A. Description of Firm Rice Hall James & Associates, LLC (“Rice Hall James”) is an SEC registered investment management firm, with its principal place of business located in San Diego, California and a branch office located in Pasadena, California. Rice Hall James was founded in 1974. Rice Hall James provides investment management services on a discretionary basis to its clients. We conduct business in a number of states (see Part 1 of our Form ADV). Rice Hall James, a limited liability company, has six managing members (“Managing Members”) serving with the following functions: Thomas McDowell, Chief Executive Officer & Co-Chief Investment Officer for San Diego; Thao Buuhoan, President and Chief Operating Officer; Timothy Todaro, Portfolio Manager; Cara Thome, Portfolio Manager, Yossi Lipsker, Portfolio Manager/Analyst, and Lou Holtz, Chief Investment Officer for Pasadena-based Opportunities Team and Portfolio Manager/Analyst. The Managing Members are responsible for overseeing the firm’s investment activities and business operations. In the aggregate, they own a majority interest in Rice Hall James and comprise the firm’s management committee. B. Types of Advisory Services Offered Rice Hall James provides its investment management services on a discretionary basis to clients directly (“Direct Clients”), via sub-advisory arrangements (“Sub-Advisory Clients”), and through unaffiliated third party sponsored wrap programs (“Wrap Clients”). Currently, Rice Hall James does not offer or provide its services to clients on a non-discretionary basis, except under Unified Managed Account programs (see below for description) and we do not sponsor wrap programs. Additionally, Rice Hall James serves as the investment adviser for our affiliated registered mutual fund, the RHJ Fund, and serves as a sub-manager to non-affiliated U.S. mutual funds (“Mutual Fund Clients”). Rice Hall James also serves as sub-manager to an Ireland based common contractual fund (“CCF Client”) and an adviser to the Rice Hall James Collective Investment Trust (“RHJ CIT”). Currently we offer five core investment strategies: 1) Small Cap Equity Strategy 2) Micro Cap Equity Strategy 3) Small Cap Opportunities Strategy 4) Micro Cap Opportunities Strategy 5) SMID Cap Opportunities Strategy Please refer to Item 8 for further information regarding our analysis methods and investment strategies, including details on the specific risks associated with these strategies. Services Provided to Direct Clients Each Direct Client will enter into a written agreement with Rice Hall James for the management of assets. At the beginning of the relationship, we generally meet with Direct Clients and gather information regarding the client’s overall investment objectives. This will include the Direct Client’s individual needs, such as risk tolerance, time horizon and any restrictions placed by the client. From there, we assist the client in determining the investment strategy or strategies that are best suited to meet the clients’ needs and objectives. Once a Direct Client has selected an investment strategy or strategies, we provide continuous supervision and asset management. Direct Clients are responsible for informing us of any changes to their guidelines, individual needs and/or restrictions. Services Provided to Unified Managed Accounts (“UMAs”) Rice Hall James has entered into written agreements with certain unaffiliated investment advisers, commonly referred to as UMA accounts (unified managed accounts), to provide ongoing information regarding our strategies. Under these arrangements we supply the investment adviser (“UMA Sponsor”) with a model portfolio for one or more of the investment strategies we offer. Rice Hall James does not have any relationship or agreement with the UMA Sponsor’s Clients and does not receive any specific client information from the UMA Sponsor. The UMA Sponsor retains full discretion on whether or not to invest their UMA Clients’ assets using model portfolio investment recommendations we provide. Rice Hall James does not include any UMA assets in the calculation of our AUM (assets under management), however, we are paid a flat

percentage fee on these assets. See Item 5 below for further information on fees. Services Provided to the Mutual Fund and CCF Clients For our Mutual Fund and CCF Clients, we manage the pooled assets of each in accordance with the relevant fund’s investment objectives and restrictions as outlined in the offering documents (i.e., prospectus). These investment objectives and restrictions cannot be changed without a shareholder/investor vote or agreement, as applicable. Services Provided to the RHJ CIT Rice Hall James serves as an investment adviser to the RHJ SMID Cap Opportunities CIT (the "RHJ CIT Fund"), which is part of the Rice Hall James Collective Investment Trust (the "RHJ CIT”). SEI Trust Company serves as the Trustee of the RHJ CIT (the “Trustee”) and is an unaffiliated trust company organized under the laws of the Commonwealth of Pennsylvania and wholly owned subsidiary of SEI Investments Company. The RHJ CIT Fund investors are limited to tax qualified pension plans, profit sharing plans, and government plans. A collective investment trust such as the RHJ CIT Fund is not a mutual fund. Rice Hall James also provides various services for the RHJ CIT, which include but are not limited to providing: (i) educational and training materials on the RHJ CIT to prospective participants, (ii) customer service to RHJ CIT participants; and (iii) certain information to the Trustee of the RHJ CIT on a quarterly basis. Services Provided through Unaffiliated Wrap Programs Rice Hall James also offers its investment strategies through certain wrap programs (each, a “Wrap Program”), which are sponsored by multi-service financial institutions unaffiliated with us (each, a “Wrap Sponsor”). A list of such Wrap Programs may be found in Part 1 of our Form ADV. Wrap Clients enter into a written agreement with the Wrap Sponsor, not Rice Hall James. Generally, a Wrap Client selects an investment adviser, such as Rice Hall James, from a list of Wrap Sponsor-approved advisers. The selected adviser will provide investment management services for the Wrap Client’s assets allocated to the Wrap Program. For a single all-inclusive fee that the Wrap Client pays the Wrap Sponsor (the “Wrap Fee”), a Wrap Client receives certain other services from the Wrap Sponsor, such as trading execution and custodial services. Rice Hall James does not receive any fees or compensation directly from Wrap Clients. Under an agreement with the Wrap Sponsor, Rice Hall James receives a portion of the Wrap Fee from the Wrap Sponsor for providing investment management services for the Wrap Client’s account. Although the types of investment management services we provide to Wrap Clients are generally the same as the types of investment management services provided to our Direct Clients, certain differences exist. These include: 1) that the Wrap Sponsor collects each Wrap Client’s investment objectives and assists in determining the strategy best suited for the Wrap Client, and 2) communications regarding the investment management of a Wrap Clients’ assets is between the Wrap Sponsor and the Wrap Client, with Rice Hall James only communicating with the Wrap Sponsor (unless the Wrap Client requests otherwise). Sub-Adviser Arrangements with Unaffiliated Third-Party Advisers Rice Hall James has entered into written agreements with certain unaffiliated third-party investment advisers to serve as a sub-adviser and provide investment management services to the third-party advisers’ clients. Under these sub-advisory arrangements, each third-party investment adviser is responsible for working with its clients to select the appropriate Rice Hall James strategy for investment. Rice Hall James manages the clients’ designated assets based on the respective selected investment strategy, as provided by the third-party investment adviser. Please refer to Item 5 for information regarding the fees received by Rice Hall James under the various arrangements outlined above. C. Assets Under Management As of December 31, 2023, the following represents the total amount of regulatory client assets under management ("AUM") by Rice Hall James on a discretionary basis: Discretionary $1,740,724,495