Brockenbrough was founded in 1970. Brockenbrough is primarily owned by Austin Brockenbrough III and related family trusts. As of December 31, 2023, our assets under management are approximately $3.8 billion for which we provide investment advisory services. Brockenbrough provides discretionary and non-discretionary investment management services. In limited circumstances and at the request of the client, Brockenbrough will provide various planning services. Brockenbrough provides advice to clients that maintain separately managed accounts, to an affiliated registered investment company (Jamestown Equity Fund) and to affiliated privately offered pooled investment vehicles (“Private Funds”). Clients’ accounts are managed based on stated client investment objectives. The investment objectives of the Private Funds are set forth in their respective organizational and offering documents. Brockenbrough invests clients’ portfolios in, but not limited to, individual equity and fixed income securities, separately managed accounts, mutual funds, exchange traded funds, or limited partnerships. Brockenbrough’s investment management services include:
• Private Wealth Management Services
• Institutional Management Services
• Proprietary Investment Strategies Client Obligations. In performing its services, Brockenbrough shall not be required to verify any information received from the Client or from the Client’s other professionals and is expressly authorized to rely thereon. Moreover, each Client is advised that it remains their responsibility to promptly notify Brockenbrough if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Brockenbrough’s previous recommendations and/or services. Affiliated Private Funds. As discussed below, Brockenbrough is affiliated with several private funds (the “Private Funds”). Brockenbrough may recommend that clients, for whom one or more of these funds is suitable, consider an allocation to the Private Funds. Brockenbrough may earn an incentive allocation from investments in these Private Funds. The terms and conditions for participation in the affiliated funds, including management and incentive fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. Brockenbrough’s clients are under absolutely no obligation to consider or make an investment in a Private Fund. Conflict Of Interest. Because Brockenbrough and/or its affiliates can earn compensation (management fees and incentive allocations) from the Private Funds that may exceed what Brockenbrough would earn under its standard asset-based fee schedule referenced in Item 5 below, the recommendation that a client invest in a Private Fund presents a conflict of interest. No client is under any obligation to become a Private Fund investor. Unaffiliated Private Investment Funds. Brockenbrough may also provide investment advice regarding unaffiliated private investment funds. Brockenbrough may recommend that certain clients, for whom it is suitable, consider an investment in unaffiliated private investment funds. Brockenbrough’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client becomes a private fund investor, the assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Brockenbrough calculating its investment advisory fee. Brockenbrough’s clients are under absolutely no obligation to consider or make an investment in a private investment fund. Private Investment Risks. Private investment 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 fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments, private investment funds do not provide daily liquidity or daily pricing. Each prospective client will be required to complete a subscription agreement, pursuant to which the client shall represent that they are an Accredited Investor Qualified Client and/or Qualified Person and is suitable for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Uncontrollable Event Risk. There is a risk that events beyond our control can cause investment markets, the securities that you may invest in, and your account to lose value or experience unexpected volatility. Terrorist attacks, war, and pandemics are just a few examples of these events, whether actual or anticipated that affects investor attitudes toward the market in general and result in system-wide fluctuations in security prices. Valuation. In the event that Brockenbrough references private investment funds owned by the client on any supplemental account reports prepared by Brockenbrough, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund manager and may be estimated or reported with a lag. If no subsequent valuation post-purchase is provided by the fund’s manager, then the valuation shall reflect the initial purchase amount. If the valuation reflects the initial purchase or value as of a previous date, it is possible that the current value(s) (to the extent ascertainable) could be significantly more or less-than what is shown in the report. The client’s advisory fee shall be based upon the value reflected in the client’s Brockenbrough statement. Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Brockenbrough recommends that a client roll over their retirement assets into an account to be managed by Brockenbrough, such a recommendation creates a conflict of interest if Brockenbrough will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Brockenbrough serves as a fiduciary under the Employee Retirement Income Security Act (“ERISA”), or the Internal Revenue Code, or both. Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, Brockenbrough will generally remain available to provide limited financial planning consulting services as part of its investment management engagement. Unless Brockenbrough is specifically engaged to provide more extensive financial planning services (per the terms and conditions of a separate executed Addendum to this Agreement), the consulting services (to the extent requested) are generally limited to issue spotting and referrals (if requested) to corresponding unaffiliated professionals (i.e., attorney, CPA, insurance agent, etc.) for further review and potential implementation services. At all times, Brockenbrough shall rely on the documentation and/or information provided by the client, shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon, If any such documentation or information is inaccurate or incomplete, the corresponding results or recommendations could be inaccurate or incomplete. Brockenbrough does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Brockenbrough does not prepare legal documents or tax returns, nor does it offer or sell insurance products. As indicated above, to the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.). The client is not under any obligation to engage any such professional(s). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Brockenbrough and/or its representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent, etc.),

recommended or otherwise, and a dispute arises thereafter relative to such engagement, the engaged professional shall remain exclusively responsible for resolving any such dispute with the client. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Brockenbrough, shall be responsible for the quality and competency of the services provided. Wrap/Managed Account Programs. In the event that Brockenbrough is engaged to provide investment advisory services as part of an unaffiliated wrap-fee program, Brockenbrough will be unable to negotiate commissions and/or transaction costs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. In the event that Brockenbrough is engaged to provide investment advisory services as part of an unaffiliated managed account program, Brockenbrough will likewise be unable to negotiate commissions and/or transaction costs. If the program is offered on a non-wrap basis, the program sponsor will determine the broker-dealer though which transactions must be effected, and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. Trade away/Prime Broker Fees. Relative to its discretionary investment management services, when beneficial to the client, individual fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “trade away” and/or prime broker fee charged by the account custodian. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Brockenbrough) would be profitable or equal any specific performance level(s). No Legal or Accounting Services. Neither Brockenbrough, nor any of its representatives, serves as an attorney or accountant, and no portion of Brockenbrough's services should be construed as same. Acknowledgement of Fiduciary Status. In conformity with the requirements of the Department of Labor’s Fiduciary Rule, to the extent that a client is: (1) a participant or beneficiary of a Retirement Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code (the “Code”), with authority to direct the investment of assets in his or her Plan account or to take a distribution; (2) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or, (3) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Code, then we represent that we and our investment adviser representatives are fiduciaries under ERISA or the Code, or both, with respect to any investment advice provided by us or our investment adviser representatives or with respect to any investment recommendations regarding a Retirement Plan subject to ERISA or participant or beneficiary account. Conflicts Relating to Relationships with Clients. Brockenbrough has clients that could be perceived to have the ability to influence our conduct due to the amount of assets they control or their public reputations. In addition, certain of these clients may have owners, employees, board members or trustees (collectively, “client board members”) that separately could be perceived to influence our conduct for these same reasons. As a matter of policy and practice, we do not consider these clients, client board members or investment principals when formulating our investment decisions. Further, we do not collaborate with any of these client board members in any of our investment processes, except that we may consider their thoughts and opinions with respect to the client that they serve. Accrued Interest/Dividends. The market value reflected on periodic account statements issued by the account custodian may differ from the value used by Brockenbrough for its advisory fee billing process. Brockenbrough includes the accrued value of certain month or quarter-end interest and/or dividend payments when calculating client advisory fees, which amounts may not yet be reflected on the custodian statement as having been received by the account. Cash Positions. Brockenbrough treats cash as an asset class. As such, unless determined to the contrary by Brockenbrough, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating Brockenbrough’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Brockenbrough may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Brockenbrough’s advisory fee could exceed the interest paid by the client’s money market fund. Margin Accounts. Brockenbrough does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client determine to use margin, Brockenbrough will include the entire market value of the margined assets when computing its advisory fee. Accordingly, Brockenbrough’s fee shall be based upon a higher margined account value, resulting in Brockenbrough earning a correspondingly higher advisory fee. As a result, the potential of conflict of interest arises since Brockenbrough may have an economic disincentive to recommend that the client terminate the use of margin. The use of margin can cause significant adverse financial consequences in the event of a market correction. Brockenbrough’s Chief Compliance Officer, David Lyons, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Other Assets. A client may hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Brockenbrough. Generally, with potential exceptions, Brockenbrough does not/would not recommend nor follow such securities and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. If/when liquidated, it should not be assumed that the replacement securities purchased by Brockenbrough will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Brockenbrough) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client or which Brockenbrough does not maintain custodian access and/or trading authority; and, hold other securities and/or own accounts for which Brockenbrough does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by Brockenbrough, Brockenbrough shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent; (3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by Brockenbrough; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Brockenbrough’s Chief Compliance Officer, David Lyons, remains available to address any questions regarding the above.