A. Firm Description We are a disciplined, value-oriented, global investment management firm committed to capital preservation and long-term growth. Since Dalton Investments LLC (an affiliate and a relying adviser of ours) was founded in 1999, our strategies have focused on investments in Asian and Global equity securities, and in 2018, we initiated an Emerging Markets equities strategy. 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 were formed as a Nevada corporation in 2019. Mr. James B. Rosenwald III serves as the Chief Investment Officer and the Chairman of the Board of the Directors of Dalton. Gifford Combs, who was one of the founding members of Dalton Investments LLC (along with Mr. Rosenwald), serves as the Treasurer, the Secretary, and a Director of Dalton’s Board and has portfolio management responsibilities. As of the date of this document, Dalton is indirectly owned 99% by Dalton Investments LLC and 1% by Rosenwald Capital Management, Inc. Rosenwald Capital Management, Inc., for which Mr. Rosenwald serves as the President, is a majority-owner and the sole Managing Member of Dalton Investments LLC. B. Advisory Services We provide discretionary investment advisory services to a select group of domestic and foreign institutional clients including pension plans, charitable organizations and endowments. The investment parameters of each such separately managed account will vary by strategy, client specific guidelines and applicable regulations. In addition, we also provide 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. Certain of our commingled funds are structured as “master-feeders” with a domestic feeder, whereby U.S. taxable investors are admitted as limited partners to a Delaware limited partnership and a foreign feeder, whereby U.S. tax exempt entities and foreigners are admitted as shareholders of a Cayman corporation. The “feeder” funds generally contribute all their assets to a master (Delaware or Cayman Islands) limited partnership which trades and holds investments on behalf of the feeder funds. In addition to the “master-feeders,” Dalton has also established various other structures for its commingled funds, including one that is structured

as a Delaware statutory trust. 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. Part 1A is available on the SEC’s website or by contacting us. As of the date of this document, we also serve as a sub-adviser or delegated investment manager to certain UCITS funds formed in the European Union, which are distributed by the applicable investment company (or their affiliates) to qualified investors subject to each country’s laws and regulations. C. Customized Services Our advisory services will vary by client, but we typically have broad and flexible investment parameters and may 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 pooled investment vehicles which Dalton advises will vary by and within a strategy. The variance is attributable to differing investment strategies, various investment restrictions and tailoring for certain investor limitations or requests. We may 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, we may enter into separate agreements with certain investors in our commingled funds which may provide more favorable terms than those provided to our other investors. D. Wrap Fee Programs None. E. Client Assets As of December 31, 2022, the regulatory assets under management of Dalton and its affiliates were $2,406,511,672 (based on unaudited numbers). We also manage a non-discretionary account, and we may provide certain investment-related consulting services to certain clients.