Adalta Capital Management LLC (“Adalta,” the “Adviser” or the “Firm”) is a SEC–registered investment adviser that provides asset management services to individual, family office and institutional clients primarily through separately managed accounts. Adalta seeks long-term capital appreciation for its clients by investing in securities of companies with sound, long-term fundamentals based on a value-driven investment discipline. Adalta also seeks such appreciation through allocation to select third-party managers. Principal owners David E. Rappa and Zoë A. Vlachos and veteran investment manager Peter A. Vlachos are responsible for the day-to-day operations of the Firm. The Firm, formed in 2016, is a limited liability company organized under the laws of the state of Delaware. This brochure describes primarily the services that Adalta provides to separate account clients. Adalta also renders advice to private investment funds. The services Adalta renders to those funds are described in the respective fund offering documents. Separate account portfolios are customized for taxable and tax-exempt investors. Investment strategies for each client are developed after completing an examination of the client's financial condition and establishing the client's investment objectives. Such objectives and needs are defined at the onset of a relationship and periodically reviewed thereafter on an ongoing basis. Adalta manages the investment and reinvestment of its clients’ assets including making decisions with respect to all purchases and sales and other transactions of securities. Most accounts are discretionary, meaning the Firm makes and executes investment decisions about particular securities for the client’s account without getting the client’s prior permission. As of March 28, 2024, the Firm had approximately $258.0 million in regulatory assets under management, $254.3 million on a discretionary basis and $3.7 million on a non- discretionary basis. Clients that determine to engage Adalta on a non-discretionary investment advisory basis must be willing to accept that Adalta cannot affect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Adalta would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Adalta will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. The structure of each portfolio is determined according to the specific objectives and risk tolerance of the client. Equity investments are made typically in financially strong companies which appear to have attractive prospects for growth in earnings and dividends. High- quality, fixed-income securities are used to provide a basic return. Portfolios are comprised primarily of publicly traded U.S. domestic securities as well as foreign securities. These securities include: exchange listed shares and shares traded over-the-counter; securities convertible into or exercisable for common stocks; preferred stocks; warrants; fixed and floating rate bonds; U.S. Treasuries; and municipal bonds. Securities in which an account is invested can be restricted by the client by sector, industry or company or by type of security should a client want or need to do so for any reason; such restrictions are either incorporated into the investment policy statement for the account or indicated separately in writing to the Firm. Clients should be aware that imposing restrictions on an account may cause the account to perform differently than an account managed without such restrictions. A few client accounts, generally testamentary trusts or the equivalent, limit applicant purchases to securities contained on an approved list. Such list is created and maintained by the client and provided to Adalta on a regularly scheduled basis. Typically, a taxable account strategy encompasses the purchases of marketable securities for long-term holding. Tax-free accounts, while generally seeking to invest for long term appreciation, can become involved with marketable security purchases with short- term potential. The Firm does not make short sales or utilize margin debt (unless specifically directed by the client). The Firm does not utilize options in any of its investment strategies with the exception of the periodic purchase of warrants for client accounts. At any specific time, depending upon perceived or anticipated market conditions or events (there being no guarantee that such anticipated market conditions or events will occur), Adalta may maintain cash positions in accounts for defensive purposes. Adalta may provide investment advice regarding affiliated and/or unaffiliated private funds. Adalta, on a non-discretionary basis, may also recommend that certain qualified clients consider an investment in affiliated and/or unaffiliated private funds. Adalta’s role relative to the private funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an investor in an unaffiliated private fund, the amount of assets invested in the issuance shall be included as part of “assets under management” for purposes of Adalta calculating its investment advisory fee. Adalta’s clients are under absolutely no obligation to consider or make an investment in a private fund(s). The recommendation by Adalta that a client invest in a private fund sponsored by an affiliated entity of Adalta presents a conflict of interest, as Adalta’s interest in the affiliated entity may provide an incentive to recommend investment in the affiliated entity based on funds received, rather than on a particular client’s

need. In an attempt to mitigate this conflict, Adalta will not include the value of such affiliated private funds in calculating Adalta’s advisory fee. Clients invested in affiliated private funds will only be subject to the private fund’s management fee, which is typically performance-based, as described in Item 6 below. No client is under any obligation to invest in the affiliated entity or any other private offering. Adalta’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Private funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each issuance’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a subscription agreement, pursuant to which the client shall establish that he/she is qualified for investment in the issuance and acknowledges and accepts the various risk factors that are associated with such an investment. In the event that Adalta references private funds owned by the client on any supplemental account reports prepared by Adalta, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the issuer. If no subsequent valuation post-purchase is provided by the issuer, the valuation shall reflect the initial purchase price (and/or a value as of a previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). From time to time the Firm evaluates initial public offering investments in the same manner it assesses other equity investments – portfolio managers look for attractively priced shares of companies with high quality management, finances and business prospects. Shares in initial public offerings will be allocated to client accounts with regard to: (i) a client's risk tolerance; (ii) the appropriateness of the investment for a given portfolio; and, (iii) the availability of adequate funds to purchase shares in the equity portion of the account. If the Firm anticipates the purchase of shares in an initial public offering may be for less than one year, it may restrict the purchase of shares to tax-exempt accounts to avoid adverse tax treatment of short-term capital gains. Adalta does not have any direct or indirect affiliation with any broker, commercial bank, investment bank or other organization giving investment advice or soliciting securities orders. Neither the Firm, nor any of its representatives, serves as an attorney, accountant, or insurance agent, and no portion of the Firm’s services should be construed as the services of such professionals. Although the Firm tries to remain current with regard to each client’s financial situation, each client is advised that it is the client’s responsibility to promptly notify Adalta if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s previous recommendations and/or services. As an investment adviser, the Firm has a duty to protect the privacy of client information. Confidential client information will not be disclosed to third parties except as necessary to provide the services that the client has requested or authorized. A copy of the Firm’s privacy policy is sent to existing clients annually and upon request. Adalta has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Adalta will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, the portfolio’s securities allocations, investment performance, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Adalta determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Adalta will be profitable or equal any specific performance level(s). In performing its services, Adalta shall not be required to verify any information received from the client or from the client’s other designated professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Adalta if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Adalta’s previous recommendations and/or services. While Adalta may recommend allocating investment assets to mutual funds that are not available directly to the public, Adalta may also recommend that clients allocate investment assets to publicly-available mutual funds that the client could obtain without engaging Adalta as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds without engaging Adalta as an investment adviser, the client or prospective client would not receive the benefit of Adalta’s initial and ongoing investment advisory services.