A. Firm Description We are a disciplined, value-oriented, global investment management firm committed to capital preservation and long-term growth. Since our founding, our strategies have focused on investments in global securities (e.g., debt, preferred and common equity, convertibles, liquidation units), real estate, pooled investment funds, venture capital investments, and private offerings. We generally look for less crowded areas of the markets with the objective of generating positive long-term returns on an absolute and relative basis. We formed RCM as a New York corporation in 1984 and Rising Sun as an exempted limited company in the Cayman Islands in 2019. Mr. James B. Rosenwald III is the President of RCM. The Rosenwald Family Trust owns 100% of RCM. RCM owns the majority of Rising Sun. B. Advisory Services RCM provides discretionary investment advisory services to a select group of domestic and foreign institutional clients including insurance companies and charitable organizations. The investment parameters of each such separately managed account will vary by strategy, client specific guidelines and applicable regulations. In addition, RCM also provides discretionary investment advisory services to commingled funds. The investors for the funds include domestic and foreign institutional investors, high net-worth family offices and individuals, and directly or indirectly include Mr. Rosenwald, members of his extended family and trusts or other entities established for any of the foregoing persons' benefit. As of the date of this document, Rising Sun serves as an investment adviser to the Nippon Active Value Fund plc (“NAVF”) listed on the London Stock Exchange and one privately-offered, pooled investment vehicle, which is managed by Dalton Investments, Inc. Rising Sun also may serve as an investment adviser for other pooled investment vehicle(s) in the future. Commingled funds are offered only by private placement and are limited to accredited and qualified investors as defined by the SEC. We have included in our ADV Part 1A the list of

our private funds managed on a discretionary basis. In addition to the fund disclosures, Part 1A includes information about our affiliated entities that are the general partners to funds we manage. Part 1A is available on the SEC’s website or by contacting us. C. Customized Services Our advisory services will vary by client, but we typically have broad and flexible investment parameters and are generally permitted to make investments outside of the core strategies when the opportunity arises and the investment fits our investment philosophy. For example, certain client accounts and funds may utilize margin borrowing and other forms of leverage. Our client mandates may permit us to invest in long and short positions as well as certain illiquid securities and jurisdictions. Investment parameters and limitations are described in each client’s respective advisory contract. Similarly, the holdings for the private funds will vary by and within a strategy. This is attributable to differing investment strategies, various investment restrictions and tailoring for certain investor limitations or requests. We will emphasize or deemphasize, add, develop or eliminate different investments and strategies from time to time depending upon, among other factors, our view of new market opportunities or regulatory changes. To the extent that our clients are commingled funds, we provide advisory services to the commingled funds and not to the individual investors in such funds. In addition, although we have not done so in the past, we reserve the right to enter into separate agreements with certain investors in our commingled funds which may provide more favorable terms than those provided to our other investors, including more favorable fee terms. D. Wrap Fee Programs None. E. Client Assets As of December 31, 2023, RCM’s net assets under management were $168,497,597 regulatory assets (based on unaudited numbers, and excluding the account for which RCM advises exclusively on real estate assets). RCM does not manage any non-discretionary accounts.