St. James Investment Company was founded in 1999. Our owners are Robert J. Mark, through his entity Sibelius Holdings, LLC, and Larry J. Redell. As of December 31, 2023, St. James managed $661.9 million on a discretionary basis. We also distribute our Select Value model, under which $220.5 million was managed by other advisers. St. James does not provide regular supervisory or management services on a non-discretionary basis. St. James is an independent, fee-only, registered investment advisory firm providing portfolio management to private individuals, trusts and estates, registered investment companies (a mutual fund and an ETF), pension, profit sharing and other retirement plans, charitable organizations, and foundations. We manage equity portfolios. Each client’s portfolio is managed based on the St. James composite investment strategy they select. We are an asset manager utilizing a value investment strategy which is implemented through the use of equity securities, as well as open-end mutual funds and Exchange Traded Funds (“ETFs”). St. James accepts reasonable investment restrictions from clients, which are documented in the client files. In addition, St. James provides sub-advised portfolio management services for a number of independent registered investment advisers and investment companies as well as distributes a model of investment portfolio for use by other advisers. In all matters, St. James’ portfolio management services are analytical and advisory only and do not include legal or other professional services. St. James will work with legal, accounting, insurance or other professional advisors, if requested by the client, to ensure the coordination of all pieces involved in the investment management process, however, St. James is strictly a portfolio manager only and is not responsible for any of the client’s outside service providers. If a client’s account is a pension or other employee benefit plan governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), St. James acknowledges that it is a “fiduciary” to the plan as that term is defined under Section 3(21)(A) under ERISA.

However, St. James does not provide legal, accounting or tax advice, or custodial, insurance, recordkeeping, or brokerage services to the plan. The client is responsible for maintaining the plan in compliance with requirements applicable to tax- qualified plans under the Internal Revenue Code including, where applicable, receipt of a favorable determination letter. St. James does not accept responsibility for the administration of the plan including, without limitation, timely transmission of required contributions, filing required governmental reports, preparing or providing notices and communications to the plan’s participants as required by applicable law and regulation, or notifying you that any such notices or communications are required. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.