Pacific Global Investment Management Company (“Pacific Global” or “we” or the “firm”), a privately held California corporation established in 1991, provides investment management services to individuals, institutions, retirement plans and others as Separately Managed Accounts (SMAs). The firm also provides financial planning services related primarily to retirement, cash flow and investment planning. From 1993 to early 2020, the firm also managed the Pacific Advisors family of mutual funds. Pacific Global is registered with the SEC under the Investment Advisers Act of 1940 (Advisers Act). This registration does not imply a certain level of skill or training. A. Ownership Structure George A. Henning, Chairman and President of Pacific Global, is a principal owner of the firm. B. Advisory Services Pacific Global provides investment advisory services to various types of SMA clients as described below and in Item 7. 1. SMA Clients Pacific Global provides investment advisory services to high net worth individuals and institutional investors. When providing such services, each client account is governed by a written Investment Management Agreement (IMA) which reflects any circumstances specific to the account. In the IMA, the client selects one investment management style for the account. Our management styles, all of which are offered exclusively on a discretionary basis, include equity (value‐oriented or core, a combination of value and growth), fixed income and balanced (fixed income and equity mix) options. For individuals, the client’s financial situation, risk tolerance and needs are considered. The client makes the final determination as to which of the management styles is appropriate and desired. Subject to Pacific Global’s approval, the client may impose reasonable restrictions on investments or the management style selected in the IMA. Restrictions are permissible provided that, in Pacific Global’s view, they do not present a significant handicap to the management style. If we determine that the restrictions would present a significant handicap, we would not accept the prospective client, or the IMA would be terminated. Periodically, an officer or authorized representative of Pacific Global seeks to determine if any changes in a client’s financial situation or needs might affect the client’s account or make continuation of management services inappropriate. 2. Financial Planning Services We utilize currently known variables to assess future cash flows, asset values, and withdrawal plans in our comprehensive evaluation of a client’s current and anticipated future financial state. Through the financial planning process, we consider and analyze all information and variables which may impact, or be impacted by, the entire financial and life situation of the client. Each client who enters into a Financial Planning Agreement will receive a written report which provides

a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. We offer financial planning in the following subject areas:  Retirement Planning: We analyze a client’s current strategies and investment plans to help assess future asset values, cash flows and withdrawal plans. For retirees, we analyze the impact of varying income and expenses, gifting, and risk tolerance with the objective of maintaining financial independence.  Cash Flow Planning & Income: We review a client’s family records, budgets, assets, liabilities, and cash flow to create a clear picture of the current financial status to determine opportunities and priorities.  Investment Planning: We analyze investment alternatives and the effects of each on a client’s portfolio. Specific topics that may include current asset allocation; strategies for retirement income; potential returns, withdrawal rates and tax ramifications of various investment strategies; portfolio optimization and rebalancing; and education planning. We gather required information through in‐depth personal interviews as well as client‐provided documents. In preparing a written plan, we consider a client’s current financial status, tax circumstances, future goals, investment objectives, and attitudes toward risk. We initiate the Financial Planning process once a client signs the Financial Planning Engagement Agreement and provides the necessary requested information and documents. The financial plan will be completed when a client receives a written plan; typical financial planning engagements are completed within six (6) months of the initiation date. Should a client choose to implement the recommendations contained in the financial plan, Pacific Global suggests that a client work closely with his or her attorney, accountant, insurance agent, financial adviser and/or broker. Implementation of the recommendations contained in the financial plan and/or financial consulting engagement is entirely at a client’s discretion. A client may select on‐going reviews of the financial plan. The updates, which typically occur annually, review the income, expense and other components of the plan. Absent the selection of this ongoing review option on the Financial Planning Engagement Agreement, the plan will be complete with the delivery of the written plan. We also provide a less formal financial consulting service. Consulting topics may include our observations and recommendations on assets (such as 401(k) accounts) which are not managed by Pacific Global. Additional topics available for consulting engagements are Education Planning, Gifting Strategies and Investment Analysis. Separate fees, as agreed upon, may be charged for consulting services. C. Assets Under Management As of December 31, 2023, Pacific Global had $740.2 million in client assets under management. All assets were managed on a discretionary basis.