Leeward Investments, LLC ("Leeward", "we" and/or "the Firm") is a SEC-registered investment adviser with its primary office located in Boston, Massachusetts. We are a member managed Massachusetts Limited Liability Company owned 100% by our employees and led by R. Todd Vingers, President, who owns more than 25% of the Firm. Leeward became 100% employee owned as of March 1, 2022 when LMCG Investments, LLC (“LMCG”) spun- off a portion of its business and those employees of LMCG responsible for managing this business, including R. Todd Vingers, became employees of Leeward. Leeward has no affiliates. See Item 10 for additional information about our financial industry affiliations. The following paragraphs describe the services offered by the Firm. As used in this Brochure, the words "our" and "us" also refer to the Firm. The words "you," "your" or "client" refer to our clients and prospective clients. Other terms may be defined later in this Brochure as well. Advisory Services Our Small Cap, Mid Cap and Small-Mid Cap Value Strategies apply a classic value investment style focusing on solid small cap and mid cap companies, respectively, whose stock we believe is temporarily out of favor in the market. The strategies emphasize companies with higher returns on capital, free cash flow, and strong balance sheets. These companies often dominate a particular industry niche. Generally, these industries have significant barriers to entry and, as a result, are able to perpetuate a higher return on capital over time. The strategies emphasize strong risk-adjusted returns by taking modest bets and focusing not only on upside but also on limiting the downside. Leeward believes that responsible investment practices incorporating an assessment of environmental, social and governance (ESG) factors, adds sustainable value for our investors by mitigating risk and positively influencing long-term financial performance, consistent with our fiduciary duty. Our firm has adopted a formal ESG Policy to define our approach to integrating the considerations of ESG factors into our investment analysis and decision making processes. Additional Advisory Services We act as a sub adviser to several registered mutual funds. In almost all such engagements we provide professional investment advisory services on a discretionary basis. Investments for advised and sub advised mutual funds are managed in accordance with each fund's investment objective, strategies, and restrictions and they are not tailored to the individualized needs of any particular fund investor. Wrap Fee/Sponsored Programs: We participate in wrap fee advisory

programs sponsored by unaffiliated advisors, broker-dealers, and banks (collectively, the "Sponsors"). Under these programs, the Sponsors are responsible for selecting or facilitating the selection of advisers, pre- screening client suitability, most aspects of direct client servicing, and operations. We provide separate account advisory services with various investing strategies to clients of the Sponsors. Trades are generally placed with brokers designated by the Sponsors, although we may use other brokers. See Item 12 for information about how directed brokerage affects management of client accounts. In determining whether to establish a wrap fee program account, a client should be aware that the overall cost to it may be higher or lower than it might incur by engaging us directly. Model Portfolio Programs: We provide model portfolios for particular strategies to clients that are investment advisers, mutual funds, platforms and other similar aggregation entities ("Model Clients"). These Model Clients use the recommendations comprising our model portfolios as a basis for investment strategies that they offer to 5 LEEWARD INVESTMENTS LLC FORM ADV PART 2A – March 26, 2024 their clients or investors. We do not create our model portfolios for the individual or particular needs of their clients or investors, or any other individual, but rather provide what we believe is an appropriate allocation and weighting of securities for a given asset class. Our Model Clients have discretion to determine how and when to implement our model portfolios and our changes to these portfolios and we have limited or no trading authority in such arrangements. Client Restrictions Clients invested in our separately managed accounts may place investment restrictions (as to individual securities/tickers, positions, industries, cash, etc.) subject to our approval. When we invest the assets of those accounts in ETFs, our ability to avoid investments in a specific company or industry, in accordance with a client's restrictions, may be fully or partly curtailed. When investing in ETFs we do not look through the underlying holdings for client-specific restrictions. We inform these clients of the impact of investment restrictions. See Item 16 for additional information on client- imposed restrictions. Assets Under Management As of December 31, 2023, Leeward had approximately $2.8 billion in assets under management. Discretionary assets under management totaled $2.1 billion; non-discretionary assets under management totaled $651 million.