SAM is an SEC registered investment adviser organized as a Delaware limited liability company with its principal office and place of business in New York City. SAM was founded in 1982 and is owned by Michael A. Steinberg, certain of his family members and the Steinberg 2001 Family Trust. As of December 31, 2023, SAM had total regulatory assets under management of $143,055,977, which includes proprietary accounts of SAM principals, and client accounts managed on a discretionary basis. SAM is led by Michael A. Steinberg and Justin S. Steinberg, who lead SAM’s Investment Team. SAM is a value equity adviser managing separate accounts in primarily all-cap value equity portfolios for institutions, pensions, endowments, foundations, and high net worth individuals. SAM also manages certain client accounts in small-cap, and mid-cap strategies. Clients may request that SAM tailor its advisory services for them to include reasonable restrictions and special objectives which SAM will accommodate so long as, in the sole judgment of SAM, it has reasonably determined that the implementation of the request will not unduly interfere with or disadvantage the requesting client or other existing clients. Typical examples of client requests for their portfolio include:
• Limiting maximum individual position sizes;
• Limiting maximum sector exposure;
• Excluding “sin stocks” such as alcohol, tobacco and gaming companies;
• Excluding foreign ordinary stocks;
• Directing all or a portion of trading to certain broker(s); and/or
• Maintaining a specific cash position. While SAM does not sponsor any wrap fee program, it does serve as a manager for other wrap fee programs offered by brokerage and financial service firms. SAM manages accounts which are part of wrap fee programs using the same investment philosophy and process as non-wrap fee program clients. In a wrap fee program, clients pay a single fee to the wrap sponsor which covers some or all of the following services: portfolio management, custody, administration,

commissions for trades executed by the sponsor (or an affiliate of the sponsor), and selection of portfolio managers and monitoring of the managers’ performance for continued inclusion in the sponsor’s wrap fee program. The fee paid by the client is not based directly upon transactions in the client’s account but is based on the asset value of the account. Wrap fee program clients either have a direct contractual relationship with SAM or receive SAM’s advisory services through a contract entered into with the sponsor. Advisory fees may be paid to SAM by the wrap fee program sponsor or directly by the client. Wrap fee program clients generally instruct the advisor to execute transactions through the wrap fee program sponsor. Clients are advised that the sponsor may assess additional charges if our client directs trades through a broker-dealer other than the sponsor (or its affiliate). SAM relies on wrap fee program sponsors and their financial advisers to fulfill certain responsibilities with regard to wrap fee program clients. Generally, wrap fee program sponsors may assume tasks such as: (1) ensuring SAM’s advisory services are suitable for the client’s investment objectives; (2) performing any “know your customer” requirements imposed under applicable money laundering requirements; (3) monitoring and evaluating SAM’s performance; (4) delivery of SAM’s Brochure and Privacy Notice; and (5) communicating performance, reports and other information to the client. The terms of each client's account in a wrap fee program are governed by the client's agreement with the wrap fee program sponsor, the brokerage account agreement and disclosures, and the sponsor’s investment advisory disclosure documents. Wrap fee program clients are urged to refer to these documents for further information and contact their financial adviser with questions about the wrap fee program. SAM provides personalized investment advice to clients, who may contact SAM with questions about the portfolio management services provided by SAM.