A. Description of Advisory Firm and Principal Owner(s) Lombard Investments, Inc. (the “Firm”), a California corporation, was formed in San Francisco in 1985. Currently, the Firm is owned by three of its current and former senior professional staff members: Thomas J. Smith, Jr., Peter H. Sullivan, and Scott P. Sweet. B. Types of Advisory Services Offered The Firm provides discretionary investment management and administrative services to certain private partnerships and private investment funds (each a “Fund” and, collectively, the “Funds”) in accordance with the terms of each Fund’s disclosure documents and relevant offering materials and organizational and other governing documents (together, the “Governing Documents”). Interests in the Funds are typically offered and sold in reliance on the private placement exemptions provided under the U.S. Securities Act of 1933, as amended (the “Securities Act”), including Regulation D and/or Regulation S relating to certain non-U.S. offerings. The Firm is affiliated with Lombard Holdings, LLC (“Lombard Holdings”) and Lombard Investments (HK) Limited (“Lombard HK”). The Firm, Lombard Holdings and Lombard HK, are part of a single advisory business controlled by Thomas J. Smith, Jr. and Scott P. Sweet. Each of Lombard Holdings and Lombard HK are “relying advisers” with respect to the Firm. The relying advisers are deemed to have been registered through the Firm’s Form ADV pursuant to an umbrella registration provision which, among other things, requires that: (i) the Firm (the “filing adviser”) and the relying advisers advise only private funds or certain separate accounts with investors who are “qualified clients,” as defined under Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); (ii) the filing adviser’s principal office and place of business is in the United States and the substantive provisions of the Advisers Act and the rules thereunder apply to the filing adviser’s and each relying adviser’s dealings with each of its clients; (iii) the relying advisors and their personnel are subject to the filing adviser’s supervision and control and are “persons associated with” the filing adviser, as defined in Section 202(a)(17) of the Advisers Act; (iv) the advisory activities of each relying adviser are subject to the Advisers Act and the rules thereunder and each relying adviser is subject to examination by the SEC; and (v) the filing adviser and the relying advisers operate under a single set of written policies and procedures adopted and implement in accordance with Rule 206(4)-(7) under the Advisers Act and a single Chief Compliance Officer. Private Equity (Thailand) Company Limited (“PETCL”) was previously affiliated with the Firm and was a relying adviser. PETCL separated from Lombard (as defined below) on May 13, 2021, at which time Lombard Holdings disposed of its interest in PETCL to certain of PETCL’s senior employees and their affiliated entity. As a result of such separation, and PETCL’s separate registration

with the U.S. SEC, PETCL is no longer a relying adviser with respect to the Firm. While PETCL is no longer an affiliate of the Firm or a relying adviser, it has agreed to continue to act as a sub-advisor with respect to the existing Funds. The Firm provides its services to the Funds through or with the assistance of Lombard Holdings, Lombard HK, which employs staff based in Hong Kong (the “Offshore Affiliate”); and other affiliated entities, including the general partner of each Fund (the Firm, Lombard Holdings, the Offshore Affiliate, and the other affiliated entities, including the general partner of each Fund, collectively, “Lombard,” “us,” “we”, and “our”). C. Tailoring of Advisory Services to Client Needs; Client Restrictions The term “Client” as used in this brochure generally refers to one of the Funds or any future fund or pooled investment vehicle that Lombard may, from time-to-time, manage or advise. The term “Investors” generally refers to the limited partners or other equity owners of one or more of the Funds. Lombard’s most recently established Funds have focused on markets within the Asia- Pacific region. The terms upon which Lombard serves as an investment manager of a Fund are established at the time each Fund relationship is established and are generally disclosed in the offering documents for the Fund and/or as set out in an investment management agreement and/or limited partnership agreement or other Governing Documents entered into by Lombard with respect to the relevant Fund and/or side letter agreements negotiated with Investors, as applicable. Lombard provides investment advice directly to the Funds, and not individually to Investors in a Fund. These terms, which vary as among each Fund, may restrict Lombard’s advice concerning investment in certain securities or geographies, or concentration limits, among others. As described more fully in Item 8, below, we routinely enter into side letter agreements with certain Investors in Funds providing such Investors with customized terms, which often result in preferential treatment. D. Wrap Fee Program We do not participate in wrap fee programs. E. Managed Assets As of March 31, 2023, we managed $304,599,581 of Client assets on a discretionary basis in the following Funds: Lombard Asia III L.P. (“LAIII”) LAIII was formed in 2006 to make direct, private equity investments in certain markets of the Asia-Pacific region. The investment period for LAIII has ended. LAIII AIV, L.P. (“LAIII AIV”), an associated Fund, was formed in 2008 to make a direct, private equity investment in Taiwan. The shares of the sole portfolio company held by LAIII AIV were sold, and the proceeds from the sale and other net assets of LAIII AIV were distributed in 2013. LAIII AIV was dissolved on January 6, 2014. Lombard Asia IV, L.P. (“LAIV”) LAIV was formed in 2012 primarily to make direct, private equity investments in certain markets of the Asia-Pacific region. The investment period for LAIV has ended.