Mittleman Investment Management, LLC (“MIM,” “we,” “our,” or “us”) is a limited liability company formed under the laws of the State of New York. Mittleman Investment Management, LLC is also known by the names Mittleman Brothers or Mittleman Brothers Asset Management. We began providing discretionary portfolio management and advisory services with a focus on domestic and foreign equity securities in 2005. We are an indirect wholly-owned subsidiary of Aimia AM Holdings Inc. (“Holdings”), a holding company organized in the State of Delaware. 100% of the voting interests of Holdings is owned indirectly by Aimia Inc. (“Aimia”), a publicly traded company listed on the Toronto Stock Exchange (Ticker: AIM:CN). We serve as an investment adviser and provide asset management services to high-net-worth individuals and various types of institutional clients described below in “Item 7 – Types of Clients” and to one private investment fund. We conduct research, make investment decisions for our client accounts, and generally select the broker-dealers for the execution of client transactions. Additional details are provided below in “Item 12 – Brokerage Discretion.” As of December 31, 2022, we managed approximately $93 million of net assets on a discretionary basis. We do not provide investment management services on a non-discretionary basis. As the result of the departure of certain key personnel, including Christopher P. Mittleman, our former Chief Investment Officer, among other reasons, we have determined to begin to wind-down the business operations of Mittleman Investment Management, LLC. A. SEPARATELY MANAGED ADVISORY ACCOUNTS Separately Managed Accounts (“SMAs”) are managed in accordance with the terms, conditions, guidelines, and limitations contained in Investment Advisory Agreements or Investment Management Agreements (either, an “IMA”) between us and our corresponding client. In general, we do not tailor our asset management strategy to the individual requests of our clients (that is, client portfolios typically all contain the same securities), although position weightings of investments in our clients’ accounts will typically vary as we make independent allocation decisions with respect to each client account. Under limited circumstances, if acceptable investment guidelines or investment restrictions are requested by an institutional investor, we have, and will consider such on a case-by-case basis. In light of our decision to begin to wind-down the business operations of Mittleman Investment Management, LLC, we have discontinued the investment program for our SMA clients. Our IMA with an SMA client will be terminated on or before April 14, 2023, unless a client would prefer to terminate the agreement earlier. An SMA client will have the option to retain the securities within their account at the account’s current custodian, in which case the account will become a self-directed account and, as such, we will no longer have investment discretion over such account. An SMA client will also

have the option to move the securities in their account to another specified brokerage account. B. PRIVATE FUND (AFFILIATED WITH AND MANAGED BY US) We advise one affiliated private investment fund, Precog Capital Partners, L.P. (“Precog”). We manage Precog in accordance with the objectives and investment strategies described in its offering documents. The terms, conditions, risks, and fees pertaining to an investment in Precog are outlined in Precog’s Private Placement Memorandum and other applicable offering documents. Our SMA clients are under no obligation to consider, or to make, an investment in Precog. See additional details regarding conflicts of interest below in “Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss” and “Item 11 - Code of Ethics, Participation of Interest in Client Transactions and Personal Trading.” Aimia is a significant investor in Precog with ownership of more than 86% of its limited partnership interests as of December 31, 2022. While this investment provides a wider capital base to absorb the operating expenses of Precog, it does require us to treat Precog as a proprietary account which means that in situations where we trade in the same securities for Precog and SMAs on the same day, Precog will not receive a better trade price than any SMA unless such SMA is also considered a proprietary account. See additional details regarding fees below in “Item 5 – Fees and Compensation, and regarding conflict of interest below in Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss” and “Item 11 - Code of Ethics, Participation of Interest in Client Transactions and Personal Trading.” Investing in Precog involves various risks, including but not limited to: the potential for complete loss of principal, liquidity constraints, and a lack of transparency. Unlike liquid investments that a client may maintain, Precog does not provide daily liquidity or pricing. We serve as the investment manager to Precog and provide investment advice thereto in accordance with Precog’s offering documents, and not in accordance with the individual needs or objectives of any particular investor therein. In general, investors in Precog are not permitted to impose restrictions or limitations. However, we have entered into side letter agreements with one or more investors that change the terms of the interest(s) held by these investor(s). See “Item 5B – Fees and Compensation, Precog.” In light of our decision to begin to wind-down the business operations of Mittleman Investment Management, LLC, we have discontinued Precog’s investment program and commenced the liquidation of its assets. Precog will no longer accept any new subscriptions for interests. Throughout this Brochure, discussions of Precog are separated from our discussions about matters that relate to our SMA clients except where such separation is unnecessary because Precog and our SMA clients are treated in the same or substantially the same manner.