SIT INVESTMENT ASSOCIATES INC

Management (Mutual Funds): In the Sit Mutual Fund fee table, removed equity fund fee waivers, if any, and updated the contractual management fee for such funds to reflect the reduction in the contractual management fee by the amount of that fee waiver such that the total expense ratio remained unchanged.

Updated the disclosures in “Cybersecurity Risk”, “Market Risk” and “Interest Rate Risk”. Full Brochure Available To receive a current brochure (free of charge) please contact us at 612-332-3223. Our brochure is also available on our web site www.sitinvest.com. Additional information about Sit Investment is also available via the SEC’s web site www.adviserinfo.sec.gov.

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Table of Contents Cover Page Item 1 ............................................................................................................................. i Material Changes Item 2 ................................................................................................................. ii Table of Contents Item 3 ................................................................................................................. iii Advisory Business Item 4 ................................................................................................................ 1 Fees and Compensation Item 5 ....................................................................................................... 3 Performance-Based Fees and Side-By-Side Management Item 6................................................... 8 Types of Clients Item 7 ................................................................................................................... 9 Methods of Analysis, Investment Strategies and Risk of Loss Item 8 .......................................... 10 Disciplinary Information Item 9.................................................................................................... 15 Other Financial Industry Activities and Affiliations Item 10........................................................ 16 Code of Ethics, Interest in Client Transactions and Personal Trading Item 11 ............................ 19 Brokerage Practices Item 12 ......................................................................................................... 20 Review of Accounts Item 13 ......................................................................................................... 24 Client Referrals and Other Compensation Item 14 ....................................................................... 24 Custody Item 15 ............................................................................................................................ 24 Investment Discretion Item 16 ...................................................................................................... 25 Voting Client Securities Item 17 ................................................................................................... 25 Financial Information Item 18 ...................................................................................................... 26 Requirements for State-Registered Advisers ................................................................................. 26 Privacy Policy ................................................................................................................................ 26 Business Continuation Policy ........................................................................................................ 27 Class Action Settlements ............................................................................................................... 27 Brochure Supplement..................................................................................................................... 28

Advisory Business Item 4 Firm Description Sit Investment is a privately owned independent investment adviser located in Minneapolis, Minnesota. Sit Investment was founded in 1981. We manage our clients’ assets on a discretionary basis. Sit Investment manages domestic and international equity securities. Our subsidiary, Sit Fixed Income Advisors II, LLC is a separately registered investment adviser and specializes in managing fixed income securities. Sit Investment and its subsidiary are located in the same Minneapolis office and share all resources. The fixed income investment management services offered by our subsidiary are discussed in a separate brochure. Ownership Sit Investment is privately held. Approximately 88% of the company is owned by members of the Sit Family and by trusts established for their benefit, the trustees of which are Roger J. Sit and Ronald D. Sit. Roger J. Sit is an officer and director of Sit Investment and actively involved in the management operations. Ronald D. Sit is a director of Sit Investment. The outstanding shares are held by: Sit Family 88% Other Employees 8% Outside Shareholders - Individuals 4% Total 100% Investment Management – Equity Investment Philosophy Our equity investment philosophy targets growth-oriented companies. Generally, we look to invest in companies with the potential to increase earnings at a faster rate than the representative economy and market index. We believe that earnings growth is the primary determinant of superior long-term returns. We manage our portfolios on an active basis, concentrating our investment in the best growth opportunities at the most reasonable valuation levels. See Item 8 for a discussion regarding our investment strategies. Investment Management – Decision Making Process We manage our clients’ assets on a team basis. Investment management decisions are made by the Investment Committee, with Roger J. Sit as the Chief Investment Officer having final decision-making responsibilities. The Investment Committee’s investment decisions are implemented using model portfolios with targeted security weightings. The stock selections for specific client accounts are based on the model portfolios and adjusted for each client’s unique investment restrictions as set forth in the investment management agreement with each client. Specific client restrictions differ from client to client and include, for example, restrictions on investing in certain companies or types of securities. The Investment Committee is comprised of the firm’s equity investment management professionals. The individuals with the most significant responsibility for the day-to-day discretionary advice provided to

clients are listed below. These individuals also have primary client relationship responsibilities. Please see the Brochure Supplement for information about these individuals. Roger J. Sit, Chairman, CEO, President and Global Chief Investment Officer David A. Brown, CFA, CPA (inactive), Vice President – Research and Investment Management, Director of Client Services Kent L. Johnson, CFA, Senior Vice President – Research and Investment Management Assets Under Management Sit Investment manages client assets on a discretionary basis for several types of clients, including, public and private institutional investors, pension funds, Taft-Hartley plans, charitable institutions, foundations, endowments, corporations, insurance companies, municipalities, registered investment companies, private investment companies, collective investment trusts and high net worth individuals. As of December 31, 2025, we managed $3.5 billion. Please refer to Item 7 for information regarding the accounts managed. Sit Investment serves as the sponsor, general partner, or manager for several of the investment companies to which it provides investment advisory services. Sit Investment is the adviser to the Sit Mutual Funds, a family of 14 no-load mutual funds. For information on the investment company affiliates, see the response to Items 7 and 10. Sit Investment provides services to a model delivery program sponsored by an unaffiliated third party. The program sponsor has investment discretion and is responsible for execution of transactions for and monitoring of its participant accounts. Sit Investment delivers to the program sponsor notice of changes Sit Investment makes to the model portfolio. Sit Investment’s subsidiary, Sit Fixed Income Advisors II, LLC, manages fixed income assets on a discretionary basis for the same types of clients. Together, Sit Investment and Sit Fixed Income Advisors II, LLC manage $18.5 billion in fixed income and equity securities as of December 31, 2025.

Fees and Compensation Item 5 The specific manner in which fees are calculated and paid to Sit Investment is established in the investment management agreement with each client. Generally, fees are stated at an annual rate, calculated quarterly as a percentage of net asset value at the end of each calendar quarter, and payable quarterly in arrears. Fees paid by investment company clients are generally calculated and paid monthly in arrears. The net asset value is generally determined based on the aggregate market value of all assets held in the account. Management fees are prorated for material capital contributions or withdrawals made during the calendar quarter, and fees are prorated for accounts initiated or terminated during the quarter. Depending on specific circumstances, such as, for example, a large amount of assets managed for a client, fees are subject to negotiation. Sit Investment’s fees are exclusive of brokerage commissions, transaction fees, and other portfolio related costs and expenses which are incurred by the client. Clients will likely incur charges imposed by custodians, brokers, and consultants. Item 12 further describes the factors that Sit Investment considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of the commissions. Clients may request to be billed in advance, and in the event such a client terminates its agreement, unearned fees will be promptly refunded. Clients may also request that Sit Investment send a copy of its invoice directly to its custodian, who will in turn direct payment from the client’s account. Pursuant to the terms of the investment management agreement with each client, clients may terminate the agreement with Sit Investment on thirty days written notice, or in some cases at any time without notice. Each registered investment company may terminate the investment management agreement with Sit Investment on sixty days written notice provided the investment company's Board of Directors consents or a majority of the investment company's shareholders consent. The investment management agreements are terminated automatically if assigned. All terminations are without penalty. Sit Investment provides services to a model delivery program sponsored by an unaffiliated third party on a nondiscretionary basis. As compensation for model delivery services, Sit Investment is paid a fee by the program sponsor at a pre-determined rate based on assets under management in the program utilizing the model. The program sponsor determines the fee to charge its model delivery program clients. Sit Investment provides investment management services to tax-exempt charitable organizations and makes a charitable contribution to certain of such organizations. The charitable contributions are generally equal to a fixed percentage of the investment management fees paid to Sit Investment by the charitable organizations. Sit Investment’s most significant fee schedules are presented below. Separate Account Management: Large Capitalization, Concentrated, Dividend Growth, and Balanced Portfolios Net Asset Value Annual Rate First $10 million 0.75% Next $10 million 0.70% Next $10 million 0.65% Next $10 million 0.60% Over $40 million Negotiable

Medium Capitalization Portfolios Net Asset Value First $30 million Next $70 million Over $100 million

Annual Rate 1.00% 0.70% 0.50%

Small Capitalization and Small Capitalization Dividend Portfolios Net Asset Value Annual Rate First $50 million 1.00% Next $50 million 0.60% Over $100 million 0.50% International/EAFE+, Global, Global Dividend, Global Balanced, and ESG Growth Portfolios Net Asset Value Annual Rate First $10 million 0.80% Next $20 million 0.75% Next $20 million 0.65% Over $50 million 0.50% Developing Markets and Pacific Basin Portfolios Net Asset Value Annual Rate First $10 million 0.90% Next $20 million 0.85% Next $20 million 0.75% Over $50 million 0.60%

For certain clients for which Sit Investment manages multiple accounts, Sit Investment has negotiated a rate applicable to the total of all assets managed on behalf of the client by Sit Investment and its affiliates. For certain clients utilizing the services of certain financial consultants or financial intermediaries, Sit Investment has negotiated a rate applicable to the total of all assets managed on behalf of the financial consultant or financial intermediary by Sit Investment and its affiliates. Affiliated Registered Investment Company Management (Mutual Funds): The Sit Mutual Funds are a family of no-load, open-end registered investment companies (mutual funds). Sit Investment serves as the investment adviser and administrator to the Sit Mutual Funds pursuant to the investment management agreements with each Fund and with respect to U.S. Government Securities Fund, Inc. and Sit Mutual Funds II, Inc., additional separate Supervision and Administration Agreements. The Funds are unified fee investment companies (UFIC) where the Funds pay Sit Investment a single unified management fee and Sit Investment is responsible for paying all fund operating expenses (except interest, brokerage commissions, portfolio transaction charges including acquired fund fees and expenses, fees paid under a distribution plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940, and certain extraordinary expenses as determined by the boards of directors). Fees paid Sit Investment are based on the Fund’s average daily net assets on an annual basis as set forth below. Seven Sit Mutual Funds have two share classes as noted below with different minimum investment requirements and a 12b-1 fee or a different supervisory and administrative fee.

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