Kabouter Management, LLC (“Kabouter,” “we,” “us,” “our,” or the “firm”) is a registered investment adviser based in Chicago, Illinois. Kabouter is organized as a Delaware limited liability company and has been providing investment advisory services since 2003. Kabouter is a wholly- owned subsidiary of Kabouter Holdings, Inc., a Delaware corporation. Kabouter Holdings is principally owned and controlled by Peter Zaldivar and Marcel Houtzager, the founders and principals of Kabouter. Kabouter has completed the Minority Owned Business (MBE) Certification Program with the City of Chicago and has been granted certification as a Minority Business Enterprise under the Business Enterprise Program for Minorities, Females and Persons with Disabilities with the State of Illinois. Overview Kabouter offers its investment advisory (and sub-advisory) services to a variety of client types, including privately offered pooled investment vehicles organized as domestic limited liability entities and Cayman Islands exempted companies (each, a “private fund”), separately managed accounts (each, a “separately managed account”), and other investment vehicle types (together with the private funds and the separately managed accounts, “clients”). Kabouter currently offers investment strategies focused primarily on the equity securities of micro, small, and/or mid-sized companies located outside the United States, including in emerging markets. Private Funds Kabouter serves as the investment manager, investment adviser, or sub-adviser to private funds. Kabouter also provides advisory services to private funds operated by unaffiliated advisers on a sub-advisory basis. The primary investment objective of each private fund is to seek to provide investors with an above-average long-term return from a portfolio invested primarily in equity securities of smaller or mid-sized companies located outside the United States. Each private fund has different investment features which may include varying levels of management fees and/or performance compensation, withdrawal rights, investment guidelines, investment minimums, investor qualification standards, and liquidity terms. This Brochure should not be considered an offering document for the private funds and investors should refer to a specific private fund’s offering memorandum or organizational documents for a complete description of that fund, including its types of investments and strategies, risks, conflicts of interest, fees, and expenses. We tailor our investment advisory services for a private fund to such fund’s overall investment program, and not to the needs of any underlying investor therein. The governing documents for the private fund and/or the investment advisory agreement, if applicable, govern Kabouter’s advisory services provided to the private fund. Aside from private funds where Kabouter serves as a sub-adviser, the governing documents generally provide that the private fund may be dissolved upon Kabouter’s dissolution, withdrawal from the private fund, or resignation as the manager or investment adviser.

The private funds are exempt from registration as an investment company under either Section 3(c)(1) or 3(c)(7) of the Investment Company Act of 1940, as amended (the “Company Act”). Separately Managed Accounts Kabouter also serves as adviser or sub-adviser to certain separately managed accounts. These customized offerings generally follow the same portfolio construction process as the private funds, however, we may customize an investment portfolio in accordance with the client’s risk tolerance and investment objectives, including reasonable restrictions on investing in certain securities. For example, clients may specify that investments in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrict or prohibit transactions in the securities of a specific industry or issuer. Once we construct an investment portfolio, we monitor the performance of each client’s portfolio on an ongoing basis and will rebalance the portfolio as necessary due to changes in market conditions. From time to time, Kabouter may provide advisory services, including on a sub-advisory basis, to other investment vehicle types, including collective investment trusts. Collective investment trusts are for the collective investment of assets of participating tax qualified pension and profit-sharing plans and related trusts, and governmental plans. Investment Advisory Agreements Our investment advisory (and sub-advisory) agreements contain an authorization by which clients grant us discretion to make purchases and sales for their accounts without requiring us to obtain their consent or approval prior to each transaction, to select the types and amounts of securities that we buy or sell for their accounts, the broker or dealer we use to effect such transactions and the commission rates paid. As noted above, certain clients may specify their investment objectives and guidelines, direct brokerage, select their portfolio strategy, and impose certain restrictions or investment parameters. Imposing account restrictions may adversely or favorably affect account performance compared to unrestricted accounts we manage. In the event an investment advisory (or sub-advisory) agreement is terminated, clients will receive a prorated refund of any fees paid in advance. If clients pay fees at the end of a billing period in arrears, they will incur a pro rata charge for services rendered prior to the termination of the agreement, which means they will incur advisory fees only in proportion to the number of days in the billing period for which they are a client. Assets Under Management As of December 31, 2023, the firm’s regulatory assets under management were approximately $876,673,683. We do not currently manage any assets on a non-discretionary basis. Performance Kabouter reports its performance in compliance with the Global Investment Performance Standards (GIPS). We completed the exercise of having our firm verified by Adviser Compliance Associates, LLC (ACA), an independent third party.