account with the same Wrap Fee structure (the Client of such new or existing Account, a “Successor Client”), because the Adviser will continue to manage the assets, a new fee will not be charged nor will a pro rata portion of the Wrap Fee be refunded. This may occur when there is (i) a change in the account strategy, (ii) a change in the account registration or title, (iii) a new account owner(s), (iv) a new trustee of a trust account or (v) a similar circumstance. When the Wrap Fee is paid in advance, no refunds of Wrap Fees are made with respect to partial withdrawals from a Wrap Fee Account and no additional Wrap Fees are charged for additions to a Wrap Fee Account during a quarter. Wrap Fee Accounts – Performance Fees A client may request that a Wrap Fee Accounts be charged a Performance Fee instead of an asset- based fee. The specific terms of each Performance Fee may be different for each Account and will be detailed in the Advisory Agreement relating to the Wrap Fee Account. Account Valuation. For purposes of calculating the client’s Wrap Fee, transactions and the value of cash and securities in the client’s Wrap Fee Account are computed on a trade date basis. Statements from the client’s custodian will typically reflect transactions as of their settlement date (typically two business days following the trade date for U.S. securities transactions) and may value securities and foreign currencies using different valuations from those on which the Wrap Fee has been calculated (see next paragraph). Accordingly, there may be a discrepancy between both the positions in the client’s Wrap Fee Account and the values of securities and cash used to calculate the Wrap Fee and the positions and values set forth on the client’s statement from its custodian. Each security listed on a securities exchange shall be valued at the last quoted sales price during normal trading hours on the primary exchange on which such security is traded on the date for which the value is sought. Each security traded in the over-the-counter market shall be valued at the last quoted sales price during normal trading hours in the over-the-counter market on which such security is traded on the date for which the value is sought. If there was no such trade on such valuation date, whether exchange listed or not, securities held long will be valued at the closing bid price and securities held short will be valued at the closing ask price, as reasonably determined by the Adviser. If, however, in the judgment of the Adviser, any price determined under this paragraph relates to a trade or trades that are deemed not to reflect the fair value of a security, such security’s value will be as reasonably determined by the Adviser. Any other security or asset shall be valued in a manner determined in good faith by the Adviser to reflect its fair value. The Adviser reserves the right to accrue for dividends as of the ex-dividend date of any security until the distribution of such dividend. The value in U.S. Dollars of foreign currencies, or securities or other assets denominated in foreign currencies will be based upon the rate of exchange between the U.S. Dollar and such foreign currency as of the date for which a value is sought unless industry practice is to use a different date; provided, that in any event the Adviser may reasonably determine to use a different date. General. Clients in the Program will not be charged brokerage commissions for the execution of securities trades. All transaction-based costs, with the exception of wire transfer fees, certificate issue fees, special delivery request fees, reorganization fees, SEC exchange fees, stock transfer taxes, margin interest, custodial fees and similar administrative fees, are included within the Wrap Fee negotiated between the client and the Adviser within the parameters of the fee schedule above. A counterparty markup or markdown or dealer’s spread may be built into the price of over-the-counter or exchange traded securities traded within the Wrap Fee Program. The Adviser, however, will pay any incremental costs if a broker-dealer other than Robotti BD is used for a transaction in the client’s Wrap Fee Account. Wrap Account Fees do not include expenses of any mutual funds or ETFs that are included in the client’s portfolio; however, the Adviser may, at its discretion, absorb some of these additional fees. The Adviser may have incentives not to trade in client Wrap Fee Accounts due to its absorption of these charges and expenses. Moreover, a client may incur higher costs by participating in the Wrap Fee program instead of a Managed Account, for example if the client’s portfolio trades infrequently or has a high cash balance. Accordingly, it may be more cost effective to the client for the account to pay brokerage commissions and other fees rather than pay a higher wrap fee. In evaluating the Program, a client should consider the total value of all of the services received for the fee charged, including the amount of trading activity in the client's Wrap Fee Account, the value of custodial, reporting and other services which are provided under the arrangement. The Wrap Fee may or may not exceed the aggregate cost of such services if they were to be provided separately. Generally, Wrap Fee programs are relatively less expensive for actively traded Wrap Fee Accounts but they may result in higher overall costs to the client in Wrap Fee Accounts that experience little trading activity. Wrap Fees vary among our clients and can be negotiable based upon a number of factors, including, but not limited to, the size of the client’s account, the nature of related services provided, the length of the advisory relationship with a client and the nature of the client. The Adviser, in some instances, may compensate current portfolio managers, relationship managers or professional staff of the Adviser or Robotti BD (together, “Affiliated Solicitors”) for client referrals. Accounts referred by Affiliated Solicitors will be subject to the Adviser’s normal fee schedule, subject to any negotiation with the client; the client will not be charged any additional fees or expenses as a result of the referral. An Affiliated Solicitor may earn a larger fee for recommending a Wrap Fee Account with a performance fee or a Robotti Fund, and in some cases, for a Managed Account, than for a Wrap Fee Account subject only to an asset-based management fee. Accordingly, an Affiliated Solicitor has an incentive to recommend such an account or a Robotti Fund over a Wrap Fee Account without a performance fee. The Adviser strives to mitigate this conflict by maintaining compliance policies requiring that client funds be placed only in investments fitting to their financial situation and investment profile. Conflicts relating to management of performance fee accounts and non-performance fee accounts are described in Item 6 – “Portfolio Manager Selection and Evaluation - Performance-Based Fees and Side-By-Side Management” below. The Adviser also offers discretionary investment management services for separately managed accounts on a non-Wrap Fee basis. The Adviser’s strategies for Managed Accounts are the Value Equity Strategy, Select Value Strategy, Single Issue Strategy and Central Asia Opportunity Strategy. The Value Equity Strategy is the same strategy whether it is contracted on a Wrap Fee or Managed Account basis. The Adviser receives a portion of the Wrap Fee for investment advisory services and a portion for arranging for brokerage execution and reporting services for the Wrap Fee Account. The Select Value Strategy is a Managed Account strategy with limits on sector weighting, market capitalization and position weighting. The Single Issue Strategy and Central Asia Opportunity Strategy are Managed Account strategies that invest in shares, warrants, derivatives and/or debt of an individual company. The Select Value Strategy, Single Issue Strategy and Central Asia Opportunity Strategy are not offered on a Wrap Fee basis. Other Compensation Certain of the Adviser’s employees may receive remuneration and/or reimbursement for out- of-pocket expenses in connection with serving as a director on a portfolio company’s Board of Directors.