Alta Capital Management, LLC (“Alta Capital”) is an investment management firm based in Salt Lake City, Utah, and established in 1981. Alta Capital’s principal owner is Guardian Capital LLC (“Guardian”). Guardian is part of a diversified financial services firm founded in 1962 and based in Toronto, Canada. Alta Capital follows a quality growth investment discipline in all equity investment portfolios. This discipline is implemented through several strategies including Large Cap Quality Growth, All Cap Quality Growth, SMID, Quality Dividend Growth, Select, Emerging Markets, and Fundamental Global Equity. Fixed Income and Balanced portfolios are available as well to complement any of the above equity strategies. Client accounts are managed to a model as determined by the Investment Committee. Alta Capital’s strategies are offered directly to institutional and private investors and accessible through multiple financial advisory partners. Direct relationships are considered non-wrap programs whereas client relationships through financial advisory partners are noted as wrap programs. In the case of wrap programs, Alta Capital does receive a portion of the wrap fee for management of the accounts. Accounts are managed to the same model, regardless of the type of program. Client initiated restrictions will be reasonably considered depending on the situation and asset level. In some cases, Alta Capital does offer financial planning services. No additional fees are charged for such services. Use of Sub-advisers Alta Capital utilizes the services of sub-adviser Drive Wealth Management, for the Fixed Income portion of certain client accounts. More information about Drive Wealth Management is available at https://adviserinfo.sec.gov/firm/summary/174728. Alta Capital utilizes the services of sub-adviser GuardCap Asset Management Limited (“GuardCap”), for the Emerging Markets and Fundamental Global Equity strategies. GuardCap provides a Model Portfolio of securities recommendations, while Alta Capital maintains full discretion to apply recommendations in a client portfolio. GuardCap is paid 50% of any management fees paid to Alta Capital for accounts in this strategy. This fee is paid quarterly in arrears. Participating Affiliate In providing services to clients invested in the Emerging Markets and Fundamental Global Equity strategies, Alta Capital relies upon the resources of its non-U.S. affiliate pursuant to a participating affiliate agreement (“Participating Affiliate”) with GuardCap. This arrangement is further discussed under “Other Financial Industry Activities and Affiliations.” Wrap Fee Programs Alta Capital offers investment advice to some of our clients through ‘wrap fee’ programs. These programs are sponsored by brokerage firms to give their clients access to various non-affiliated investment advisers of which Alta Capital is a participating adviser. If a sponsor’s client selects Alta Capital to manage assets within a separately managed account, the sponsor pays Alta Capital a portion of the fee charged by the sponsor to the client. In some circumstances, clients will see those fees payable to Alta Capital itemized, and in other cases, they will be bundled together with the fees charged by the wrap sponsor. Duties related to overall account management are shared between Alta Capital and the wrap sponsor, although Alta Capital generally retains full discretion over investment decisions. In this regard, wrap accounts are managed in a similar fashion to direct accounts within the same strategy. Clients participating in wrap fee programs also pay other fees, including certain brokerage charges, as further detailed in Items 5 and 12 below, and other custodial or administrative charges. In particular, clients pay additional brokerage commissions when their transactions are stepped out, as described more fully in Item 12. For a more complete description of the fees involved with wrap programs, please see Item 5 of this Brochure and the wrap sponsors’ Form ADV Brochure. Unified Managed Accounts Alta Capital provides model portfolio services to several Unified Managed Account

(“UMA”) programs that are managed by unaffiliated investment advisory firms. A UMA combines all of a client’s assets into a single account. These services require Alta Capital to provide these programs with daily changes to our model portfolios and are submitted in accordance with directed trading procedures, as discussed in Item 12. As the investment adviser to UMA portfolios, we are paid to share day-to-day portfolio strategy, while the program sponsors retain final discretion to implement the modeled strategy. Program sponsors manage all trading and administrative aspects of client account management. Fees and brokerage arrangements for model portfolio services differ from more traditional asset management, as described in Items 5 and 12 of this Brochure. Performance Differences between Wrap and UMA Accounts While Alta Capital wrap and UMA accounts utilizing the same investment strategy generally perform similarly, there will be performance differences between them, primarily because Alta Capital does not retain trading discretion over UMA accounts, and fees and expenses vary across sponsors. For more information about Alta Capital’s trading policies and procedures, please see Item 12 of this Brochure. Sub-advisory Arrangements Effective April 19, 2018, Alta Capital began to sub-advise the Guardian U.S. Equity All Cap Quality Growth Fund, a Canadian registered mutual fund. Effective January 21, 2019, Alta Capital began to sub-advise the Alexandria All Cap Quality Growth Fund, a fund registered in the Cayman Islands. Effective April 19, 2020, Alta Capital began to sub-advise the Guardian U.S. Equity Fund, a Canadian registered mutual fund. Each of the above advisers who have designated Alta Capital as a sub-adviser are affiliated with Alta Capital through common parent company ownership. Unitholders and shareholders are urged to review the fund’s prospectus or supplement, as applicable, for a complete discussion of the investment strategy, fees, investment minimums, risks, and conflicts of interest associated with a fund investment. Other Advisory Arrangements Effective December 19, 2018, Alta Capital has been named Investment Adviser to the Alta Quality Growth Fund, which is organized as a series of the Capitol Series Trust by Ultimus Fund Solutions, LLC. This Fund is managed to the Large Cap Quality Growth strategy. Before investing in this fund, shareholders are urged to review the fund’s prospectus, , for a complete discussion of investment strategy, fees, investment minimums, risks, and conflicts of interest associated with a fund investment. Intercompany Arrangements and Shared Employees To expand offerings to clients and leverage knowledge and expertise, Alta Capital has entered into intercompany service agreements with certain affiliates. As part of this arrangement, shared employees are made available to provide investment advisory and portfolio management services, or to provide administrative or non-advisory services to Alta Capital. To mitigate conflicts of interest, shared employees are subject to the oversight and control of both parties to ensure compliance with applicable compliance policies and regulations. Each shared employee is subject to Alta Capital’s Code of Ethics and applicable policies within Alta Capital’s Compliance Manual. No shared employee may exercise discretionary authority with respect to a client’s account unless specifically authorized by Alta Capital to do so. Shared employees are required to act at all times in a manner consistent with the fiduciary duties owed to clients to ensure that clients are treated fairly and equitably over time and information about any investment advisory or trading activity applicable to a particular client or group of clients is not used to benefit the shared employees or parties to the intercompany services agreements. Assets under Management Alta Capital’s Regulatory Assets Under Management as of 12/31/23 totaled $1,710,281,631, all managed on a discretionary basis. In addition, Alta Capital has assets under administration or Unified Managed Account (“UMA”) program assets of $1,593,116,500.