Knightsbridge is an independent, 100% employee-owned limited liability company headquartered in Newport Beach, California. Knightsbridge is registered as an investment adviser with the U.S. Securities and Exchange Commission. Knightsbridge was co-founded in 1998 by John Prichard, CFA. Historical investment results include periods under predecessor firms Canterbury Capital Services, Inc. (1992) and Buffalo Capital Corporation (1993). John Prichard, CFA, Kurt Beimfohr, and Miles Yourman, CFA currently own the firm. Knightsbridge Wrap Fee Program Knightsbridge provides investment advisory services directly to retail clients through a wrap fee program, as described in this brochure. Knightsbridge is both the sponsor and currently the only portfolio manager for our wrap fee program. Knightsbridge no longer offers this program to new investors. Client investments may include over the counter and exchange-traded securities such as common and preferred stocks and bonds, American Depository Receipts (ADRs), foreign securities listed on foreign exchanges (ordinaries), Real Estate Investment Trusts (REITs), closed-end and open-end mutual funds, exchange-traded funds (ETFs), interests in exchange-traded and private limited partnerships or funds that may be illiquid, fixed income securities such as corporate, mortgage, government and municipal bonds, and floating rate notes. Accounts may at times hold material positions in cash or cash equivalents. Fees for the Program Clients participating in our wrap fee program pay a single bundled fee to Knightsbridge for our advisory services and commissions on transactions instead of paying these fees separately. The maximum annual fee charged is 1.5%. The specific advisory fees are set forth in your Investment Management Agreement. Additional fees charged to clients of the Knightsbridge wrap fee program may include wire fees, and other fees and taxes on brokerage accounts and securities transactions including possible SEC transaction fees, postage, handling or other miscellaneous transaction related costs. Clients may also incur charges imposed by closed-end and open-end mutual funds and exchange-traded funds which are disclosed in the fund’s prospectus (i.e., fund management fees, operating expenses, or variable annuity fees). Clients in the program ultimately bear these costs in addition to the wrap fees charged directly to the client. Participating in the wrap fee program may cost a client more or less than purchasing investment management and trading services separately. Factors that may affect the cost of a wrap fee program relative to other compensation arrangements include: the advisory fees the client would pay for Knightsbridge’s investment management services if the fees were un-bundled; the transaction and execution fees the custodian would charge to the client under a non-wrap fee arrangement, and the frequency and volume of trading activity in the client’s account. Under the terms of this wrap fee program, Knightsbridge will pay trading and execution costs imposed by the custodian for transactions in client accounts. This arrangement presents a conflict of interest for

Knightsbridge, as Knightsbridge has a financial disincentive to engage in active trading. However, transaction fees are not a material consideration for Knightsbridge in deciding whether to engage in any trading or the level of trading activity through the custodian. We make investment decisions for clients in wrap fee programs the same way we manage accounts where the client pays for trading and execution costs separately. Knightsbridge receives compensation when clients participate in this wrap fee program. This compensation may be more than what Knightsbridge would receive if clients participated in other programs at Knightsbridge or paid separately for investment advice, brokerage, and other services, and Knightsbridge may therefore have a financial incentive to recommend the wrap fee program over other programs or services. Billing Method All separate accounts controlled by a single client under the wrap fee program will be taken together as if one account for purposes of determining fees. Once the client reaches a breakpoint, Knightsbridge bills all assets under management in the portfolio at the lower rate. Fees will be charged quarterly in arrears. Fees are calculated quarterly based on the portfolio value of the client’s assets under management, including accrued interest, at the close of business on the last day of each calendar quarter. All assets in any form in the client’s account are considered in determining the portfolio value, including cash balances, money market assets, equity and debt positions. Knightsbridge does not charge fees for the initial quarter after inception of the account if we manage the account for less than a full calendar quarter. Fees are due no later than 30 days after the calendar quarter. With client authorization, Knightsbridge will instruct the custodian to automatically withdraw its advisory fee from the client’s account on a quarterly basis. The quarterly reports we send to clients will show the amount of the fee and the fee calculation. Knightsbridge may accommodate client requests to be billed directly. All clients will receive brokerage statements from the custodian no less frequently than quarterly. The custodian statement will show the deduction of the advisory fee. It is the client’s responsibility to verify the accuracy of the fee calculation. The custodian will not determine whether the fee is properly calculated. Termination of Agreements Either party may terminate the agreement upon ten (10) days written notice to the other party; however, the client can revoke our discretionary authority over the account at any time. The client will be responsible for paying fees for services through the effective date of termination. Clients may terminate the agreement by writing Knightsbridge at our office. Any notice shall be deemed effective upon actual receipt of written acknowledgement. Upon notice of termination, Knightsbridge will calculate the final fees due for services provided through the date of termination. Any advisory fees earned for services provided will be due upon termination. We will prorate the fee due based on the effective date of termination.