A Our Firm. Rutherford Investment Management is an Oregon limited liability company registered as an investment advisor with the SEC. Our principal place of business is located in Portland, Oregon. William D. Rutherford is the sole owner and President of the firm. Mr. Rutherford, Adam Brzeczek, James M. Cook (formerly Ulatowski), and Joan Lamb are the sole investment advisor representatives of the firm. The information contained in this Brochure describes our investment advisory services, practices, and fees. Please refer to the description of our investment advisory services listed below for information on how we tailor our services to the needs of our clients. As used throughout this firm brochure, the words “we,” “our,” “firm,” “RIM” and “us” refer to Rutherford Investment Management, and the words “you,” “your,” and “Client” refer to you as either a client or prospective client of our firm. Prior to forming an investment advisor-client relationship, we typically offer prospective clients a complimentary general consultation to discuss the nature of our services and the Client’s financial status and objectives to determine the possibility of a potential advisory relationship. Investment advisory services and an advisor-client relationship begin only after the prospective client and RIM formalize their relationship in a written advisory agreement. B Our Services. Discretionary Portfolio Management We offer ongoing portfolio management and investment advisory services that are tailored to the unique investment objectives, financial goal and circumstances, risk tolerance, and investment time horizon of each Client. Pursuant to a written investment advisory agreement entered into with each Client, we will continuously manage your investment portfolio on a discretionary basis. Stated plainly, this means you have granted us the authority to do all of the following within your account, without obtaining your consent prior to each transaction:
• To buy and sell securities in your account, including the determination of the timing of such transactions and amount and type of securities to be bought or sold;
• To arrange for delivery and payment in connection with all such transactions;
• To select, retain and terminate sub-advisors available through the qualified custodian’s brokerage platform to manage all or a portion of your account; and
• To act on your behalf in all other matters necessary or incidental to the handling of your account. You shall have the ability to impose reasonable restrictions on our management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be with respect to a specific company’s securities, industry sector, asset class, or any other restriction you request. All such requests must be provided to us in writing. Rutherford Investment Management - Form ADV Part 2A - Page 2 Please see Item 8 of this Brochure for a description of the types of investments we generally recommend for Client accounts. Your account can be managed in a tax aware manner; however, we do not provide tax advice or tax management services. We can refer you to a tax professional at your request. We do not receive compensation of any kind in connection with such referrals. The decision to retain any referred third party professionals, including attorneys, accountants, tax professionals and others is a matter solely within the Client’s discretion and our firm shall not be responsible for the acts or omissions of any third party professionals. Investment Manager to a Collective Investment Trust Fund RIM provides discretionary portfolio management services to certain collective investment funds established under the Rutherford Collective Investment Trust (“Rutherford CIT”), a collective investment trust maintained by Alta Trust that is designed to serve the investment needs of tax qualified employer sponsored retirement plans (“Plans”). Alta Trust is a South Dakota chartered trust company that acts as the “Trustee” of the Rutherford CIT. Collective investment trusts, including the Rutherford CIT, are excluded from the definition of a registered security and an investment company under various securities laws, but are subject to the Office of the Comptroller of the Currency (OCC) Regulation 12 CFR 9.18, state banking rules and/or the Employment Retirement Income Security Act of 1974, as amended (“ERISA”). This Rutherford CIT only accept assets of defined contribution plans that are part of a pension, profit sharing, stock bonus or other employee benefit plan of an employer for the exclusive benefit of employees or their beneficiaries and is (i) exempt from federal income taxes under Section 501 (a) of the code, by reason of qualifying under Section 401(a) or 414(d) of the code or (ii) is part of an eligible deferred compensation plan maintained by a state or local governmental

unit under Section 457(b) of the Code (“Section 457 Plan”), which is either exempt from or not subject to income taxation. RIM serves as a fiduciary and “Investment Manager” (as that term is defined in Section 3(38) of ERISA) with respect to the Rutherford CIT and any Plans investing in its underlying funds. At present, RIM serves as the Investment Manager to the Rutherford Multi-Cap Growth Fund (“Fund”), a collective investment fund established under the Rutherford CIT. The Fund is not a mutual fund registered under the Investment Company Act of 1940, as amended, (“1940 Act”) or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to a collective investment fund are different from those applicable to a mutual fund registered under the 1940 Act. The Fund’s units are not securities registered under the Securities Act of 1933, as amended, or applicable securities laws of any state or other jurisdiction. In addition, the Fund’s units are not publicly traded on any exchange or over-the-counter market and, as a result, the unit values are not available for publication in newspapers. All of the assets of the Fund are invested according to the Fund’s stated investment objectives, guidelines, and restrictions. The Fund’s investment objective is to seek capital appreciation for investors with long-term investment goals. The Fund invests primarily but not exclusively in U.S. equities across multiple market capitalization weightings. RIM identifies what it believes Rutherford Investment Management - Form ADV Part 2A - Page 3 to be the most attractive market sectors and subsequently invests the Fund’s assets in preferred equities in each such market sector. Equities are selected based on their expected growth prospects. Growing sectors are over weighted. RIM maintains the right to allocate to cash or fixed income investments at its discretion in times of market turmoil. The Rutherford CIT’s Declaration of Trust dated November 3, 2017, the Fund’s Employee Benefit Summary, and other important disclosures regarding the Fund’s investment objective, strategies, risks, fees and expenses (collectively, “Disclosure Information”) should be read in conjunction with the above information when considering an investment in the Fund. A copy of the Fund’s Disclosure Information may be obtained by contacting RIM at the telephone number or e-mail address found on the cover page of this Brochure or Alta Trust at [email protected]. Additional information regarding the Fund is also available at http://www.trustalta.com/rutherford. C Tailored Advisory Services; Ongoing Management. Prior to implementing an investment program, and periodically thereafter, we will meet and confer with you in person, electronically, or telephonically to discuss and document your investment goals and objectives. All of our investment decisions are made in accordance with investment guidelines that fit with the Client’s investment needs and objectives. You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change and we are entitled to rely on all investor profile information you provide to us. If you decide to implement an investment management strategy with us, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, not with us. We generally recommend using Charles Schwab & Co., Inc. (“Charles Schwab”) as your custodian. However, you have the right to use another custodian instead of Charles Schwab to handle your account. Our brokerage practices are described in further detail in Item 12 of this Brochure. In all cases, you will enter into a separate custodial agreement with the custodian of your choice. The custodian will effect transactions, deliver securities and make payments. You will receive, at least quarterly, a statement containing a description of all the activity in your account from the custodian. This statement lists the total value at the start of the quarter, itemizes all transaction activity during the quarter, and lists the types, amounts, and total value of securities held as of the end of the quarter. We will be copied on these statements. Your statement may be in either printed or electronic form based upon your preferences. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash at times in such amounts as you desire, to vote proxies, and to receive transaction confirmations. D No Wrap Fee Program. We do not participate in or sponsor any wrap fee programs. E Our Assets Under Management. As of December 31, 2023, we managed approximately $173,438,267 of Client assets on a discretionary basis and approximately $0 of Client assets on a non-discretionary basis. Rutherford Investment Management - Form ADV Part 2A - Page 4