Oak Ridge Investments, LLC (“Oak Ridge,” “We” or the “Firm”) is an investment advisory firm founded in 1989. Our founder and CEO, David Klaskin, owns slightly less than 50% of the Firm. We focus, and predominantly limit, our direct advice to analyzing and recommending equity stocks traded on United States stock exchanges for our clients, currently in the strategies described below. As one part of its advisory services Oak Ridge sub-advises four mutual funds. Equity Strategies As of the date of this document, the Firm manages five diversified equity strategies (the “Equity Strategies”) for separately managed accounts and manages or is available to manage unified managed accounts:
• Small/Mid Cap Growth invests in securities with a market cap range at the time of initial purchase similar to its benchmark, the Russell 2000® Growth Index.
• Mid Cap Growth has a market capitalization guideline at the time of initial purchase of being in line with its benchmark, the Russell Midcap Growth® Index.
• Large Cap Growth holds stocks with a market capitalization of over $3 billion at the time of purchase. The strategy’s benchmark is the Russell 1000® Growth Index.
• All Cap Growth purchases securities with a market capitalization of $500 million and up. The strategy’s index is the Russell 3000® Growth Index.
• Dividend Growth is a concentrated portfolio, holding 25-35 securities, with a minimum capitalization of $5 billion. The index for this strategy is the S&P 500 and the portfolio’s goals include seeking to buy stocks with a growing dividend per share and exceeding the dividend yield rate for the index. The primary objective of our Equity Strategies is long-term capital appreciation. Our Dividend Growth investment strategy also has dividend yield as a primary objective. We generally maintain accounts fully invested in equity securities, which we define as holding less than 10% in cash and equivalents. Additional information about the Equity Strategies can be found in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss. Our clients in the Equity Strategies can access our portfolio management through multiple channels, including directly through the Firm or through one or more programs sponsored by unaffiliated entities (“Sponsored Programs”). The unaffiliated entities (each a “Sponsor”) can be a bank, broker-dealer or investment advisor. There are three types of Sponsored Programs: 1) Dual Contract programs where the client signs separate agreements with the Sponsor and with Oak Ridge; 2) Sub-advised programs, including wrap fee programs, in which the client signs an agreement only with the Sponsor and the Sponsor has the discretion to engage Oak Ridge to advise a separate account on behalf of clients within the program; or 3) Unified Managed Account (“UMA”) programs in which Oak Ridge provides a Sponsor with a model portfolio, but does not have discretion over client assets, records of individual client holdings and typically information about individual clients. Oak Ridge invests discretionary assets for each account in the Equity Strategy or Strategies chosen by a client using Oak Ridge’s Equity Strategy model portfolio. Oak Ridge also considers each client’s objectives, individual needs and restrictions. Oak Ridge manages the equity holdings and the overall asset allocation between equities and cash, but does not select money market funds, mutual funds or ETFs for clients. You, your custodian, broker-dealer or investment advisor

should select a money market fund or cash equivalent that is appropriate for your Oak Ridge account. We will accept accounts with reasonable restrictions (see Item 16, Investment Discretion) and will follow client direction for individualized treatment of securities, such as for tax gain or loss sales or certain limited other purposes. We will also work with clients on restrictions for clients who desire their accounts be managed in a socially responsible way as however the clients may want to define that. Oak Ridge will also provide input on managing an account, if requested, in accordance with environmental, social and governance standards (“ESG”) as the client may want to define or design that. Oak Ridge will also consider other circumstances, such as ticket charges if applicable, when trading client portfolios. You should contact us, either directly or through your program Sponsor, to inform us of any changes in your circumstances or restrictions that would affect how we manage your account. Wrap Fee and Sponsored Programs – Wrap fee accounts and other Sponsored Program accounts may be billed to you as a single fee by the Sponsor. The Sponsor will pay Oak Ridge’s investment advisory fee out of the wrap fee it collects, with the remainder being retained as its fees and/or advisory or consulting fees and in lieu of the Sponsor’s commissions and custody fees. Cash needs in these accounts may be slightly higher than in other accounts due to the combined fees (for the Sponsor and Oak Ridge) periodically deducted directly from the portfolio assets. Additional information about fees can be found in Item 5, Fees and Compensation. In determining, whether to establish a Sponsored Program account, whether a wrap fee program or otherwise, you should be aware that the overall costs may be higher or lower than you might incur by accessing the same services outside of the Sponsor Program. In evaluating whether or not a wrap fee program or arrangement is appropriate for your needs, you should consider factors such as the size of the account, the expected frequency of transactions by the advisor in the investment strategy or due to cash flows initiated by you, and your investment objectives. Rebalancing transactions due to cash flows in or out of your account, especially in smaller accounts, may affect performance and could incur higher than normal trading expenses (including commissions if in place) both in amount and as a percentage of your account value. These could influence your decision whether or not to choose a wrap account or even whether to engage in cash flow transactions on as frequent a basis. UMA Programs – Oak Ridge has agreements with other investment advisors who use model portfolios provided by the Firm as the basis for investment strategies that they offer to their clients. Oak Ridge does not create these models for any specific individual(s) or the particular needs of any client; but based upon what Oak Ridge believes is an appropriate allocation and weighting of securities for each strategy. The UMA investment advisor has discretion to determine when, how and to what extent to act upon Oak Ridge’s recommendations. Assets under Management; Assets under Administration As of December 31, 2022, we had assets under administration of approximately $1.139 billion which included discretionary client assets under management of approximately $708 million and an additional approximately $431 million advised on a non-discretionary basis in UMA accounts.