GILDER GAGNON HOWE & CO LLC

Item 16 - Investment Discretion​

Item 17 - Voting Client Securities​

Item 18 - Financial Information​

ITEM 4 - ADVISORY BUSINESS

Types of Advisory Services

Firm Description

GGHC provides ongoing discretionary investment advisory services for a portion of a client’s investable assets that they are willing to put at a high level of risk. GGHC’s portfolio managers (also called “Money Managers” or “Managers”) have full trading discretion through a limited power-of-attorney over the investment of the account. Clients may impose reasonable trade restrictions on their account, subject to GGHC approval.

Founded in 1968, Gilder, Gagnon, Howe & Co., LLC (“GGHC” “Firm” “we” “us” or “our”) is registered with the Securities and Exchange Commission (“SEC”) as both an investment adviser and a broker-dealer. GGHC seeks to provide long-term clients with the opportunity to build wealth through an active and aggressive discretionary trading strategy focused primarily on growth stocks, with limited use of options, bonds and exchange-traded funds (“ETFs”).

GGHC also serves as the portfolio manager and sponsor of a wrap-fee program, available only to retirement accounts. Under this program, client retirement accounts pay a single “bundled” fee, calculated as a percentage of the account’s assets under management, which covers discretionary investment advisory services, most trade execution costs and other services such as custody, recordkeeping and reporting (please see Fees and Compensation for the Firm’s commission and fee schedules and Other Expenses relating to investing in foreign securities). Individual Retirement Accounts (“IRA”) pay additional administrative and custody fees to GGHC’s clearing broker, NFS (please see Other Expenses for additional expenses paid by IRA accounts).

Investing with GGHC involves substantial risk, including risk of loss. Our aggressive approach is highly volatile and not suitable for all investors. Client accounts may experience frequent, rapid and significant swings in performance (upward as well as downward), particularly during periods of market stress and economic uncertainty. GGHC manages all investments through separately managed client accounts. The compensation model depends on the account type: non-retirement cash or margin accounts pay transaction-based commissions for each trade and retirement accounts participate in our wrap-fee program and pay an asset-based fee, billed monthly in arrears(also called a wrap-fee). The wrap-fee program is only available to retirement accounts, and GGHC only offers retirement accounts through this wrap-fee program. Because of that, “retirement account” and “wrap-fee account" are used interchangeably throughout this brochure. Please refer to the Fees and Compensation section for more information.

The primary difference between wrap-fee accounts and non-wrap-fee accounts, is that wrap-fee accounts cannot use margin or engage in short-selling, while eligible non-retirement margin accounts may do so.

Investment Strategy GGHC seeks capital appreciation through growth stock investing, primarily in equities. Money Managers operate independently and make different investment decisions, pursue different strategies, emphasize different sectors, and take differing views of the same security (e.g. Manager A is long, whereas Manager B is short the same position)1. As a result, client accounts can hold different securities, maintain different position sizes, use different

GGHC is an introducing broker, and National Financial Services (“NFS”) serves our clearing broker and custodian on a fully disclosed basis. The client always maintains asset control and can withdraw funds or close the account at any time, upon providing notice. However, GGHC has authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the executing broker-dealer(s) to be used for each trade.

For those clients who choose to have multiple accounts with different managers at GGHC, this means that you could have a long position in ABC in your account with Manager A and a short position in ABC in your account with Manager B.

levels of leverage, where permitted, and ultimately experience different investment results.

performance. The annual turnover ratio in margin accounts generally exceeds 100% and non margin accounts is generally less than 100%. Please see Fees and Compensation for further details about the costs associated with maintaining a GGHC account.

Participation in specific trades depends on factors such as available cash within the client account, account size (equity value), existing positions within the client account, and use of GGHC’s proprietary account ratios, such as risk ratio and leverage ratio. As a result, client accounts will experience trading activity and performance.

Assets Under Management As of December 31, 2025 GGHC had approximately $9,075,841,934 of assets under management (“AUM”) on a discretionary basis. GGHC does not manage any client assets on a non-discretionary basis. Because the AUM amounts disclosed in this brochure reflect the deduction of outstanding margin loans, they differ from the regulatory assets under management (“RAUM”) amounts disclosed in Form ADV Part 1A.

GGHC client accounts will experience frequent trading activity as GGHC Money Managers pursue potential growth opportunities. Where permitted, a GGHC Money Manager may purchase securities for client accounts on margin, using the client’s account as collateral, and the client will pay NFS interest on any margin loan. Only non-retirement margin accounts can purchase securities on margin or engage in short selling. Because GGHC earns commissions on trades in non-retirement accounts, higher trading activity increases commission costs to the client.

Types of Agreements The following agreements govern the typical client’s relationships with GGHC and with NFS, GGHC’s clearing broker which serves as the custodian for client accounts:

Borrowing to invest (i.e. buying on margin) can increase exposure and potentially lead to losses greater than the account value if the market suddenly falls. Although unlikely, GGHC may have to liquidate securities during an unfavorable time in the market to repay the lender, which can cause losses that exceed the initial investment. To attempt to reduce this exposure, GGHC will engage in short sales (borrowed securities are sold), which offer the opportunity to profit from falling stock prices. However, short selling is a risky strategy. The price of the stock sold short could increase without limitation, and thus there is no limit to potential losses from a short.

INVESTMENT ADVISORY AGREEMENT Each client signs an Investment Advisory Agreement with a limited power of attorney granting GGHC discretion to purchase and sell securities and other instruments and obligations for the client’s account. The Investment Advisory Agreement provides, in part, that GGHC will not be liable for honest mistakes in judgment, for losses due to such mistakes, or for any other loss or damage arising out of, or based upon any act or omission by GGHC, unless GGHC has knowingly violated any applicable law, or is found to have been negligent or to have engaged in willful misconduct. Of course, federal and some state securities laws may impose liabilities under certain circumstances on persons who act in good faith, and nothing in the agreement constitutes a waiver or limitation of any rights that a client may have under applicable federal or state securities law.

Buying on margin and selling short have the virtue of increasing the client’s dollars at work, while attempting to moderately reduce the client’s exposure to abrupt swings in the market. Frequency of trading or account turnover will vary, depending on factors including the GGHC Money Manager, type of account (margin or cash/retirement), market volatility, and client specific activity (money movements including deposits or withdrawals). The annual turnover in margin and cash accounts generally exceeds 100%. The higher the turnover in a commission-paying account, the greater the adverse impact that commissions will have on investment

AGREEMENTS BETWEEN THE CLIENT AND NFS Each client must establish a brokerage account at NFS and deposit cash and/or securities in their account. NFS will maintain custody of the assets in the client’s account while those assets are managed by GGHC. GGHC will not

accept unsolicited orders from clients for a discretionary managed account. Clients should read their brokerage agreements carefully for complete information about the terms and conditions of their NFS accounts.

asset based fee, and those fees are prorated based on the number of days money is in the account during the month.

ITEM 5 - FEES AND COMPENSATION

In order to participate in IPOs and follow-on offerings clients must establish a Prime Broker Account at NFS. There is a minimum equity requirement of $105,000.00 for the establishment of a Prime Broker account. Prime Broker paperwork is included in the new account documentation sent to all new clients. Account equities are reviewed daily for Prime Broker qualification. If a client has more than one account at GGHC with the same ownership title, the equity values are combined to meet the minimum requirement.

Description GGHC receives compensation for its investment advisory services, which is specified in the client’s investment advisory agreement with GGHC. The compensation structure will vary depending on the type of account and is not subject to negotiation. Non-retirement accounts are charged a transaction based fee (also known as a commission) on each trade and will vary depending on the type of security (please see Commission Schedule Non-Retirement Accounts for details on the commission schedule). Each commission payment will adversely affect the performance of the account. Certain types of trades or accounts qualify for standard discounts, which are described below following the commission schedule.

Clients who have a non-retirement margin account must sign a margin agreement with NFS to be able to trade on margin. This agreement discusses the risks associated with trading on margin, including borrowing money to use securities as collateral to purchase additional securities and sell securities short. Please see “Other Expenses” for other expenses associated with margin accounts and “Other Compensation- Payments and Credits from NFS to GGHC” with regards to NFS sharing revenue with NFS.

GGHC bears the cost of trade execution for domestic securities, which is less than the amount of commissions GGHC charges its clients, and means that GGHC earns a profit on each trade. For foreign securities, the cost of trade execution is embedded in the price of the stock. Note regardless of trade execution costs, clients pay GGHC a commission on each trade. Commissions paid by clients include the cost of investment advisory services, custody and brokerage services (Please see Other Expenses for trades executed in foreign markets and Commission Schedule - Non-Retirement Accounts).

In addition, clients who have a non-retirement cash account or retirement account that want to participate in an optional fully paid lending program with NFS, must sign a separate agreement and other ancillary documents. This program offers clients the potential to receive additional incremental income by loaning out the fully paid shares and receiving interest payment. Please see “Other Compensation – Payments and Credits from NFS to GGHC” for information regarding NFS sharing revenue with GGHC.

Retirement accounts are charged an annualized bundled or “wrap” fee based on the account’s assets under management, valued on a month-end basis and paid monthly in arrears. The wrap fee covers investment advisory services, most execution costs (see “Other Expenses”), and other services, such as custody, recordkeeping and reporting (no additional GGHC commissions are paid by retirement accounts for trades executed in these accounts).

At any time, a client may terminate GGHC’s Investment Advisory Agreement by providing GGHC with written notice. GGHC may terminate the Investment Advisory Agreement upon delivery of 30 days’ written notice to the client. Unless otherwise mutually agreed to by GGHC and the client, upon termination, GGHC will commence an orderly liquidation of the securities and any other non-cash assets in the account in the normal course of business. The risks associated with such liquidation will be borne exclusively by the client, as will any commissions resulting from the liquidation for non-retirement accounts. Retirement accounts pay an

GGHC’s standard commission and wrap fee rate is not negotiable.

OTHER COMMISSIONS (2% LIMIT)

Commission Schedule Non-Retirement Accounts

While GGHC primarily purchases equities for client accounts, we may occasionally purchase options, debt securities/bonds, and ETFs.

COMMISSIONS ON EQUITY TRADES

Options—GGHC’s standard commissions on option trades are based on the premium price (the price paid to the issuer of the option for granting the rights, which are separate from and in addition to the exercise price). If the option premium is less than or equal to $5.00, the commission is 2% of the premium. If the option premium is greater than $5.00, the commission is $10 per option. GGHC does not charge commissions when exercising options (but commissions are charged when buying or selling options).

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GGHC provides discretionary investment management services. GGHC enters into an investment advisory agreement with each client, giving GGHC the authority, without obtaining specific client consent, to buy, sell, hold, manage or otherwise trade in any security. This authority includes the ability to transact in securities in foreign markets, which may require the disclosure of personal client information (clients must agree to the disclosure of personal information). Clients also grant GGHC discretion to select the broker-dealers and other financial institutions through which to effect transactions for their accounts and the commission rates paid (please see Brokerage Practices for further details).

ANNUAL TECHNOLOGY CREDIT AND BUSINESS DEVELOPMENT CREDIT During the initial 10-year term of the clearing agreement, NFS has agreed to issue an annual technology credit to GGHC ($750,000) to offset technology-related costs. This credit creates an incentive for GGHC to select and continue to use NFS as its clearing firm. However, based upon the scope of services and pricing offered by NFS, GGHC believes that its selection of NFS was, and remains, in its clients’ best interests; GGHC believes that the NFS platform enables GGHC to maintain access to a market-leading clearing agent.

Clients may impose reasonable restrictions on GGHC’s discretionary authority, subject to Firm approval. GGHC will accept restrictions on accounts in certain circumstances, including restrictions because of the client’s employment or affiliation. GGHC may decide not to accommodate investment restrictions deemed unduly burdensome or materially incompatible with GGHC’s investment approach. Client-directed investment restrictions could cause the performance of the account with restrictions to deviate from the performance of other similarly managed accounts. Generally, GGHC’s clients are unable to restrict or prohibit transactions or direct transactions for execution through specific brokers and dealers.

ITEM 15 - CUSTODY GGHC does not maintain physical custody of clients’ assets. All GGHC client accounts are carried by NFS, on a fully disclosed basis. GGHC is considered to have “custody” because it is authorized to deduct its commissions or advisory fees, as applicable, directly from

GGHC does not vote proxies for securities held in client accounts and does not provide advice on how to vote them. Clients receive all proxy statements and related voting materials directly from the issuers of the securities they hold. For retirement plan clients, these materials are sent to the plan fiduciary identified in the plan’s Investment Advisory Agreement, who is responsible for voting. For foreign issuers, clients may not always be able to vote proxies. For example, proxy voting materials may not reach our clearing broker, NFS, to then be distributed to clients to vote before the deadline.

The Firm is not subject to any financial condition that is reasonably likely to impair its ability to meet its contractual and fiduciary commitments to clients.