General Description of the Adviser The Adviser is a New York limited liability company registered as an investment adviser with the SEC. For purposes of this brochure, the “Adviser” or “13D” includes (where the context permits) any affiliated general partner and other affiliates that provides advisory services to and/or receives advisory fees from the 13D Funds (as defined below). Such affiliates may or may not be under common control with 13D but possess a substantial identity of personnel and/or equity owners with 13D. These affiliates may be formed for tax, regulatory or other purposes in connection with the organization of a fund or may serve as general partners of a fund. The Adviser provides investment advisory services on a discretionary basis to investment vehicles through its specialization in a non-diversified domestic, long-only equity strategy that focuses on shareholder activism. The Adviser’s flagship fund, the 13D Activist Fund (the “40 Act Fund”), was founded in 2011 as an open-end investment company registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). 13D also provides investment management services to privately offered commingled investment funds intended for sophisticated investors and institutional investors which are exempt from registration under the 1940 Act and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”), (the “Private Funds” and together with the 40 Act Fund, the “13D Funds” or “Funds”). In providing investment advisory services, the Adviser seeks to achieve the capital appreciation by investing primarily in common stocks of U.S. companies of any market capitalization that are the target of shareholder activism. The Adviser defines an activist as an investor who holds or takes a long position in a company’s shares and either (A) has a history of activist investing and/or (B) has publicly disclosed a catalyst for change such as seeking board seats, improving operations and/or corporate governance practices, spinning-off an operating division or selling a significant amount of company assets (such an investor being referred to herein as an “activist”). The Adviser reviews all material activist situations and makes investment decisions based on its knowledge of the activist investor involved, the industry, the shareholder base, the activist’s average cost, its strategy and the Adviser’s determination of the chance of success and potential impact on share price. Environmental, social and governance (“ESG”) is a central part of 13D Fund’s investment process. The Adviser only selects situations where the shareholder will be improving or participating in corporate governance or otherwise influencing management. Accordingly, approximately 75% of the Fund’s portfolio positions has historically had a shareholder representative on the board of directors who advocates for best-in-class corporate governance practices and a shareholder focused mentality. The Adviser does not only select companies with good corporate governance, because it believes there is more of a social and economic benefit in identifying poor corporate governance companies and supporting a transition to good corporate governance. Implementing best corporate governance practices can range from completely changing corporate culture to replacing entrenched, conflicted and self-dealing management teams. It is the Adviser’s experience that it is the governance element that could lead to environmental and social improvements in the business practices of the Fund’s portfolio companies. Every portfolio position contains an engaged investor and most contain a shareholder representative on the board of directors. We believe these individuals are in

a unique position to not only create economic value but also drive positive ESG improvement. We refer to this as Active ESG (“AESG”) investing. The Adviser uses the following selection guidelines to create and manage the Fund’s investment portfolio: Selecting Investment Universe: Identify companies where an activist investor is involved. Weighting Investments: Different weights will be given to each investment depending on the (i) type of activist intent stated, (ii) the activist involved, (iii) the industry involved, and (iv) the Adviser’s determination as to the chance of activist success. Exiting Investments: Exiting an investment is an integral part of the investment strategy. The Adviser will exit a position when the activist indicates that it is exiting the investment, the activist becomes a passive investor, or in the Adviser’s opinion, the activist catalyst has changed or weakened. While these guidelines will define the trading horizon, this horizon may change based on other events. For example, an early exit may be warranted after the activist has attained most of its goals, there has been a sufficient return on the investment, and there are other activist opportunities that the Adviser believes offer a better return. The Fund is non-diversified, which means that it may invest in fewer issuers than a diversified fund. The Adviser may engage in frequent buying and selling of securities in managing the Fund’s portfolio. This brochure, including any brochure supplement, is intended for 13D’s direct advisory clients. Investors in 13D Funds (“Investors”) are not deemed to be 13D clients but are entitled to certain rights and benefits under in the applicable Private Placement Memorandum, Limited Partnership Agreement, Investment Management Agreement, Registration Statement, Offering Documents, or other applicable constituent fund documents (the “Client Constituent Documents”), and may therefore refer to this brochure, or any other brochure supplement, for informational purposes only. Additional information about 13D’s products, structure and directors is available online at www.13dactivistfund.com (also where 13dmanagement.com webpage is directed) and is provided on Part 1 of the Adviser’s Form ADV which is available online at www.adviserinfo.sec.gov. The principal owner of the Adviser and portfolio manager of the 13D Funds is Kenneth Squire (“Managing Member”). Mr. Squire founded 13D in 2011. Mr. Squire is also the founder and principal of Investor Communications Network LLC, which operates 13D Monitor, an institutional research firm specializing in corporate governance and shareholder activism. Mr. Squire is CNBC’s On-Air Contributor for Shareholder Activism, and his Activist Spotlight column can be read on CNBC.com. The Activist Spotlight was featured weekly in Barron’s from 2007 to 2020. In 2010, Squire created the annual Active- Passive Investor Summit, to bring the activist and passive investment worlds together to discuss topics in corporate governance. Prior to founding 13D Monitor in 2006, Mr. Squire was a private equity investor as a principal of LSC Investors and Crown Capital Group, where he worked on various investments in public and private companies, starting in 1997. Previously, Mr. Squire was an associate in the Corporate and Securities Department at Weil, Gotshal & Manges, LLP in their New York law office from 1992 to 1997. Mr. Squire holds a B.S. with a concentration in finance from New York University’s Stern School and a J.D. from New York University School of Law where he was an editor of NYU Law Review. As of December 31, 2023, the Adviser managed approximately $176,029,176 of regulatory assets under management all of which is managed on a discretionary basis.