KLCM Advisors, Inc.

Kitzinger.

not charge advisory fees to certain individuals at the firm's discretion, including employees and their family members.

clearly describe preclearance requirements and the controls KLCM uses to mitigate conflicts of interest when employees trade the same securities as clients, and added new disclosures describing restrictions on trading before known client transactions and liquidity‑based standards used to review employee personal trading activity.

Item 12: Updated disclosures regarding brokerage selection practices to more clearly describe how KLCM evaluates commission rates in relation to the value of research and brokerage services received, including disclosure that commissions paid can exceed the lowest available execution‑only rates and can range up to approximately $0.05 per share.

terms other than those intended by KLCM or the client, and that the Compliance Committee reviews all trade errors exceeding $100.

at least quarterly.

Other Information: Reorganized (but did not alter) the existing disclosures within this response for clarity, moving information on disaster recovery (Item 18), cybersecurity risks (Item 8), diminished capacity (Item 4), identity theft (Item 15), legal proceedings/class action claims (Item 17), and compliance oversight responsibilities (Item 10) to more logical locations.

Form ADV Part 2A, Item 3

Contents Material Changes .......................................................................................................................................... 2 Advisory Business.......................................................................................................................................... 4 Fees and Compensation ................................................................................................................................ 4 Performance-Based Fees and Side-by-Side Management ............................................................................ 5 Types of Clients ............................................................................................................................................. 5 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................................... 6 Disciplinary Information................................................................................................................................ 7 Other Financial Industry Activities and Affiliates .......................................................................................... 7 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................ 8 Brokerage Practices ...................................................................................................................................... 8 Review of Accounts ..................................................................................................................................... 11 Client Referrals and Other Compensation .................................................................................................. 12 Custody ....................................................................................................................................................... 13 Investment Discretion ................................................................................................................................. 14 Voting Client Securities ............................................................................................................................... 14 Financial Information .................................................................................................................................. 14

Form ADV Part 2A, Item 4

Advisory Business KLCM Advisors, Inc. (KLCM) was established in March 1993. Our owners are James B. Kitzinger, Carl J. Fuda, Mark A. Sailer, Katherine R. Licau Gifford, Neal P. Coleman and Jack J. Kitzinger. Collectively they have over 100 years of experience working with individuals, corporate sponsors, and institutions in building balanced and equity portfolios. James B. Kitzinger and Jack J. Kitzinger serve as KLCM's principal owners. KLCM offers balanced, equity, and fixed income portfolio management. We also work as part of our client's financial team to consult on issues related to the portfolios we manage. Our product set includes:

Value Equity Balanced (value equity and fixed income) Fixed Income

Portfolios are managed as separate accounts. Each client's asset allocation is tailored to reflect their income needs, risk tolerance, and liquidity requirements. KLCM does not manage accounts or invest in securities based on Environmental, Social, and Governance ("ESG") criteria. Clients may impose restrictions on investing in certain types of securities, industries, specific securities, or other client limitations. It is the client's responsibility to provide these limitations to us in writing. Measures are taken to note the individual client's request for that restriction. KLCM does not participate in "wrap fee programs," where we would receive a portion of the wrap fee for our services. All our client accounts are discretionary. As of December 31, 2025, we had $1,876,937,886 under management. We do not manage client assets on a non-discretionary basis. We are mindful that cognitive capacities can diminish over time, though not always as a result of age. We take our fiduciary responsibilities to our clients seriously and have implemented policies to help guide our employees when they suspect a client is experiencing diminished capacity, as these clients could, through no fault of their own, be susceptible to making decisions that are not in their long-term best interests. As requested by the custodian, we encourage clients to name a trusted contact with whom we could speak if we identify a potential diminished capacity concern.

Form ADV Part 2A, Item 5

Fees and Compensation Management fees are based upon a percentage of assets. The standard fee is 1.0% per year on equity assets, and 0.6% on fixed income assets managed. Existing clients' actual fees are based on the terms negotiated when those relationships were established and are detailed within the investment management agreement. Management fees are negotiable and can include fees based on a percentage of assets and fixed fees. KLCM does not charge advisory fees to certain individuals at the firm's discretion, including employees and their family members. While KLCM's fee schedule creates an incentive to encourage clients to remain invested, KLCM prioritizes acting in the client's best interest as described within this brochure.

KLCM fees are billed quarterly in arrears. This quarterly rate is applied to the average month-end market value for the previous quarter. KLCM aggregates the assets for clients with tiered fee schedules when calculating fees. KLCM will consider the receipt of cash flows received during the quarter in calculating fees separately, based on the size and timing of the cash flow relative to the account's size, and will adjust the fees when the cash received or disbursed is deemed material. Clients may elect to be billed directly for fees or authorize KLCM to debit fees from their accounts via their custodian. Each client receives a quarterly invoice. KLCM bills all terminating clients for fees due upon receipt of the notice of termination. Besides management fees, clients will pay third-party custody fees, brokerage fees, transaction costs, and mutual fund and exchange-traded fund (ETF) expenses. For more details about brokerage and transaction costs, please refer to Item 12, "Brokerage Practices." KLCM uses account market values supplied by the clients' custodians or an independent pricing service to calculate investment performance and client fees. KLCM reviews prices provided by these pricing sources for reasonableness. While this rarely occurs, if a pricing source does not provide a price or if we believe a price supplied does not reflect an accurate market value, we will attempt to obtain a price from separate independent pricing sources.

Form ADV Part 2A, Item 6

Performance-Based Fees and Side-by-Side Management KLCM does not charge or accept performance-based fees or compensation.

Form ADV Part 2A, Item 7

Types of Clients KLCM provides investment advice to high-net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations or business entities. All clients are required to enter into an investment management agreement before we provide our services. The general minimum account size for management is $500,000. Exceptions are made based on investment client type, account size, relationship size, service requirements, and other factors. We have an incentive to encourage individual retirement account owners to rollover an employer retirement account into a KLCM-managed Individual Retirement Account, which results in higher fees for KLCM. The decision of whether to rollover an employer retirement account rests with you, the individual account owner. Unless you independently choose to rollover the account, we will provide information to help you make a decision that is in your best interests. Select clients are family members or personal friends with firm personnel, including firm partners. These clients maintain separate personal relationships with firm personnel. At times, firm personnel will engage in personal business dealings with these clients as a natural extension of their outside personal relationships. Given the inherently close working relationship we have with our clients, we expect relationships with clients to continue to evolve. These expanded relationships present an inherent conflict to provide preferential treatment to certain clients. We believe our firm's steadfast dedication to fairness and integrity, along with our policies and procedures designed to promote the fair and consistent treatment of clients as summarized

within this disclosure brochure, help to mitigate this conflict. Also, employee outside business activities require advanced approval, with the goal of identifying and determining how to mitigate conflicts identified.

Form ADV Part 2A, Item 8

Methods of Analysis, Investment Strategies, and Risk of Loss The primary focus of KLCM equity investing is to buy companies at compelling valuations while minimizing the risk of capital loss. In our experience, opportunities arise when the market overreacts to disappointing short-term results or due to the general neglect or protracted unpopularity of a company or sector. Our approach is to apply intensive research and direct and typically extended management contact to identify those situations with limited risk and substantial upside over two to three years. Emphasis on cash flow and an underlying firm's enterprise value, isolating a catalyst for change, looking beyond short-term results, and understanding management objectives are critical to the process. We engage in fundamental fixed income analysis for fixed income securities to identify issuers with sound revenue sources, reasonable leverage, and a track record of profitability in most years. We also apply traditional credit analysis to assess the capacity, collateral, and character of each issue. Despite rigorous analysis, the possibility of loss still exists. We do not intend the following summary of risk factors to be a complete and comprehensive statement of all risks related to investing generally or investing with KLCM. General Risk of Loss. Investing is a speculative endeavor involving risk, which includes the possible loss of principal. Past performance is not indicative of future results. Market Risks. The value of the securities held in client accounts tends to increase or decrease in response to movements in the market. Stocks generally fluctuate more than bonds and may decline significantly over short periods. Management Risk. The profitability of a significant portion of our recommendations depends to a great extent upon correctly assessing the future course of price movements of stocks and bonds. We cannot assure we will predict those price movements accurately. Our strategies do not, however, attempt or depend on our ability to predict the direction of the overall market in the short to intermediate term. Reliance on Key Personnel. The investment management activities of our firm rely on the business and investment acumen of our management team. If any member of our management team leaves, it could negatively impact our ability to manage client portfolios. Equity Securities Risk. Equity securities are inherently volatile, susceptible to broad market fluctuations and economic downturns. This volatility can lead to significant price swings, potentially resulting in capital losses for investors. The performance of an individual equity security is also directly linked to the issuing company's financial health, management decisions, and industry trends. Poor company performance, negative events, or industry disruptions can significantly impact the security's value. We strive to minimize equity risk through in-depth fundamental analysis with attention devoted to cash flow and balance sheet issues and careful attention to valuation. We will not buy stocks that are currently in vogue with high valuations and high expectations. Avoiding overpriced securities and employing a disciplined sell process is critical to constraining risk. Fixed Income Securities Risk. Fixed income securities carry the risk that the issuer may fail to meet their interest or principal repayment obligations. This risk is generally higher for corporate bonds compared to government bonds. Also, changes in interest rates can affect the market value of fixed income securities.

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