General Information Based in Atlanta, Georgia, Gleneagles Investment Advisors LLC (“GIA,” “we” or “the Firm”) was formed on October 2020 as a Georgia LLC and is a wholly-owned subsidiary of Gleneagles Group, LLC (“Gleneagles Group”). GIA has filed its initial investment adviser registration with the SEC in reliance on the Investment Advisers Act of 1940 (“the Advisers Act”) Rule 203A-2(c) exemption, which allows a firm to register initially with the SEC if it has a reasonable expectation that it would be eligible to register with the SEC within 120 days after the date the firm’s registration with the SEC becomes effective. Accordingly, this Brochure discusses our anticipated operations and services to be provided following the effective date of our SEC registration as an investment adviser. GIA provides investment advisory and asset management services on a non-discretionary basis to certain client families of Gleneagles Capital Management (“GCM”), also a wholly-owned subsidiary of Gleneagles Group that provides non-investment consulting and management services to a limited number of high net worth families, as well to other family offices that have limited personnel. Gleneagles Group is controlled by its principal, David Plyler. Individualized Advisory Services GIA provides non-discretionary investment management services to individual clients regarding single stock portfolios, employee option strategies, options trading, or pooled investment vehicles (“Pooled Investments”), which may include, without limitation, investment companies, hedge funds, funds of funds and private equity funds, and the monitoring and evaluation of the performance of third-party money managers. In addition, GIA offers non-discretionary advisory services with respect to a client’s overall portfolio. In these cases, GIA will work with the client to determine the client’s financial circumstances and investment objectives. Our advisory services are tailored to each client based on their individual needs. Clients may also impose restrictions on investing in certain

securities or types of securities. We work with our clients to develop a continuous investment program (“Investment Policy and Guidelines”) based on an analysis of various factors, including, without limitation, the client’s diversification, liquidity and distribution requirements and other investment objectives, investment restrictions, tax position, other assets not advised by us, social concerns, and risk tolerance. We review the Investment Policy and Guidelines with our clients as needed, but no less frequently than annually. In this review we consider whether amendments or modifications to the Investment Policy and Guidelines may be appropriate. When changes are made to a clients’ Investment Policy and Guidelines at the client’s discretion, we will work with the client to identify positions in the portfolio that may need to be liquidated to bring the portfolio in line with the new or revised Investment Policy and Guidelines. GIA does not provide wrap fees programs. GIA currently manages client assets of approximately $13,190,929 on a discretionary basis and $2,454,579,410 on a non-discretionary basis. These amounts reflect regulatory assets under management (“RAUM”) and were calculated as of December 31, 2023. It is noted that RAUM are assets of securities portfolios over which the adviser provides “continuous and regular supervisory or management services,” regardless of whether they are proprietary assets, assets managed without receiving compensation or assets of foreign clients, all of which an adviser currently may, but is not required to exclude in calculating the “assets under management” for SEC registration purposes. RAUM represents gross assets rather than net assets (AUM). Private Pooled Investment Vehicles GIA serves as investment manager to several privately-offered pooled investment vehicles and funds of funds (collectively, the “Funds”). The Funds include Gleneagles Absolute Return Fund, LLC (“GARF”), Gleneagles Credit Partners I, LLC (“GCPI”), Gleneagles Private Equity Partners I, LLC (“GPEP”) and Gleneagles Credit Partners II, LLC (“GCPII”).