Description of Business Hallador Investment Advisors, Inc. (“HIA” or the “Firm”) primarily provides investment advisory, administrative and support services to Hallador Management, LLC (“HMGT”) an affiliated firm that is the managing member or general partner of certain privately placed pooled investment vehicles. HIA also provides investment advisory services and serves as the general partner and investment adviser to one or more privately placed pooled investment vehicles. Together, these pooled investment vehicles comprise the Hallador Funds. Finally, HIA provides investment advisory services to individually managed accounts, primarily for high net worth individuals and serves as a sub-advisor to an institutional pooled investment vehicle managed by an independent third-party advisor. HIA is 100% owned by David Hardie, its Chairman and HMGT is 100% owned by HIA. HIA’s senior managers are experienced in an array of investment products/services including equities, fixed income, and alternative investments including hedge funds and private equity. HIA was formed in 2004, and Hallador Balanced Fund, which has its roots as a family investment partnership, dates to 1974. Services Offered HIA’s core service is discretionary investment management, including but not limited to: asset allocation; due diligence on sub-managers and direct investments; monitoring of portfolio investments against the Firm’s thesis; and investor communications. HIA also observes macro-economic activity which may inform investment strategy, asset allocation, and investment selection. HIA’s primary objective across all of its strategies is to maximize absolute long-term risk-adjusted returns by investing in a diversified mix of asset classes. In pursuit of this objective, HIA allocates capital to external money managers (“sub-managers”) in certain Hallador Funds and makes direct investments in public and private securities. HIA’s sub-managers generally have full discretion

for individual investment transactions in accounts allocated to them. IRA Rollover Recommendations. For purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgement to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. We typically do not provide our clients with recommendations on IRA rollover decisions, but if we do, we will only recommend a rollover when we believe it is in your best interest. Regulatory Assets Under Management (RAUM) As of December 31, 2023, HIA managed $306,690,414 in discretionary regulatory assets under management and $0 in non-discretionary regulatory assets under management.