Avenir Corporation: investment adviser

Avenir provides advisory services for a diverse client base, ranging from taxable individual and family accounts, trusts and partnerships to non-taxable pension accounts and foundations. Avenir’s investment style is a highly disciplined core value strategy focused on capital preservation and real rates of return, taking into consideration inflation and taxes. Avenir’s portfolios are relatively concentrated, reflecting Avenir’s belief that portfolios comprised of a limited number of superior investment opportunities combined with a high margin of safety can achieve better overall results than broadly diversified portfolios. Avenir understands that each client has special requirements and goals, and therefore clients may impose restrictions on investing in certain securities or types of securities. Avenir provides investment management services to certain clients who participate in wrap fee programs. Wrap fee programs are typically characterized by a bundled fee arrangement that covers both the investment manager’s services (i.e. those provided by Avenir) and any advisory fees paid to the wrap sponsor, as well as all brokerage commissions, custodial costs and related administrative costs. The total fees charged by these programs are set by the sponsoring broker, not by Avenir. From Avenir’s perspective, clients with wrap fee arrangements receive the same level of investment advisory services as non-wrap fee clients. Avenir managed approximately $849,280,840 of discretionary assets as of March 30, 2026.

In addition to paying investment management fees, accounts are also subject to other expenses such as custodial charges, brokerage commissions and related costs; taxes; foreign exchange transaction fees; and costs, expenses and fees that may be specific to the account. Client assets may be invested in money market mutual funds, ETFs or similar instruments. For such investments, the client will bear its pro-rata share of the investment management fee and related expenses of the investment separately from the investment management fee paid to Avenir. For a full discussion of Avenir’s brokerage practices please refer to Item 12 of this brochure. Avenir or the client may request termination of the investment management agreement and the client may obtain a pro-rata refund of fees paid by supplying written notice to Avenir 30 days prior to the effective date.

Avenir seeks to engage senior management in detailed discussions relating to the nature of the business in order to identify the true economic potential of the business, evaluate the quality of the franchise and assess management’s ability to achieve high returns on investment. Avenir avoids the concept of relative valuation to the market as a whole and does not necessarily believe that a stock is inexpensive simply because traditional metrics such as price-to-earnings ratio or price-tobook value multiples are low. Avenir focuses on long-term value opportunities and security selection is not limited by market capitalization weightings, industry sectors, or other classifications. Although Avenir’s investment strategy is focused primarily on equities, the firm will consider investments in any security that can generate equity-like returns while also providing a margin of safety, including convertible securities and distressed debt. In general, all Avenir portfolios are managed in a similar manner; however, certain accounts may hold different securities due to unique client circumstances or the timing of account fundings. Avenir’s investment strategy involves risk and clients must be prepared to bear the loss of their entire investment. There are substantial risks related to Avenir’s investment strategy. Avenir invests primarily in equities and thus Avenir portfolios are always exposed to systemic risk as well as the unique risk present in any security. Accounts may not be diversified across a wide range of securities, industry sectors or geographies. Avenir accounts are relatively concentrated and thus will likely exhibit more volatility and by traditional measures may be considered to have more risk than accounts that are invested in a larger number of securities with correspondingly smaller position sizes. Concentrated investment portfolios typically exhibit more volatility and changes in value relative to an index. Moreover, Avenir’s assessment of an investment may be flawed, or the investment may suffer a permanent loss in value due to unforeseen reasons. Equity prices fluctuate in response to numerous factors including company specific issues as well as macro-economic factors, political factors, market related movements, and other developments. Fluctuations can be significant over the short and long term, and different sectors of the market and different types of equity securities may react differently to various events. Many unforeseen events and developments may affect a single issuer, issuers within an industry or entire sectors of the economy. Terrorism and related

geopolitical risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and financial markets generally.

Managers and employees of Avenir in the course of their investment management and other activities may come into possession of confidential or material nonpublic information about issuers, including issuers in which Avenir or its related persons have invested or seek to invest on behalf of clients. Avenir is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a client. Avenir maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Avenir is meeting its obligations to clients and remains in compliance with applicable law. Avenir’s employees own the same securities owned by clients. This practice directly aligns the personal interests of Avenir’s employees with those of the firm’s clients. Such practices could present a conflict in cases where Avenir employees may be in a position to trade in a manner that could adversely affect clients. In order to mitigate any such conflicts, Avenir has policies and procedures that favor client transactions over those of Avenir employees. The guiding premise is that client accounts are always served first. To ensure compliance with this policy, all contemplated employee owned security purchases and sales are to be reviewed by an officer of Avenir prior to execution. The Chief Compliance Officer reviews all employee and manager trades in a timely manner to ensure that this rule is upheld.

current commission rates, existing and new trading relationships, and discuss any changes in the trading environment. Avenir often receives research or other products or services from broker-dealers or a third party. Avenir does not maintain any soft dollar accounts to obtain research or other products or services. In the cases where Avenir directs trades to a broker-dealer in return for research or other products or services clients are not charged additional costs beyond the brokerage commission; however, the brokerage commission for a specific trade may at times be higher than those that would be charged by other broker-dealers or alternative trading platforms. In some cases Avenir may request a broker-dealer to step-out part of the commission to another broker-dealer in return for research or other products or services. Examples of research products and services that may be obtained include research reports on companies, industries and securities; discussions with research analysts; and hosted meetings with corporate executives. These research products and services supplement Avenir’s own research and analysis and aid in the investment decision process. The use of client commissions to obtain research or other products or services may raise conflicts of interest. Avenir receives a benefit by not having to produce or pay for the research, products or services. This creates an incentive for Avenir to select or recommend a broker-dealer based on its interest in receiving those products and services, rather than on a client’s interest in receiving most favorable execution. Research and other services obtained in this manner may be used in servicing any or all accounts and may be used in connection with accounts other than those that pay commissions to the broker-dealer relating to the research or other service arrangements. Certain clients choose custodians who require directed brokerage as a part of their custodial services. These accounts require directed brokerage due to either the market value of the account or are a part of a wrap platform. When Avenir is directed by a client to use a specified broker-dealer to execute its transactions, Avenir may be unable to achieve the most favorable execution of a transaction. Typically, Avenir has limited ability to negotiate commission rates with directed broker-dealers and the client may not receive as favorable prices or commission rates as it might otherwise have obtained if Avenir selected the brokerdealer. This can create a disadvantage for the client and cause the client to pay higher transaction costs. Avenir typically aggregates client purchase and sell orders for individual securities. Aggregated orders allow Avenir to allocate securities to clients at the average transaction price for a security achieved during a trading day. This may result in an aggregated price that is more or less favorable to a client when compared to an individual order. In cases where orders are placed to purchase or sell the same security concurrently for both non-directed accounts and directed accounts the larger aggregated order is typically executed first. The non-directed accounts will often make up the larger aggregated order. This may or may not cause the smaller aggregated order for directed accounts to receive a less favorable transaction price which may create a disadvantage for the client. If an aggregated order is not completely filled during the trading day, then there will not be enough shares to fill all the account targets, requiring a partial allocation among accounts. When completing such partial allocations, Avenir limits establishing insignificant positions in the target security. Additional factors are considered in determining partial allocations, including the relative cash position in an account. Avenir may execute cross transactions among discretionary client accounts except as noted below. Cross transactions enable Avenir to execute a trade among clients for the same security at a set price, thereby possibly avoiding an unfavorable price movement that may occur through entrance into the market and lowering commission costs for both accounts. Cross transactions are done at or as close as possible to the mid-point in the bid-ask spread at the time of the trade. Cross transactions are not permitted for benefit plans or other similar accounts that are subject to ERISA.

Avenir may be required to vote proxies differently for certain clients due to unique conditions. Avenir considers each proposal in proxies on a case-by-case basis, and

occasionally on an account-by-account basis. Depending upon the issue being voted on, Avenir may vote with or against a Board of Director’s suggestion or abstain from a particular proposal. Avenir may refrain from voting a proxy or vote with management on all proposals in certain circumstances. Proxies can cover a wide array of issues affecting individual companies. In general, these issues include board size and composition, executive compensation, stock option plans, choice of auditor, and individual shareholder proposals. The final voting decision is determined by Avenir’s individual managers after having reasonably evaluated each proposal on a proxy. The final vote for proposals is judged and voted on a case-by-case basis. In the event of a material conflict of interest between an individual manager of Avenir and the issuer of a security, this individual manager will refrain from the specific vote. As a separate account manager, Avenir manages a large number of individual client accounts. All accounts will not necessarily hold the same securities. In the cases in which the aggregate value of a security held across all managed accounts is less than $1 million, Avenir does not take responsibility for voting these proxies. In addition, Avenir does not take responsibility for voting proxies for securities which are unsupervised. Further, Avenir generally refrains from voting a proxy if a client no longer holds a position in a security at the time of a company’s meeting. Clients may request to receive proxy materials if they prefer to vote their own proxies. Clients may obtain a copy of Avenir’s Proxy Voting Policies and Procedures and how Avenir voted proxies by contacting us at (202) 659-4427.