ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iii ITEM 6 - SUPERVISION ............................................................................................................................. iii Highbury Pacific Capital Corp. Brochure Revised, March 20, 2024 5 Description of Advisory Firm Highbury Pacific Capital Corp. (“Highbury Pacific,” “we,” “our,” or “us”) is a privately owned corporation headquartered in Seattle, Washington. Gary Lee, President and principal owner, founded Highbury Pacific in December 2003. Advisory Services Offered Highbury Pacific provides continuous and regular investment supervisory services to a client. Gary Lee works with the client and has the ongoing responsibility to make recommendations based upon the objectives of the client. The client’s assets will be managed by external investment managers (“External Investment Managers”) supervised by Highbury Pacific. Highbury Pacific’s responsibilities include:
• Implementing the investment policy statement set by the client;
• External Investment Manager oversight, advising client on their hiring, termination, and replacement;
• Rebalancing the portfolio to maintain the proper diversification within appropriate ranges and in accordance to the guidelines established in the investment policy statement;
• At times, maintain certain positions when an External Investment Manager rebalances to minimize client transaction costs, capital gains, and taxes;
• Reviewing the portfolio’s investments at least monthly to ensure that policy guidelines continue to be met;
• Monitoring investment returns on both an absolute basis and relative to appropriate benchmarks;
• Managing the investments at reasonable cost being careful not to sacrifice

quality;
• Raising timely concerns and recommending appropriate action if investment objectives are not being met or if policies and guidelines are not being followed;
• Monitoring External Investment Managers to ensure that they conform to the terms of their contracts;
• Providing portfolio performance and manager assessment reports to the client;
• Manage the cash allocation of the portfolio in short-term, highly liquid Treasury Bill investments that are readily convertible to cash and which are subject to relatively small risk of change in value; and
• Purchase foreign currency as required by the client provided such purchase is conducted within the client custody accounts. Highbury Pacific Capital Corp. Brochure Revised, March 20, 2024 6 Tailored Services and Client Imposed Restrictions Highbury Pacific manages client accounts based on the client’s investment strategy, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Highbury Pacific applies the investment strategy for our client, based on the client’s individual circumstances and financial situation and any restrictions the client places on the portfolio, as documented in the client’s Investment Policy Statement. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations may not be suitable if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep Highbury Pacific informed of any changes to their investment objectives or restrictions. Assets Under Management As of 12/31/2023, Highbury Pacific’s non-discretionary assets under management were $274,740,790. Highbury Pacific has limited discretion in the management of assets. We discuss our discretionary authority below under Item 16 - Investment Discretion.