A. Firm Information Sterling Investment Management, LLC (the “Registrant”) is an SEC-registered investment advisor. Founded in November 1995, we provide sophisticated portfolio management services to high-net- worth individuals, endowments, foundations, and corporations located throughout the United States. John H. Payne, CFA, is the founding member and Chief Investment Officer of Sterling Investment Management, LLC. Sterling is organized as Limited Liability Company in the State of Arizona. The company has been in continuous operation since inception. B. Advisory Services Offered Introduction Sterling Investment Management, LLC (“Sterling,” “the Registrant," “the Firm”, “our”, or “we”) is an independent research-driven investment management boutique. Using a meticulous security analysis framework rooted in value investing, we provide our clients with long-term investment strategies designed to complement their unique financial goals by utilizing our structured approach to portfolio management. Our investment portfolios predominantly consist of individual equity, fixed income, and alternative securities. Investment Management Sterling provides clients with ongoing investment advisory services on a fee-only basis. Portfolios may include the common equity, preferred stock, and debt of domestic and international companies, municipal and private-placement debt securities, REITs, MLPs, and alternative assets. In addition, Exchange Traded Funds (ETFs) may be implemented for risk hedging purposes, or to satisfy unique client investment objectives. Each portfolio is individually customized to align with our clients’ financial goals. All security selection and asset allocation decisions are predicated upon each client’s risk tolerance, time horizon, and unique financial and investment goals. Portfolios

are constructed with the following underlying goals: maximize total returns while assuming an appropriate level of risk. Sterling approaches securities analysis from the perspective of a business owner; the firm seeks to hold positions in businesses that have high probabilities of generating attractive returns on invested capital over a long-term time horizon. Investment management services are performed on a discretionary basis. Investment guidelines and restrictions must be provided to us in writing. For more information on Sterling’s discretionary and non-discretionary asset management practices see Item 16 – Investment Discretion. Financial Planning Sterling provides consultation services involving the analysis of a client’s financial situation. This commonly takes the form of a financial plan but may solely focus on a topic such as retirement planning, college planning, or cash flow analysis. In preparing a financial plan for a client, Sterling gathers information through personal interviews and document requests. Should a client implement the recommendations contained in the financial plan, Sterling suggests that the client work closely with his or her attorney and/or accountant and share the recommendations. Consulting Services may be charged on an hourly basis of $500/hr. or as a flat fee but are usually covered under the Investment Advisory Fee for clients that have assets under our management. C. Wrap Fee Programs The Registrant does not place client assets with any wrap fee programs. All management services are performed by the Registrant on behalf of its clients. D. Assets Under Management As of March 20, 2024, Sterling’s Assets Under Management are as follows: Discretionary Assets $371,202,026 Non-Discretionary Assets $0 Total Assets $371,202,026