Cambiar Investors, LLC (“Cambiar” or the “Adviser”) is an independent, employee-owned investment manager founded and registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”) in 1973. Cambiar is wholly owned by Cambiar Holdings, LLLP (“Holdings”). Holdings is owned by 20 partners, all of whom are employees of Cambiar. Cambiar provides investment management services, primarily on a discretionary basis, to taxable and tax-exempt clients, including mutual funds, exchange-traded funds, pension plans, endowments, foundations, collective investment trusts, state and municipal government entities, Taft-Hartley plans, families and individuals. Cambiar provides the following advisory services:
• Discretionary investment advisory services to separate accounts (“Separate Accounts”). Cambiar provides discretionary investment advisory services to institutions such as corporate retirement plans, endowments, foundations, charitable, tax-exempt, and other institutions. Cambiar also offers Separate Account services to high-net-worth individuals and individual retirement accounts. Cambiar provides investment advisory services in its current investment strategies pursuant to contractual arrangements negotiated with the client. The terms of these agreements may contain reasonable client-specific guidelines and restrictions, provided that such guidelines and restrictions will not prevent the Adviser from effecting the investment strategy. Cambiar will also provide investment guidelines upon request.
• Discretionary investment adviser to mutual funds and exchange-traded funds (ETFs). Cambiar serves as the investment adviser to the Cambiar Opportunity Fund, the Cambiar International Equity Fund, the Cambiar Small Cap Fund, and the Cambiar SMID Fund (the “Cambiar Funds”), each a series of The Advisors’ Inner Circle Fund. Cambiar may also serve as investment sub-adviser to other registered investment companies (together, with the Cambiar Funds, the “Mutual Funds”). Cambiar also provides advisory services to one or more fully-transparent, actively- managed ETFs, including the Cambiar Aggressive Value ETF (the “Cambiar ETFs”, and together with the Cambiar Funds, the “Cambiar ICs”).
• Discretionary investment services to a Collective Investment Trust. The Trustee of the Cambiar Investors Collective Investment Trust (“CIT”) has retained Cambiar to provide investment management services to the CIT.
• Discretionary investment services for wrap/separately managed account programs. Cambiar provides investment management services to wrap fee programs by serving as investment manager (or as sub-adviser to the manager) of wrap fee participant accounts. In a separately managed account (“SMA”) program, the program sponsor (typically a broker- dealer or an affiliated advisory firm) provides a bundle of services to clients such as assessing client suitability, assisting the client in selecting and overseeing investment managers, providing custodial and client relationship services, and facilitating and executing portfolio trades, in exchange for a single “wrap” fee paid to the sponsor. Costs associated with executing client portfolio trades, e.g., brokerage/commissions, as applicable, are within the sole discretion of the program sponsor. Typically, the sponsor pays a portion of the “wrap” fee to investment managers such as the Adviser for providing investment advisory services. Cambiar does not sponsor any SMA, wrap fee, UMA (described below) or any similar program.
• Discretionary and non-discretionary sub-advisory services to third-party advisers. Cambiar also provides services to unified managed account (“UMA”) programs, as well as programs under which Cambiar provides stand-alone investment models (“model portfolio” arrangements) on both a discretionary and non-discretionary basis. Under these types of programs, investment managers provide investment recommendations to the sponsor (or an overlay manager selected by the sponsor) in the form of a model portfolio and periodically provide model updates. The sponsor or overlay manager retain the discretion as to whether to implement the investment manager’s recommendations for its clients.

The sponsor or overlay manager typically initiates and executes trades for UMA/model portfolio arrangements, although Cambiar may assume more direct trading responsibilities under certain arrangements. In these arrangements, underlying UMA/ model portfolio clients are receiving investment management services from the program sponsor rather than directly from the investment manager, and the manager generally has limited information regarding the identity or nature of the sponsor’s client. Wrap Fee Programs. SMA and UMA/model portfolio arrangements (together, “Wrap fee programs”), offer certain advantages to participants, such as enabling smaller clients to obtain the services of selected investment managers for accounts that might otherwise be too small to be managed as a separate account. Other characteristics of these types of accounts are the sponsor’s monitoring and oversight of investment managers, the execution of trades and the payment of brokerage commissions for accounts regardless of the number of trades, and the maintenance of custody of portfolio securities. Participants should be aware, however, that the fees charged by wrap fee program sponsors can be higher than the fees that might be paid for the same services on a stand-alone basis and can be higher than the fees other accounts pay for Cambiar’s services directly, and wrap fee clients should evaluate whether the aggregated cost of such services, if provided separately, would be less than the wrap fee paid to the sponsor. Due to the structure of wrap fee programs and investors’ more direct relationship with the sponsor, Cambiar is generally not in a position to provide the same comprehensive client relationship services to wrap fee participants that it provides to other types of clients, including Separate Accounts. Investment Restrictions. Separate Account clients may impose reasonable investment-related restrictions on the nature and types of securities to be held in their accounts. Cambiar reserves the right to reject or modify investment restrictions based on, among other things, the impact such restrictions may have on Cambiar’s ability to execute its investment strategy, the willingness or ability of the client to specifically identify the securities or other financial instruments to be restricted, and the difficulty adhering to and monitoring certain types of investment guidelines or restrictions. Wrap fee program participants are permitted to impose reasonable investment-related restrictions on the management of their accounts, which may be implemented by the sponsor or the overlay manager, or in other instances, by Cambiar or service providers retained by Cambiar. Wrap fee participants or Separate Account clients who impose multiple restrictions on the nature or type of securities to be held in their accounts should be aware that Cambiar may, in its discretion: (i) invest a larger percentage of these portfolios in fewer securities than would be the case if there were no such restrictions; (ii) choose alternative securities for the account; and/or (iii) hold higher levels of cash. In these instances, investment performance can be affected. Clients who impose investment restrictions should be aware that the performance of their accounts might differ from that of client accounts which do not impose such investment restrictions. Standard of Care. Under the Advisers Act, an investment adviser owes a fiduciary duty to its clients, consisting of a duty of care and a duty of loyalty. Although the application of Cambiar’s fiduciary duty can be shaped by agreement with clients, this duty cannot, unless specifically set forth in statute, be waived by contract or practice. Accordingly, investment advisory agreements that include an express limitation of the Adviser’s liability for acts of gross negligence, negligence, or similar standards are not applicable to the Adviser’s federal fiduciary duty owed to the client. Clients have the right to seek redress against the Adviser for such non-waivable fiduciary violations in addition to other rights the client may have under state and federal law. As of December 31, 2023, Cambiar managed approximately $3.4 billion on a discretionary basis on behalf of 7,031 clients and $1.0 billion on a non-discretionary basis.