A. Background Gordon Asset Management LLC (“Gordon”) is a registered investment adviser and asset manager specializing in portfolio management for high net worth investors and private funds, including funds-of-funds. The firm has been offering investment advisory services since 1997. It is owned and managed by Arthur S. Gordon and David L. Gordon. As of December 31, 2023, the Firm has $101,948,000 of discretionary assets and $6,341,000 of non-discretionary assets, for a total of $108,289,000. B. Advisory Services Offered Gordon Asset Management LLC provides advisory services to: A) high net worth and other individuals ("Individual Clients") and B) pooled investment vehicles ("Gordon Funds" or "Funds"), (collectively, with Individual Clients, the "Clients"). Gordon provides goals-based investment advice to Individual Clients. Investment planning is focused on personal goals which tend to be multi-decade and focused on achievements such as (1) maximizing growth between now and retirement (2) using payouts from a portfolio to cover spending and living expenses in retirement or after inheritance (3) paying for family expenses and education, and (4) and leaving a family legacy. Investment portfolios are based on the Objectives of Long-Term Growth and Capital Reserves. At the core of Long-Term Growth is investing businesses to grow capital over time. This may be in a diversified group of companies to capture equity market returns. Accredited and Qualified investors may also choose to invest in private businesses, real-estate and total return partnerships such as hedge funds (private credit, long/short, etc). Capital Reserves are important for near-term spending goals and unexpected expenses while helping to protect the portfolio from forced selling in times of market stress. The core of Capital Reserves is cash and fixed income investments. Investment strategies typically involve investments in diversified mutual funds, exchange trade funds and private funds where clients get indirect exposure to the underlying equity, fixed income, or private securities

held by those funds. A portion of client investments may also be directly invested in individual equity, fixed income, or private securities and/or accounts managed by third-party investment advisers that have discretion over security selection. Gordon may provide personal financial planning services and consult with Individual Clients and their advisers (such as CPAs and Attorneys) regarding other issues, such as but not limited to cash flow and budget planning, portfolio income and retirement planning, generation wealth transfers, and other planning. The firm does not provide tax and legal advice. C. Customized Services Gordon tailors advisory services to the investment objectives of each Client. Client’s work with the management team to receive personalized investment guidance. D. Management Team The following is a brief background of each member of Gordon’s management team: ⋅ Arthur S. Gordon – Managing Member Arthur has over forty years of experience advising clients regarding their financial matters. Prior to forming Gordon Asset Management in 1997, Arthur was a senior partner and head of the Global Valuation Practice at Arthur Andersen LLP, a global professional services firm. As a partner at Andersen for over 20 years, Arthur advised institutions and ultra-high net worth individuals on a broad range of financial matters including investments, mergers and acquisitions, restructurings, and financial planning. Arthur has a Bachelor of Business Administration from the City University of New York’s Baruch College and a Bachelor of Laws from Brooklyn Law School. ⋅ David L. Gordon – President and Chief Compliance Officer David has managed the firm for the past fifteen years, advising clients on financial and investment planning, including areas such as cash flow, retirement planning and generational wealth transfers. He also oversees the structuring and management of global market portfolios, private equity and partnership investments. David has a Bachelor of Arts from Emory University and a Juris Doctor from Brooklyn Law School.