Firm Information Dudley & Shanley, Inc. (“Dudley & Shanley” or the “Firm”) is a registered investment adviser with the Securities and Exchange Commission (“SEC”). The Firm was originally organized as a New York limited partnership in 1986 under the name Dudley & Company, LP. The Firm converted to a New York limited liability company in 1997. It converted to a Delaware limited liability company in 2000 and operated in that form until December 31, 2017, when it converted to a Delaware corporation. References in this Brochure to Dudley & Shanley or the Firm include the predecessor limited partnership and limited liability companies unless otherwise stated or the context clearly refers only to the current company. Henry C. Dudley and Frank E. Shanley are the majority shareholders of the Firm. Prior to the Firm converting to a corporation, they were the sole Members and Managers of the Firm, and each was a founding general partner of the predecessor limited partnership. Gregory R. Greene and Christiane C. McNamara are minority shareholders of the Firm. The Firm’s current investment adviser registration with the SEC became effective in July 2011. The Firm was previously registered with the SEC from 1987 until it voluntarily withdrew its registration in 2002 pursuant to an available exemption from the SEC registration requirement. The Firm again became registered with the SEC at the time that exemption was repealed. Advisory Services Dudley & Shanley provides discretionary account management services to separately-managed accounts of individuals (including high net worth individuals) and trusts, estates or charitable institutions (referred to collectively herein as “separately- managed accounts”), as well as to three pooled investment vehicles (sometimes referred to “Fund” or “Funds” and collectively as the “Clients”), none of which is registered with the SEC as an investment company. In 2022, Dudley & Shanley began providing general non-discretionary investment advice and limited authority oversight for a client’s investment managers and the management of the client’s managed assets. Dudley & Shanley does not manage the client’s assets or implement the investment advice. For this client, Dudley & Shanley receives a fixed annual advisory fee (“Advisory Fee”), billed quarterly in arrears. For both the separately-managed accounts and the Funds, the Firm primarily seeks long- term capital appreciation consistent with reasonable risk and the preservation of capital. The Firm seeks to achieve that investment objective through investments in domestic and international common and preferred stocks, convertible securities, options and/or warrants, exchange-traded funds (“ETFs”), closed-end funds and, to a lesser extent, debt instruments. Although uninvested cash may be invested in money market funds, high quality short-term fixed income securities and other money market instruments, the production of current income is not a primary objective of the Firm’s investment strategies. The Firm may also invest client funds in hedge funds, venture capital funds, private equity funds or other investment vehicles managed by other investment managers. With respect to clients who maintain separately-managed accounts with the Firm, while we generally prefer to manage all portfolios in a similar manner, in some cases we tailor our account management services to the individual needs of the client based upon information provided by each client regarding his, her or its investment objectives, financial circumstances, risk tolerance and other relevant information. Clients are urged to update any such information to the extent it becomes inaccurate. Although the

Firm exercises discretionary authority with respect to the investment of client assets, clients may impose reasonable limitations on investments in certain securities, types of securities or industry sectors. As noted above, Dudley & Shanley also manages the accounts of three Funds, Greenfield Fund, L.P., a Delaware limited partnership (“Greenfield”), Canisteo Fund, LLC, a Delaware limited liability company (“Canisteo”), and Greenhouse Associates, LLC, a Delaware limited liability company (“Greenhouse”). The Firm is also the General Partner of Greenfield and the Manager of Canisteo. Henry Dudley and Frank Shanley, as individuals, are the Managers of Greenhouse. Interests in each Fund have been privately offered solely to “accredited investors” who meet other qualifications pursuant to an exemption from registration under the Securities Act of 1933, as amended (the “Securities Act”). The Firm manages the investments of each of the Funds in accordance with each Fund’s investment objectives and investment strategies as set forth in the offering documents relating to such Fund or otherwise communicated to potential investors in a Fund. Investments for the Funds are not made in accordance with the investment objectives of the individual investors in the Funds. Henry Dudley and Frank Shanley individually, and the Firm as an entity, may be deemed to have a conflict of interest with respect to the Funds because of their ownership interests in each Fund. Specifically, such ownership interests could be deemed to give such individuals an incentive to spend more of their time managing the accounts of the Funds because they or the Firm could benefit from any relative outperformance of the Funds’ accounts as compared to the separately-managed accounts. However, all clients’ accounts are normally invested in substantially the same marketable securities selected by Messrs. Dudley, Shanley and Greene as portfolio managers, and in substantially the same percentage weightings within their accounts, although Canisteo and Greenhouse are also invested in some privately-offered, and accordingly less liquid or illiquid, securities due to some differing investment strategies. As a result, the separately-managed accounts and Greenfield experience substantially similar performance, with only relatively minor differences that arise from factors that are unrelated to account management considerations. Such factors might include the timing of additions or withdrawals of funds from a particular client’s account, which may result in investments or liquidations at times different from all other clients, or, as noted above, the individual investment objectives, risk tolerance or other needs of a particular client. The performance of Canisteo and Greenhouse, while similar to the other accounts, is somewhat different due to their different investment strategies. This investment process effectively eliminates the opportunity to manage the Canisteo and Greenhouse Funds’ accounts in any materially different manner from other clients’ accounts. It should be noted that the accounts managed by Gregory Greene, who joined the Firm in January 2018, initially contained some different securities than most of the other accounts at Dudley & Shanley. There has been a gradual, but steady shift in the constituent securities in these accounts so they now are invested in essentially the same securities as the balance of the accounts managed by Dudley & Shanley. Assets Under Management. As of December 31, 2023, the Firm manages client assets of $659,939,975 on a discretionary basis in both the Funds and the separately-managed accounts.