Kinney Asset Management, LLC (the “firm,” “we,” “us,” or “our”) is a registered investment adviser based in Chicago, Illinois. We are organized as a Delaware limited liability company and have been providing investment advisory services since 2003. Peter Kinney is the majority owner of the firm. Peter serves as the managing member of the firm. Gotham Advisers, LLC owns a passive minority stake in the firm, and does not actively participate in daily operations. The firm’s primary focus is providing investment advisory services to a private pooled investment vehicle, Acacia Capital, LP, a Delaware limited partnership organized in February 2003 (the “Fund”), and to separately managed accounts of institutional clients and investment vehicles organized by institutional third parties (each a “separately managed account,” and together with the Fund, each a “client”), including on a sub-advisory basis. We invest primarily in equity securities globally with a value-driven philosophy which focuses on a relatively small number of domestic and international equities that we believe are positioned to experience long-term appreciation. The following paragraphs describe our services and fees and how we tailor our advisory services to the individual needs of clients. Portfolio Management Services – Separately Managed Accounts We provide investment advice tailored to meet our clients’ needs and investment objectives. As part of our portfolio management services, we may customize an investment portfolio in accordance with a client’s risk tolerance and investment objectives. We may also invest client assets in accordance with a predefined strategy. Once we construct an investment portfolio for a client, we will monitor the portfolio’s performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions. Our investment advisory agreement contains an authorization by which the client grants us discretion to make purchases and sales for the account without requiring us to obtain consent or approval from the client prior to each transaction, to select the type and amount of securities that we buy or sell for the account, the broker or dealer we use to effect such transactions and

the commission rates paid. However, clients may specify their investment objectives and guidelines, select their portfolio strategy and impose certain reasonable restrictions or investment parameters for their account. For example, a client may specify that investments in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrict or prohibit transactions in the securities of a specific industry or issuer. Either a client or the firm may terminate the investment advisory agreement, generally upon 60 days’ notice. Upon termination, a client will incur a pro rata charge for services rendered prior to the termination of the agreement, which means the client will incur advisory fees only in proportion to the number of days in the quarter for which the agreement was in effect. The terms of each agreement will be determined on an individual basis. See Item 7 for more information on the types of clients we may offer advisory and sub-advisory services. Pooled Investment Vehicle – Acacia Capital, L.P. We serve as the general partner to the Fund, which is a U.S. domiciled limited partnership. The Fund has been our primary investment management client since our inception as an investment adviser. Its investment objective is to seek to provide an above average long-term absolute return from a portfolio invested primarily in equity securities located outside the United States. We tailor our advisory services to the Fund, and not to the needs of any underlying investor in the Fund. This brochure should not be considered an offering document for the Fund and investors should refer to the Fund’s private offering memorandum or organizational documents for a complete description of the Fund, including its strategies, risks, conflicts of interest and expenses. The Fund is exempt from registration as an investment company under Section 3(c)(7) of the Investment Company Act of 1940 (the “1940 Act”). We may launch or manage pooled vehicles other than the Fund. Assets Under Management As of December 31, 2023, we managed approximately $584,467,981 in regulatory assets under management on a discretionary basis. We do not currently manage any assets on a non- discretionary basis.