A. Description Lorne Steinberg Wealth Management Inc. (“LSWM”) is organized as a corporation under the laws of Canada. LSWM provides discretionary investment management (and investment sub-advisory) services to individuals, corporations and non-profit organizations. Client funds are advised or sub-advised through both separately managed accounts and pooled funds, depending on the circumstances. LSWM is owned 100% by Lorne Steinberg and was formed on April 6, 2009. In the U.S., LSWM is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”). In Canada, LSWM is registered as a portfolio manager, investment fund manager, exempt market dealer, and financial planner. In this regard, LSWM is registered in Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Nunavut, Ontario, Prince Edward Island, Quebec, Saskatchewan, and Yukon. B. Advisory Services As further described below, LSWM currently offers the following three types of investment advisory services: (1) separately managed account services, including through sub-advisory arrangements, (2) pooled funds, which are not currently available for direct investment by U.S. investors, and (3) financial planning services. Our approach to investing is value-based. Traditional Investment Advisory Services LSWM serves as a traditional investment adviser to separately managed accounts. In this regard, its separately managed accounts generally follow the same portfolio construction process as each other. However, in its sole discretion, LSWM may also customize an investment portfolio in accordance with a client’s risk tolerance and investment objectives, including reasonable restrictions on investing in certain securities or types. For example, clients may specify in their “Investment Policy Statement,” which outlines each clients’ current situation (income, tax levels and risk tolerance), that investments in any particular stock or industry should not exceed a specified percentage of the value of the portfolio and/or restrict or prohibit transactions in the securities of a specific industry or issuer, including socially responsible investment restrictions. Once we construct an investment portfolio, we monitor the performance of each client’s portfolio on an ongoing basis and rebalance the portfolio as deemed required by changes in market conditions. LSWM obtains discretionary authority from clients in order to select investments and execute transactions without permission from the client prior to each transaction. LSWM generally limits its investment advice to equities, fixed income and its own pooled funds. LSWM may make other investments as well to help diversify holdings as deemed appropriate. Quarterly communication assures that clients are kept abreast of their investments, as well as the LSWM’s investment outlook and strategy. Fund Management Services LSWM acts as the adviser to three Canadian-based funds, namely the Steinberg High Yield Fund, Steinberg Global Value Equity Fund and Steinberg Canadian Dividend Growth Fund. While these funds are not currently open for direct investment by U.S. investors, LSWM utilizes the investment strategy for the Steinberg Global Value Equity Fund and the Steinberg Canadian Dividend Growth Fund in managing separately managed accounts for U.S. clients. Below is a brief description of these three Canadian funds. Steinberg Global Value Equity Fund The Steinberg Global Value Equity Fund seeks to provide long-term capital appreciation by investing in public companies that meet our strict investment criteria, and whose share price is trading at a discount to its intrinsic value. LSWM’s research efforts for the fund are driven by the following principles:
• Bottom-up fundamental equity research
• Invest only in companies that are financially sound and generate free cash flow
• Focus on strong management and good

corporate governance
• Diversify broadly across issuers and industries Steinberg High Yield Fund The Steinberg High Yield Fund seeks to maximize total return by investing primarily in higher yielding corporate bonds and other securities. Our approach to the high yield market is consistent with the conservative, value–based investment philosophy that defines LSWM. LSWM’s research efforts for the fund are driven by the following principles:
• Bottom-up fundamental credit research
• Focus on higher quality, non-investment grade bonds
• Total return, not just income
• Diversify broadly across issuers and industries Steinberg Canadian Dividend Growth Fund The Steinberg Canadian Dividend Growth Fund seeks to achieve long-term total returns consisting of long-term capital appreciation, and regular dividend income by investing in common and preferred shares of major Canadian companies. LSWM’s research efforts for the fund are driven by the following principles:
• Bottom-up fundamental equity research
• Focus on high quality Canadian dividend paying companies
• Focus on dependable dividend income with a history of growing dividend yields
• Diversify broadly across issuers and industries LSWM may serve as the investment adviser to one or more U.S. private funds in the future. This Brochure should not be considered an offering document for any funds, and investors should refer to a specific fund’s offering memorandum or organizational documents for a complete description of that fund, including its types of investments and strategies, risks, conflicts of interest, fees and expenses. We tailor our investment advisory services for a fund to such fund’s overall investment program, and not to the needs of any underlying investor therein. The governing documents for the fund and/or the investment advisory agreement, if applicable, govern LSWM’s advisory services provided to a fund. The governing documents of any U.S. private fund will likely provide that the fund may be dissolved upon LSWM’s dissolution or the investment adviser’s resignation or withdrawal from the fund. Any U.S. private funds will likely be designed to be exempt from registration as an investment company under either Section 3(c)(1) or 3(c)(7) of the Investment Company Act of 1940, as amended (the “Company Act”). Financial Services LSWM offers various financial planning services to its separately managed account clients free of charge upon opening an account. Allocation Policy LSWM seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of LSWM’s economic, investment or other financial interests. To meet its fiduciary obligations, LSWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain clients. Accordingly, LSWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. C. Client Tailored Services and Client Imposed Restrictions In connection with its traditional investment advisory services, LSWM offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s Investment Policy Statement. Clients may, for instance, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent LSWM from properly servicing the client’s account, or if the restrictions would require LSWM to deviate from its standard suite of services, LSWM reserves the right to end the relationship. D. Assets Under Management LSWM has the following assets under management: Discretionary Amounts Non-discretionary Amounts Date Calculated $592,705,945 $0 December 31, 2023