Stonehurst Management LLC (“Stonehurst “) is an SEC-registered investment adviser with its principal place of business located in New York City. We are organized as a limited liability company under the laws of the State of New York and we have been providing investment advisory services since December 2002. We provide investment advice to individuals, families, trusts, estates, charitable organizations, endowments, and business entities. Owen King is the owner of the firm. The following paragraphs describe our services and fees. As used in this brochure, the words “we”, “our” and “us” refer to Stonehurst Management and the words “you”, “your” and “client” refer to you as either a client or prospective client of our firm. Our investment advice begins with you, the client. We seek to understand your specific circumstances, your current and future needs and goals, your experience and comfort with different types of investments and risks, and the time period over which you plan to invest. With this information, we develop appropriate asset allocations for your portfolio across traditional and alternative asset classes, consistent with modern portfolio theory and the best industry practices. This is a critical step in the investment process as it drives your portfolio's long-term risk characteristics and potential rewards. Once the strategic allocation for your portfolio is formulated, we determine the appropriate mix of strategies within each asset class to ensure proper diversification using both actively-managed and index-related styles, also considering any investment preferences you may have. As a fee- only independent adviser, our investment recommendations are not limited to any specific product or service offered by any company and will generally include (although not limited to) advice regarding the following securities: mutual fund shares, exchange-traded funds, publicly held securities (including stocks and bonds), municipal securities, United States government securities, and interests in partnerships as we may consider appropriate. Because all investments involve certain degrees of risk, they will only be implemented or recommended when consistent with your stated investment objectives, tolerance for risk, liquidity needs, and suitability. Account supervision is guided by your stated objectives (examples of such objectives include long-term capital appreciation, income with growth, growth, or income, but may also include other highly specific

objectives as desired by the client), as well as tax considerations. We monitor investment portfolios on an ongoing basis and rebalance portfolios as determined by changes in market conditions, outlooks, and/or changes in your specific financial circumstances. We may also give specific advice on such financial goals and circumstances as retirement, education, and large capital purchases, as well as addressing the particular needs of clients employed in specific areas such as private equity, financial services, and independent businesses, at no additional charge to our investment advisory clients (fees are discussed in section 2, which follows). Stonehurst Management LLC – Part 2 of Form ADV Page 4 Wrap Fee Program Stonehurst does not engage in a wrap free program. Assets Under Management We manage advisory accounts on a discretionary basis. In certain circumstances, we will hold some assets on a non-discretionary basis as a service to our clients. We maintained $20,890,241 under discretionary management as of December 31, 2023. When our firm has discretion we are able to make changes in your investments without your prior approval. When we do not have discretion, we must receive your approval prior to making changes in your investments. Whether accounts are discretionary or non- discretionary, we cannot remove money or securities from your accounts without your specific written approval (with your written approval, we are allowed to debit our investment advisory fees from your accounts). (Fees are discussed in section 2, which follows.) Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Clients may impose restrictions on the types of securities we use in implementing their portfolios. We do not participate in wrap fee programs. Our advice may include formation of an investment policy statement, as needed, asset allocation advice, portfolio management services, and investment performance monitoring. In some cases, we may provide asset allocation advice on accounts not held at our recommended custodian, Charles Schwab (“Schwab”). In such cases, we will monitor these accounts on a periodic basis and provide you recommendations, as necessary.