ARNHOLD LLC

Arnhold LLC Form ADV Part 2A – Disclosure Brochure March 25, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Arnhold LLC (“Arnhold” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (212) 651-3700 or at info@arnholdllc.com. Arnhold is a registered investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply a certain level of skill or training. This Disclosure Brochure provides information about Arnhold to assist you in determining whether to retain the Advisor. Additional information about Arnhold is available on the SEC’s website at www.adviserinfo.sec.gov. Arnhold LLC 1370 Avenue of the Americas, 31st Floor New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 Email: info@arnholdllc.com  Item 2 – Material Changes Since the last annual update of our Disclosure Brochure on March 27, 2024 we made updates to Item 10 regarding certain arrangements with First Eagle Investment Management, LLC (i.e., a client fee rebate arrangement and a trustee compensation arrangement). The Advisor does not consider these arrangements to be material to the conduct of its advisory business. However, the Advisor has determined to nonetheless include these arrangements in its Brochure. In addition, we updated the Brochure for various non-material changes to provide clarification and additional information (including a discussion of cash balances in Item 8). Page 2 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................1 Item 2 – Material Changes ......................................................................................................................................2 Item 3 – Table of Contents .....................................................................................................................................3 Item 4 – Advisory Services .....................................................................................................................................4 Item 5 – Fees and Compensation ..........................................................................................................................5 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................................7 Item 7 – Types of Clients ........................................................................................................................................7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...........................................................7 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 Item 12 – Brokerage Practices ............................................................................................................................ 13 Item 13 – Review of Accounts ............................................................................................................................. 16 Item 14 - Client Referrals and Other Compensation ......................................................................................... 16 Item 15 – Custody ................................................................................................................................................. 16 Item 16 – Investment Discretion ......................................................................................................................... 17 Item 17 – Voting Client Securities ...................................................................................................................... 17 Item 18 – Financial Information........................................................................................................................... 17 Privacy Policy ....................................................................................................................................................... 19 Page 3 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Item 4 – Advisory Services A. Firm Information Arnhold LLC (“Arnhold” or the “Advisor”) is a Delaware limited liability company and has been registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”) since 2017. Mr. John P. Arnhold, Ms. Christa M. Dorrego, and Mr. Timothy L. Tabor are the Founders and Managing Directors of Arnhold. Arnhold Management LLC is the managing member of Arnhold. Mr. John P. Arnhold is the managing member of that entity and principal owner of Arnhold. B and C. Advisory Services Offered Arnhold is an investment advisory firm dedicated to preserving and enhancing the wealth of its clients. Arnhold offers investment management and related advisory services primarily to private investment funds, institutional accounts and high net worth individuals (each referred to as a “Client”). These services include: Family Governance: Assisting with creation of a family communication process and governance system. This can include developing a family mission statement, education program and assisting with family meetings. Investment Management Services: Working with Clients to develop an asset allocation strategy. This includes investment manager selection, recommendation and oversight, as well as ongoing portfolio review and reporting. We provide discretionary investment management services. Discretionary accounts are managed in accordance with a Client’s investment guidelines. For separately managed accounts, Clients can impose certain restrictions on securities or types of securities, subject to acceptance by Arnhold. Philanthropic Strategies: Assisting in developing a philanthropic mission statement and creating philanthropic structures and planning. Tax Services: Coordination of tax related issues between the Client and Client’s tax preparers; however, the Advisor does not provide specific tax advice. Clients should consult their own tax advisors. Document Management: When requested, maintaining an inventory of family documents, including organizational documents for entities, summary of significant assets, key contact lists, investment documents, and financial reports. Expense Management: Assisting with payment of certain vendor bills and expense reporting. Arnhold acts as the investment manager providing discretionary investment management services to affiliated private investment funds (“Private Funds”). The Private Funds are generally organized or “sponsored” by Arnhold or an affiliate, and Arnhold or an affiliate typically acts as the managing member or general partner of the Private Funds. The Private Funds are typically organized as domestic limited partnerships, limited liability companies, and non-US companies and are not registered under the Investment Company Act of 1940. Interests or shares of the Private Funds are not registered under the Securities Act of 1933 and are sold on a private placement basis. Certain Clients invest in Private Funds and separate accounts managed by Arnhold and in investment funds and separate accounts managed by third party investment managers (including First Eagle Investment Management). See, also “Item 10 – Other Financial Industry Activities and Affiliations”. These include mutual funds, exchange traded funds and private investment funds managed by advisers not affiliated with Arnhold. Arnhold typically has broad and flexible investment authority with respect of allocating Client assets. Accordingly, the Clients’ assets (including assets invested or traded by third party managers) can at any time be invested in long or short positions in other securities and instruments, including U.S. or non-U.S. publicly traded or privately issued common stocks, preferred stocks, stock warrants and rights, cash and cash equivalents, corporate or sovereign debt, bonds, notes or other debentures or debt participations, convertible securities, swaps, options, Page 4 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  commodities, commodity contracts, commodity futures, currencies, financial or other futures contracts and options thereon, forward contracts and other derivative instruments. Arnhold also manages an investment strategy focused on investing mainly in listed companies that do business in the Pacific Rim countries. This strategy can also invest a portion of its assets in securities and other assets of U.S. and non-U.S. issuers and many hold unlisted securities and debt instruments and trade in options, commodities, currencies and other assets. Investment strategies used by Arnhold and third party underlying investment managers can utilize leverage to achieve their investment objectives. Third party managers appointed by Arnhold on behalf of a Client are responsible for making their own investment decisions. Where Arnhold is the investment manager to a Private Fund, Arnhold provides discretionary investment advice consistent with the investment objectives, policies, restrictions and investment program described in the offering documents for the Private Fund and does not tailor such advice to investors in the Private Fund. Arnhold has the overall responsibility for implementing the investment strategies of each Private Fund. D. Wrap Fee Programs Arnhold does not participate in wrap fee programs. E. Assets Under Management As of December 31, 2024, Arnhold manages approximately $5,238,706,885 in discretionary assets. Clients can request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The specific way fees are charged by Arnhold is established in each client’s written agreement with Arnhold. For separate account management, Arnhold typically charges an annual fee based on a percentage of the value of Client assets under management. Investment management fees for separately managed accounts are typically based on the following schedule: Assets Under Management ($) First $20,000,000 Next $30,000,000 (Up to $50,000,000) Over $50,000,000 Annual Rate (%) 0.75% 0.50% 0.25% Unless a different arrangement is made with a Client, Arnhold bills its management fees as of the end of each month in arrears based on the month-end value of the assets, including cash and cash equivalents but excluding certain assets. Management fees are generally deducted from Client accounts by the Custodian. However, Clients can elect to be billed directly for fees. Management fees are typically prorated for partial periods. (Arnhold may, in its discretion, waive advisory fees as noted below.) Arnhold calculates its fee for separately managed accounts by applying the applicable fee schedule to the value of the assets of the Client account. In general, management fees are based on a valuation of assets by the Client’s Custodian (or the fund’s administrator, in the case of Private Funds). If your account has insufficient assets, we have the authority to sell securities in your account in order to make cash available for management fee payment without notification to you. The obligation to pay management fees may limit your ability to request liquidation of securities to withdraw cash from your account. In certain cases, including with respect to private investments or investments where a third-party price is not obtainable, the Advisor will use its fair valuation procedures to determine a value for the investment. Since the Advisor’s compensation is generally based on the net asset value of an account, a conflict arises when the Advisor rather than a third-party is valuing the assets held in an account. To mitigate that potential conflict, our policies require our pricing personnel to follow specific steps when calculating the fair value of a security. Page 5 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Separate Accounts can be subject to minimum annual fees in Arnhold’s discretion. Certain Clients or strategies do not have standard fee schedules but are individually negotiated based on a variety of factors including, but not limited to, prior contractual relationships and/or historical fee schedules. We reserve the right to negotiate fees and we manage certain accounts without an advisory fee, such as accounts of employees, employees’ affiliates’ or their relations. You will pay more or less than other clients depending on certain factors, such as account size, if you have another account with us, the fee structure we have agreed to, or if we negotiate different fees with you. Our standard investment management agreement may be terminated by either party giving notice to the other consistent with the terms set forth in the client’s agreement with Arnhold. Based upon particular facts and circumstances, Arnhold, in its sole discretion, permits “family billing” or “householding” arrangements where the account values of related accounts are combined for the purpose of reducing the overall fees paid by the account. Arnhold may modify, amend or terminate any or all of these arrangements at any time in its sole discretion. Because “family billing” would result in the client paying lower fees to Arnhold, this creates an incentive for Arnhold to limit “family billing” arrangements or to combine accounts in a manner that limits the reductions of fees. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which are incurred by the Client. Contracts with clients typically include a provision for indemnification to Arnhold under certain circumstances. Arnhold can change its fee structure at any time. For Private Funds, the applicable fees and expenses are described in each private fund’s investment management agreement, subscription agreement, or other governing or offering documents. Arnhold also has performance-based fee arrangements with certain Clients. See Item 6 below for additional disclosures regarding performance-based compensation. B. Other Fees and Expenses Clients typically incur certain fees or charges imposed by third parties, other than Arnhold, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian and executing broker-dealer (if different). The investment management fee charged by Arnhold is separate and distinct from these custody and execution fees. Separate account assets that are invested in Private Funds (i.e., funds managed by Arnhold) will not be subject to two levels of advisory fees. Either the advisory fee associated with the underlying Client account will be waived or reimbursed or Arnhold will waive or reduce an amount equal to the pro‐rata portion of the management/advisory fee that Arnhold (or its affiliates) earns from the Private Funds. However, separate account assets that are invested in Private Funds will incur other fees and expenses associated with their investments in these funds. With respect to Private Funds and other Clients (including separately managed accounts) that invest in funds (including private investment funds, mutual funds and ETFs) or third‐party separate accounts managed by investment advisers other than Arnhold, in addition to the fees payable to Arnhold, investments in these non- affiliated funds or separate accounts will result in Clients paying asset‐ based and potentially performance‐based fees to a third‐party. All fees paid to Arnhold for investment management services are separate and distinct from the fees charged by the funds or separate accounts managed by investment managers not affiliated with Arnhold. Therefore, these Clients will generally pay two levels of fees; one layer of fees at the fund or separate account managed by the investment manager not affiliated with Arnhold level and one layer of fees to Arnhold or its affiliates. In addition, investments in these funds or separate accounts will result in other fees and expenses associated with such investments. These expenses will generally include brokerage and other transaction related costs, and the fees and expenses of service providers to these funds, such as custodians, transfer agents, administrators, valuation agents, auditors and counsel. In addition, all fees paid to Arnhold for investment management services are separate and distinct from the expenses charged by mutual funds, private funds and exchange-traded funds to their shareholders, if applicable. Page 6 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  These fees and expenses are described in each fund’s offering document. A Client is able to invest in these products directly, without the services of Arnhold. Clients incur certain transaction fees and other expenses including charges imposed by custodians, brokers, and other third parties such as fees charged by managers, custodial fees, brokerage commissions, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Also, certain US and non-US trading markets impose additional charges and penalties for trade settlement failures that will result in additional transaction costs to Clients. These charges, fees and commissions are exclusive of and in addition to Arnhold’s fee. Private Funds and other clients bear other expenses, in addition to the fees and expenses described above, including: (1) costs and expenses with respect to any workout, restructuring, recapitalization, amendment, waiver or consent with respect to certain investments and the protection or enforcement of rights thereunder; (2) costs and expenses in connection with the acquisition of director and officer insurance; (3) due diligence, legal, custodial, accounting and related costs and expenses; (4) pricing service costs incurred in valuing investments; (5) expenses incurred in obtaining credit ratings on investments; (6) all taxes imposed on a client and all litigation expenses (and any judgments or settlements paid in connection therewith) and other extraordinary expenses; (7) the costs of forming and maintaining any alternative investment vehicle and (at the discretion of the general partner or manager of a client) the costs of maintaining any other pooled investment vehicle through which to invest; (8) insurance costs; (9) interest and commitment fees payable in connection with credit facilities made available to a client; (10) fees of outside auditors and tax preparers and the costs of preparation of the books and records and tax returns of a client, including periodic reports to limited partners, and fund administration service provider expenses; (11) costs of liquidation and termination of a client; (12) all other costs incurred in connection with the administration of a client; (13) any other expenses actually incurred on behalf of a client and paid by Arnhold in connection with the management of certain investments; and (14) certain other fees and expenses that authorized under a fund’s governing documents or account documents. In addition, Arnhold may enter into side letter arrangements with certain investors in Private Funds, in which Arnhold grants these investors different or preferential terms than other investors in Private Funds. Item 6 – Performance-Based Fees and Side-By-Side Management Arnhold charges performance-based fees – that is, fees based on a share of capital gain or capital appreciation of the assets of a Client – in connection with certain Client accounts, including Private Funds. There are potential conflicts of interest that arise due to the side-by-side management of fixed fee accounts with performance fee accounts, as there is an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. In addition, performance-based fee arrangements can create an incentive for Arnhold to recommend riskier or more speculative investments than those which would be recommended under a different fee arrangement. A similar conflict can arise from certain Client accounts paying higher asset-based fees than other accounts or accounts containing assets owned by Arnhold, its employees, or its owners and their affiliates. To manage those potential conflicts, Arnhold has adopted a number of compliance policies and procedures, including a Code of Ethics, a Compliance Manual, and trade allocation policies that seek to reasonably ensure that investment opportunities are allocated fairly among clients. Arnhold does not consider fee structures in allocating investment opportunities. Item 7 – Types of Clients Arnhold offers investment management services primarily to private investment funds, institutional accounts and high net worth individuals and their affliated entities. Arnhold generally requires minimum account sizes, which are based on mandate and type. Arnhold reserves the right, in its sole discretion, to waive or change investment minimums in certain circumstances. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Page 7 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  A. Methods of Analysis Arnhold primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from Arnhold is derived from numerous sources, including financial reports, prospectuses, and press releases of issuers, third-party research materials, media reports, and databases. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that can indicate the overall strength and financial viability of the entity being analyzed. We consider a wide range of factors in our risk analysis and long-term outlook of a company or issuer, and the value of their securities. Further, our investment process seeks to identify and value various factors, some of which are considered environmental, social and corporate governance (ESG) factors, that may have a material impact on the investment risk and return profile of our investments. As a general rule, we will not exclude any particular investment based on ESG criteria alone. Assets are deemed suitable if they meet certain criteria to indicate that they are trading in the market at a discount to their economic value. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. As noted above, for certain Client accounts Arnhold invests Client assets in underlying funds and/or separately managed accounts managed by third party investment managers. In reviewing investment opportunities for these Clients, Arnhold conducts due diligence and research on the underlying funds and the investment managers to satisfy itself as to the suitability of the investment manager and the investment terms associated with the underlying fund, if any. Arnhold allocates and reallocates these Clients’ assets among underlying funds and third- party investment managers based on its knowledge and experience to assess the investment managers’ capabilities and to determine what Arnhold believes is an appropriate allocation to various investment sectors and styles. With respect to underlying funds and third-party investment managers, Arnhold evaluates investments based on some of the information listed above and a variety of other factors, including the investment managers’ investment performance, discipline and philosophy, discussions and meetings with investment managers, ownership structure, and reviews of the underlying funds’ operations and the underlying funds’ and investment managers’ service providers. B. Risk of Loss Investments in securities and other financial instruments involve risk of loss that investors must be prepared to bear. Below are certain risks associated with the strategies discussed above. This is a summary only. The specific risks applicable to a client will depend upon various factors. Private Fund investors should refer to the particular fund’s offering document for more detailed explanation of risks. Investors or potential investors should be aware that an investment in a Private Fund or Arnhold separately managed account is not intended to provide a complete investment program. Arnhold and third-party investment managers can use investment techniques such as margin transactions, short sales, option transactions, forward and futures contracts, and other derivatives trading, which can increase the risk of losses. There can be no guarantee that Arnhold’s or any third- party investment manager’s investment program will be successful, and investment results can vary substantially over time. Arnhold does not have any responsibility for, involvement with or control over any third-party investment manager’s investments or other activities. Following are some of the risks associated with the Advisor’s strategies: Market Risk The value of a client’s holdings will tend to fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. Non-U.S. Investment Risk Non-U.S. investments often involve special risks not present in U.S. investments that can increase the chance of losing money. These risks include risks associated with non-U.S. custodians and depositories and changes in currency exchange rates. In addition, non-U.S. investments at times are subject to less politically and Page 8 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  economically stable environments with a greater likelihood of abrupt changes to government regulation than in the U.S. Emerging Market Risk Emerging markets are riskier than more developed markets because they tend to develop unevenly and may never fully develop. Investments in emerging markets can be considered speculative. Performance Fees Arnhold and its affiliates and third-party investment managers receive performance‐based fees or allocations. These performance‐based fees and allocations can create incentives for Arnhold and the third-party investment managers to make more risky or speculative investments than they would otherwise make. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings can result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Cash Balances Typically, a portion of a Client’s account will be held as cash and cash equivalents. Holding a portion of a Client’s assets in cash and cash equivalents (including money market funds) is based on a particular Client’s cash needs or the Advisor’s determination to have an allocation to cash and cash equivalents as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to seek to provide for asset protection during periods of volatile market conditions. The cash and cash equivalents (including money market funds) in a Client’s account will be subject to Arnhold’s investment advisory fees unless otherwise agreed upon. A Client may experience negative performance on the cash and cash equivalents portion of the Client’s portfolio if the investment advisory fees charged are higher than the returns the Client receives from the cash and cash equivalents. Private Investment Funds Risk Private investment funds are not registered under the Investment Company Act of 1940 and are therefore not subject to the regulatory requirements it imposes. An investment in a private fund involves risks not typically associated with traditional investment funds. These risks include limitations on transfers, valuation of the underlying investments and transparency with respect to the fund’s underlying investments. These funds are not readily marketable and have limited liquidity. Japan Risk The Japanese economy is heavily dependent upon international trade and may be subject to considerable degrees of economic, political and social instability, which could negatively affect the relevant strategies. Japan has also experienced natural disasters, such as earthquakes and tidal waves, of varying degrees of severity, which also could negatively affect the investment strategy focused on investing in companies that do business in the Pacific Rim. Gold and Commodity Risk Exposure to gold and other commodities may subject a portfolio to greater volatility than investments in traditional securities. Prices of gold-related issues are susceptible to changes to U.S. and non-U.S. interest rates, taxes, currency, mining laws, inflation, and various other market conditions. Value Investment Strategy Risk Page 9 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  An investment made at a perceived ‘‘margin of safety’’ or ‘‘discount to intrinsic or fundamental value’’ can trade at prices substantially lower than when an investment is made, so that any perceived ‘‘margin of safety’’ or ‘‘discount to value’’ is no guarantee against loss. ‘‘Value’’ investments, as a category, or entire industries or sectors associated with such investments, may lose favor with investors as compared to those that are more ‘‘growth’’ oriented. In such an event, a client’s investment returns would be expected to lag relative to returns associated with more growth-oriented investment strategies. Investing in or having exposure to ‘‘value’’ securities presents the risk that such securities may never reach what the Advisor believes are their full market values. Investment Company and ETF Risk To the extent clients (including Private Funds) invest in investment companies, including money market funds and exchange-traded funds (ETFs), their portfolios’ performance will be affected by the performance of those investment companies. Investments in investment companies are subject to the risks of the investment companies’ underlying investments. In addition, clients will pay a proportional share of the fees and expenses of the investment companies and ETFs in addition to their own fees and expenses and, as a result, clients will be subject to two layers of fees and expenses. Investments in ETFs are subject to a variety of risks, including risks of a direct investment in the underlying investments that the ETF holds. For example, the market value of the ETF may differ from the value of its portfolio holdings because the market for ETF shares and the market for underlying securities are not always identical. Also, ETFs that track particular indices typically will be unable to match the performance of the index exactly due to the ETF’s operating expenses and transaction costs, among other things. Credit Risk Credit risk is the risk that the issuer of a bond or other instrument will not be able to make payments of interest and principal when due. Changes in an issuer’s credit rating or the market’s perception of an issuer’s creditworthiness may also affect the value of an investment in the issuer. Investment in private and middle market companies is highly speculative and involves a high degree of risk of credit loss. These risks are likely to increase during an economic recession. Key Person Risk The performance of client accounts is generally reliant on certain key investment personnel employed in managing assets. Termination, disability, death, or departure of key personnel could adversely affect the client accounts and their performance. Non-Investment Grade Risk Securities rated below investment grade, i.e., BA or BB and lower (“junk bonds”), are subject to greater risks of loss of money than higher-rated securities. Compared with issuers of investment grade fixed income securities, junk bonds are more likely to encounter financial difficulties and to be materially affected by these difficulties. Diversification Risk. Client accounts that are not diversified across a wide range of asset classes or issuers could increase the risk of loss and volatility than would be the case if the Client account were diversified across asset classes or issuers because the value of holdings would be more susceptible to adverse events affecting that asset class or issuer. Short Sale Risk Short sale strategies can be riskier than “long” investment strategies. To the extent that a short sale involves the sale of a security that is not owned, the potential losses are unlimited. Derivatives Risk Certain strategies permit the use of derivatives to create market exposure. Futures contracts and other “derivatives” present risks related to their significant price volatility and risk of default by the counterparty to the contract. Derivatives can be illiquid, difficult to price, and leveraged, so that small changes can produce disproportionate losses and subject to counterparty risk to a greater degree than more traditional investments. Because of their complex nature, some derivatives may not perform as intended. As a result, the investment would not realize the anticipated benefits from a derivative or it can realize losses. Derivative Page 10 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  transactions can create investment leverage, which increases a portfolio’s volatility and results in the liquidation of portfolio investment at a disadvantageous time. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. Equity REITs at time are affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs are often affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT can decline). Cybersecurity Risk Arnhold and its service providers may be prone to operational and information security risks resulting from cyber- attacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting Arnhold and its service providers may adversely impact clients. For instance, cyber-attacks may interfere with the processing of transactions, cause the release of private information about clients, impede trading, subject clients and Arnhold to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which clients may invest, which could result in material adverse consequences for such issuers and may cause Arnhold investment in such issuers to lose value. Epidemics and Pandemics and other Events Health crises, such as pandemic and epidemic diseases, as well as other incidents that interrupt the expected course of events, such as natural disasters, war or civil disturbance, acts of terrorism, power outages and other unforeseeable and external events, and the public response to or fear of such diseases or events, have led and may in the future lead to increased market volatility and have an adverse effect on your portfolio’s value. For example, any preventative or protective actions that governments may take in respect of such diseases or events may result in periods of business disruption, inability to obtain raw materials, supplies and component parts, and reduced or disrupted operations for companies and funds held in a client portfolio, as well as for Arnhold and/or other service providers that service the Client’s investment account (e.g., brokers and custodians). The occurrence and pendency of such diseases or events could adversely affect the economies and financial markets either in specific countries or worldwide. Item 9 – Disciplinary Information Item 9 is not applicable to us as we have no reportable material legal or disciplinary events. Item 10 – Other Financial Industry Activities and Affiliations Arnhold is not registered as a broker/dealer, a futures commission merchant, a commodity pool operator, and/or a commodity trading advisor. Mr. Arnhold and certain employees and Managing Directors have interests in or are affiliated with other investment advisers, broker-dealers or financial services firms. This includes Mr. Arnhold and other employees having an ownership interest in First Eagle Investment Management and its affiliates (‘First Eagle”). Client assets are invested in funds and other products managed by these investment advisers, including First Eagle. This creates a conflict of interest and financial incentive for Arnhold to allocate client assets to these investment advisers, including First Eagle. See also the “Form ADV Part 2B – Brochure Supplement” for Mr. Arnhold and each employee. Arnhold mitigates this potential conflict by evaluating other investment products that fit our clients’ investment goals and risks. In addition, under an agreement between Arnhold and First Eagle, First Eagle has agreed to make a payment to Arnhold’s clients in an amount equal to 6 basis points per annum computed on the net assets of the client invested in certain investment funds managed by First Eagle. This payment is made to, and for the benefit of, Arnhold’s clients. First Eagle or Arnhold may terminate this arrangement at any time. Page 11 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Please contact Arnhold if you have any questions concerning this arrangement, including whether or not you are eligible to receive such rebate from First Eagle. Further, Mr. Arnhold serves as a trustee/director of certain First Eagle registered investment companies (“First Eagle Funds”). First Eagle, the investment adviser to such investment companies, compensates Mr. Arnhold for his services with respect to acting as a trustee/director. For his services, Mr. Arnhold receives compensation from First Eagle equal to what those First Eagle Funds pay trustees who are not interested trustees. Based on the nature, source, and amount of the trustee compensation, the Advisor does not believe that this arrangement creates material conflicts of interest for the Advisor; however, the Advisor has determined to nonetheless include the arrangement in the Brochure. Arnhold and its affiliates act as general partner to private investment funds managed by Arnhold and its affiliates. Arnhold Funds GP, LLC, an affiliate of Arnhold, acts as the general partner of certain Private Funds. Arnhold invests certain clients’ assets in these and other investment funds managed by Arnhold and its affiliates. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Arnhold has implemented a Code of Ethics (the “Code”) that governs a number of potential conflicts of interest which exist when Arnhold provides investment advisory services to Clients. The Code is reasonably designed to ensure that Arnhold meets its fiduciary obligation to Clients. The Code imposes restrictions on the personal securities trading of Supervised Persons, as well as reporting requirements. In addition, the Code covers a range of topics that address employee ethics and conflicts of interest, including but not limited to, the acceptance and provision of gifts and business entertainment, outside business activities, political contributions, charitable contributions and privacy. We will provide a copy of our Code upon request. B. Participation or Interest in Client Transactions Arnhold and its affiliates can participate or have an interest in client transactions as described below. Principal and Agency Transactions Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliate, buys from, or sells a security to, a Client. Principal transactions present conflicts of interest which can include the adviser or affiliate earning a fee or earning (or losing) money as a result of the transaction. Arnhold does not generally engage in principal transactions with Clients. Subject to applicable rules and regulations, if Arnhold were to engage in principal transactions, Arnhold would disclose the transaction to the client and obtain the Client’s consent in accordance with Section 206‐3 of the Investment Advisers Act of 1940. Cross Transactions Cross trades involve the transfer, sale or purchase of assets from one Client to another Client which can occur with or without the use of a broker‐dealer. Arnhold may engage in cross trading, where permissible, if it determines that such action would be favorable to both Clients and the terms of the transaction are fair to both parties, in compliance with policies and procedures adopted by Arnhold. Participation or Interest in Personal Trading – Client Trading Arnhold and Supervised Persons can purchase, sell, or otherwise enter into transactions for their own accounts in securities and other instruments. Prior to, or simultaneously with, or after all transactions, Arnhold can, for its Clients, purchase, sell, or otherwise enter into transactions involving any of these same securities or other instruments, and any related securities or instruments (including securities issued by the same issuer, options on such securities or instruments, and instruments convertible into such securities or instruments). Arnhold has adopted the Code of Ethics discussed above to address potential conflicts. Subject to certain restriction, Arnhold and its affiliates and each of their Supervised Persons personally at any times hold, acquire, increase, decrease, Page 12 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  dispose of or otherwise deal with positions in investments in which a client accounts have an interest from time to time. Arnhold has no obligation to acquire for a client account a position in any security which it acquires on behalf of another client, or which an employee acquires for his or her own account. Likewise, client accounts shall not have first refusal, co-investment or other rights in respect of any such investment. Participation or Interest in Personal Trading – Client Recommendations Arnhold and its affiliates and Supervised Persons and their related persons are permitted to buy or sell securities that they also recommend to clients. This includes Arnhold and Supervised Persons acting as general partner, investment adviser or managing member to private funds in which clients are solicited to invest or that are recommended to clients. Arnhold and Supervised Persons can take a position for a Client (including a private investment fund) and affiliates of Arnhold (including Supervised Persons) can take positions for their own accounts in a security contrary to the position held in the same security (e.g., a short versus a long position) by Clients. It is possible that Arnhold, Supervised Persons or their affiliates will, from time to time, cause short sales for a Client to be executed following long transactions for other Clients (including proprietary accounts of Arnhold) in the same security. There is a possibility that Supervised Persons might benefit from market activity by a Client in a security held by a Supervised Person. The Code is designed to mitigate potential conflicts of interest. The nature and timing of actions taken by one or more of Supervised Persons or by one or more of Arnhold’s affiliates, either for their own accounts or for the accounts of Clients, can differ from the nature and timing of actions taken by Arnhold for Client accounts. Arnhold Investments in Private Funds and Other Firm Products Arnhold and its affiliates and their Supervised Persons are investors in Private Funds that are managed by Arnhold and its affiliates. Arnhold and its affiliates also advise separately managed accounts of Arnhold and its affiliates and their Supervised Persons. Arnhold generally reduces or waives fees for Arnhold, its affiliates and their Supervised Persons and family members. Arnhold’s management of accounts with proprietary and related interests alongside nonproprietary Client accounts creates a potential incentive to favor the proprietary and related accounts over nonproprietary accounts in the allocation of investment opportunities, time, aggregation and timing of investments. Arnhold has adopted allocation and other policies and procedures designed to make sure that clients are not systematically disadvantaged. All Clients receive individual investment advice and treatment. Outside Business Activities Certain types of outside affiliations or other activities can pose a conflict of interest. “Outside affiliations” include relationships in which Arnhold personnel serve as an employee, director, officer, partner or trustee of a public or private organization or company other than Arnhold or its affiliated entities, including joint ventures, portfolio investment companies, mutual fund boards and non‐profit, charitable, civic or educational organizations. Those relationships may or may not be related to employment with the firm. See, Item 10 – “Other Financial Industry Activities and Affiliations”. Supervised Persons can serve as an executor, trustee, guardian or conservator. Arnhold permits Supervised Persons to engage in philanthropic, charitable or other similar pursuits. Item 12 – Brokerage Practices Generally, Arnhold receives full discretion from its Clients to choose broker-dealers through whom transactions are executed. This means that Arnhold has discretion to select broker-dealers and negotiate the transaction costs, including commissions or spreads, in the execution of client portfolio transactions. When placing orders for the execution of transactions for Client accounts, Arnhold endeavors to place such orders on a best execution basis. In general, best price, giving effect to commissions and commission equivalents, if any, and other transaction costs, is normally a determining factor in this decision, but the selection may also take into account the quality of brokerage services, including such factors as execution capability, willingness to commit capital, creditworthiness and financial stability, clearance and settlement capability, and the provisions of research and other services. Arnhold’s determination of best execution doesn’t necessarily mean that a client is paying the lowest possible commission rate or spread, as there are several additional important factors to consider when evaluating best execution in client brokerage. The Advisor selects broker-dealers that furnish directly or indirectly through correspondent relationships, third party research or other services which provide in its view appropriate assistance in the investment decision-making process, in a manner that is permitted in accordance Page 13 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  with section 28(e) of the Securities and Exchange Act of 1934, as amended. Research services obtained in this manner is used in servicing all of the Advisor’s clients and is used in connection with accounts other than those that pay commissions to the broker-dealer relating to the research arrangements. Arnhold and its affiliates have discretion to select one or more firms to serve as prime broker (“Prime Broker”) to hold the funds and securities of the Private Funds, and certain separately managed accounts can establish a prime‐brokerage relationship. The Prime Broker can also execute transactions on behalf of Private Funds and separate account clients. Specific trades can be “traded away,” where trades are executed through brokers other than the Prime Broker in order to gain access to greater inventory or better price or execution. Arnhold can also select Prime Brokers it believes will provide specific services beneficial to a Private Fund, allowing the Private Fund to operate more effectively and efficiently, including providing Arnhold with electronic access to account information and trade confirmations and investor reporting. With Arnhold’s prior agreement, a client may direct that all or a certain portion of the transactions for its account (a “directed brokerage account”), be executed through specific broker-dealers (each, a “directed broker”). (Arnhold does not generally accept directed brokerage arrangements.) (Arnhold does not generally accept directed brokerage arrangements.) In selecting the directed broker, the client is solely responsible for negotiating commission rates and other transaction costs with the directed broker. Clients with directed broker arrangements may not receive best execution since the directed brokerage may result in higher commissions than might be the case if we were empowered to negotiate commission rates or select broker-dealers based on best execution. We are not required to execute any transaction through the directed broker if we reasonably believe that doing so could result in a breach of our fiduciary duty. By instructing Arnhold to execute transactions through the directed broker (including expense reimbursement and commission recapture arrangements), the Client may not necessarily obtain commission rates and execution as favorable as those that would be obtained if Arnhold were able to place transactions with its other Clients. The client also may forego benefits that we may be able to obtain for our other clients through, for example, negotiating volume discounts or block trades. In addition, directed brokerage can distract us from our normal trading process and represents a conflict of interest in our efforts to obtain best execution for all clients and to obtain adequate research. If the brokerage firm to which Arnhold is directed by the client to execute trades is not on our approved list of brokers, the client may be subject to additional credit and settlement risks. Recommendation of Custodian[s] Clients assets are typically held by a “qualified custodian” pursuant to a separate custody agreement. For separatelymanaged accounts, the Client shall engage the Custodian and authorize Arnhold to manage its account[s] for the provision of investment mamagement services. Arnhold will generally recommend that Clients establish their account[s] at Bank of America, N.A or J.P. Morgan. However, not all advisers require their clients to direct brokerage. Clients should understand that by directing Arnhold to executed transactions through a designated broker the client may be unable to achieve most favorable execution of transactions, and this practice may cost clients more money. Our recommendation of a custodian is based on the nature, cost or quality of custody and brokerage services provided to Clients. We strive to act in your best interests at all times. Please see Item 14 below. Other custodians may from time to time be recommended depending on a particular client’s needs. Soft Dollars, Research and Commission Sharing Under certain circumstances consistent with applicable law and regulation, Arnhold can select broker-dealers to execute clients’ transactions that furnish Arnhold with proprietary and third-party brokerage and research services that are paid for with commissions generated by transactions. These brokerage and research services that Arnhold receives are consistent with the provisions of Section 28(e) of the Securities Exchange Act of 1934, as amended. Underlying managers and third party investment advisers selected by Arnhold also can use “soft dollars” both within and outside of the safe harbor of Section 28(e) of the Securities Exchange Act of 1934, as amended, to obtain both research and non-research products and services. Arnhold can direct execution of Client transactions, including principal or agency transaction in over-the-counter ("OTC") securities, to certain brokers in recognition of their furnishing investment research and brokerage services, including, but not limited to: information and analyses concerning specific securities, companies or Page 14 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  sectors; meetings with company executives; market, financial and economic studies and forecasts; discussions with research personnel; wire services, appraisals or evaluations of potential or existing investments; certain financial and industry publications; statistical and pricing services; along with software, databases and other services utilized in the investment management process. The availability of such research and brokerage services creates a conflict between the interests of the client in obtaining the lowest cost execution and Arnhold’s interest in obtaining services. When Client brokerage commissions are used to obtain research or other products or services, Arnhold receives a benefit because it does not have to produce or pay for the research, products or services. Arnhold may have an incentive to select or recommend a broker-dealer based on our interest in receiving research or other products or services, rather than on our clients’ interest in receiving most favorable execution. Research and brokerage services obtained from brokers are used to benefit all clients as a group and not solely or necessarily for the benefit of the particular Client whose trades are handled by the broker providing services. Therefore, a Client can pay commissions for providing services that are not used directly in the management of such Client's account. Clients can, on the other hand, benefit from research and brokerage services obtained from brokers to whom Clients pay little or no commissions. Where appropriate, Arnhold can allocate mixed-use products and services as payable in cash by Arnhold (to the extent not utilized by Arnhold as brokerage or research) or through commission costs (to the extent utilized by Arnhold as brokerage or research). In allocating brokerage commissions from mixed-use items, Arnhold makes a good faith determination as to the product or service's relation to the investment decision-making process. The receipt of mixed-use products and services and the determination of the appropriate allocation creates a potential conflict of interest between Arnhold and its Clients. Arnhold may cause Client accounts to pay brokers a commission (or markup or markdown) in excess of the amount of commission (or markup or markdown) another broker qualified to execute such transactions would have charged for effecting the same transactions, absent the research or brokerage services. Arnhold will do so only where it determines in good faith that the commission is reasonable in relation to the brokerage and research services provided by the broker. A significant portion of brokers through whom Arnhold executes orders provide research products and services to Arnhold. These products and services generally include: economic, industry, municipal, sovereign (U.S. and non-U.S.), legal, or political research reports; market color; company meeting facilitation; expert network consultations and investment recommendations. Arnhold may request that a broker provide a specific proprietary or third-party product or service. Certain brokers that provide research and brokerage services to Arnhold can obtain these products and services from a third party. Arnhold may obtain quotes and other market data information in this manner to eliminate or diminish potential conflicts of interest. Certain brokers can also invite investment personnel of Arnhold to attend investment conferences sponsored by such brokers. Because brokers can combine the costs of their proprietary research services with the cost of securities execution services in the form of “bundled” commission rates, it can be difficult to quantify the cost of these research services. Brokerage Referrals - Arnhold does not select brokers in exchange for Client referrals. Aggregating and Allocating Trades As described above, we serve as the investment manager or investment adviser to certain private funds and separately managed accounts. Persons associated with our firm have significant investments in these funds. Arnhold and its affiliates manage Client accounts that invest in similar or different investments. The management of these Client accounts has the potential to conflict in some circumstances. For example, we can determine that an investment opportunity in a Client account is appropriate for a particular Client, but not for another. We have different types of Clients, including private funds and separate accounts, and our Clients can be subject to different regulations and tax regimes. Clients tend to have different investment strategies, objectives and restrictions and can be subject to different terms. These terms include, but are not limited to, the following: investor lock-up periods, management and performance fees, liquidity terms, rights to receive information regarding the portfolio and such other rights as may be negotiated by investors or other accounts. As a result, this can cause an incentive to favor one account over another when making investment decisions. Page 15 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  There can be instances when allocating investments among clients in which some Clients participate in certain opportunities while other Clients do not. Where accounts have competing interests in a limited investment opportunity, we generally do not allocate investment opportunities pro rata among Clients but rather allocate investment opportunities on the basis of numerous other considerations, including, without limitation, a Client’s cash flow, investment objectives and restrictions, participation in other opportunities, compliance with applicable laws, and tax concerns as well as the relative size of different accounts’ same or comparable portfolio holdings. It is important to note that it is our policy to allocate, to the extent operationally and otherwise practical, investment opportunities to each client on a fair and equitable basis relative to our other Clients. To reasonably ensure that accounts of all Clients and portfolios are treated fairly in the event we place orders for the same security for more than one account at or about the same time, we can combine orders placed on behalf of Clients (including advisory accounts in which Arnhold and its affiliates and their employees have an interest) for the purpose of negotiating brokerage commissions or obtaining a more favorable price. We seek to allocate investments across applicable Client accounts in a manner that is fair and equitable on an overall basis to all accounts. These orders are generally averaged as to price and allocated to accounts in amounts according to each account's daily purchase or sale orders or on some other equitable basis. We are not required to allocate on a pro rata basis if, in our sole discretion, we believe that another manner of allocating investments is fair and equitable on an overall basis to all applicable clients under the circumstances, taking into account relevant characteristics of each applicable Client. Although the aggregation of trade orders is expected to benefit Clients overall, aggregation can, in any circumstance, disadvantage a particular Client, as mathematical precision may not be attainable. There can be circumstances in which we determine not to aggregate Client trade orders that otherwise could have been aggregated or in which aggregation is not feasible. Item 13 – Review of Accounts A. Frequency of Reviews Investments in Client accounts are monitored on a regular and continuous basis by Advisory persons of Arnhold and periodically by Christa M. Dorrego, Managing Director. Formal reviews are generally conducted at least annually but can be more or less frequent depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews can be conducted more or less frequently at the Client’s request. Accounts can be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Arnhold if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews can be triggered by material market, economic or political events. Item 14 - Client Referrals and Other Compensation A. Compensation Received by Arnhold Arnhold does not compensate any persons for client referrals, nor do we receive any additional compensation beyond that described in this Brochure. B. Client Referrals from Solicitors Arnhold does not engage solicitors for Client referrals. Item 15 – Custody Arnhold is deemed to have “custody” of client funds or securities within the meaning of Rule 206(4)-2 under the Investment Advisers Act of 1940 because Arnhold debits advisory fees directly from clients’ accounts. Arnhold has obtained assurances from clients’ custodians that quarterly account statements are provided to clients indicating the amounts of any cash and securities in the account as of the end of the statement period and any transactions in the account during the statement period. Clients should receive at least quarterly statements from Page 16 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  the broker dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. Clients should carefully review these statements and compare such official custodial records to any account statements that Arnhold provides. Arnhold’s statements can vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients are advised to notify Arnhold promptly if account statements are not received from their respective account’s custodian on at least a quarterly basis. Because Arnhold and its affiliates serve as general partner or managing member of certain private funds, Arnhold is deemed to have constructive “custody” over the assets of these private funds within the meaning of Rule 206(4)-2 under the Investment Advisers Act of 1940. To comply with this Rule, these private funds will distribute to investors audited financial statements within 120 days following the private fund’s fiscal year end (180 days in the case of any fund of funds). Investors in the private funds who have not received audited financial statements on a timely basis should contact Arnhold without delay. Arnhold generally does not accept or maintain physical custody of any Client accounts, except for authorized deduction of the Advisor’s fees. Typically, Clients must place their assets with a “qualified custodian” engaged by the Clients to retain their funds and securities and direct Arnhold to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Arnhold to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices”. Item 16 – Investment Discretion Arnhold generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales can be subject to specified investment objectives, client directions, guidelines, or limitations previously set forth by the Client and agreed to by Arnhold. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment management agreement containing all applicable limitations to such authority. All discretionary trades made by Arnhold will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Arnhold accepts proxy-voting responsibility for any Client. The Advisor will receive proxy statements directly from the Custodian. Arnhold has retained an independent third-party proxy voting service provider, Institutional Shareholder Services Inc. (“ISS”), to assist it in coordinating, administering (including the maintenance of required records), processing, and voting of certain client proxies. These services also include proxy voting recommendations and research. Arnhold generally uses ISS’s Standard Guidelines (the “Standard Guidelines”). Each proxy voted by Arnhold will be instructed in accordance with the Standard Guidelines, unless Arnhold believes that it is in the best interest of Clients to vote otherwise. Arnhold takes into consideration issuers’ response to proxy advice it receives from proxy advisers regarding how to vote on a particular proposal. At times, Arnhold may not be able to vote proxies on behalf of clients, including when clients’ holdings are in countries that restrict trading activity around proxy votes. In addition, Arnhold may abstain from voting proxies for its clients’ accounts under circumstances, including when the economic effect on shareholders’ interests or the value of the portfolio holding is indeterminable or insignificant. Arnhold seeks to identify any conflicts of interests between the interests of our clients and our own interests within our proxy voting process. If we determine that Arnhold or one of our employees faces a material conflict of interest in voting a proxy, our procedures generally provide for ISS as an independent party to determine the appropriate vote. In the case of a conflict, we will seek to vote the proxy in the best interest of clients. Clients may request from Arnhold how proxies have been voted on behalf of their account. A copy of Arnhold’s proxy voting policy and procedures is available upon request. All requests should be directed to the Chief Compliance Officer by calling (212) 651-3724. Item 18 – Financial Information Page 17 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Neither Arnhold, nor its management, have any adverse financial situations that would reasonably impair the ability of Arnhold to meet all obligations to its Clients. Neither Arnhold, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Arnhold is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Page 18 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Privacy Policy Effective: March 20, 2021 Our Commitment to You Arnhold LLC (“Arnhold” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Arnhold (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Arnhold does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number(s) Income and expenses E-mail address(es) Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications, subscription agreements and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Page 19 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  How do we share your information? An RIA shares Client personal information to effectlively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, attorneys, accountants, auditors, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you and to comply with federal, state or local laws, rules and other applicable legal requirements , including but not limited to: processing transactions; general account maintenance; in compliance with a properly authorized civil, criminal or regulatory investigation, or subpoena or summons by federal, state or local authorities; and credit reporting. No Not Shared Yes Yes Marketing Purposes Arnhold does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Arnhold or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). What We do with Personal Information about Our Former Customers If you decide to discontinue doing business with us, we will continue to adhere to this privacy policy with respect to the information we have in our possession about you and your account following the termination of our relationship. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (212) 651-3700 or at info@arnholdllc.com. Page 20 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Form ADV Part 2B – Brochure Supplement for John P. Arnhold Managing Director Effective: August 20, 2024 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John P. Arnhold (CRD# 1012444) in addition to the information contained in the Arnhold LLC (“Arnhold” or the “Advisor”, CRD# 290117) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Arnhold Disclosure Brochure or this Brochure Supplement, please contact us at (212) 651-3700 or by email at info@arnholdllc.com. Additional information about Mr. Arnhold is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1012444. Page 21 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Item 2 – Educational Background and Business Experience John P. Arnhold, born in 1953, is dedicated to advising Clients of Arnhold as a Managing Director. Mr. Arnhold earned a B.A. in English Literature from University of California, Santa Barbara in 1975. Employment History: 2017 to Present 2017 to Present Managing Director, Arnhold LLC Managing Member, Arnhold Management LLC Mr. Arnhold is a director of First Eagle Holdings, Inc. and is a trustee of certain registered investment companies whose investment adviser is First Eagle Management, LLC. Prior to 2017, he was a director of First Eagle Investment Management, LLC for a number of years. He held a number of positions with First Eagle Investment Management prior to March 2016 for a number of years, including at various times, Co-President and Co-CEO First Eagle Holdings, Inc. and CEO (prior to 2010), CIO and Chairman, First Eagle Investment Management, LLC. Item 3 – Disciplinary Information Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. Mr. Arnhold has no instances to disclosure. However, we do encourage you to independently view the background of Mr. Arnhold on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1012444. Item 4 – Other Business Activities Mr. Arnhold is affiliated with Arnhold Management LLC, the holding company for Arnhold LLC and the companies and partnerships that are affiliated with Arnhold LLC and Arnhold Management LLC. Mr. Arnhold also has interests in other investment advisers (including ownership interests in First Eagle Investment Management, LLC and its affiliates (“First Eagle”)), broker-dealers or financial services firms. Client assets are invested in funds and other products managed by these investment advisers. This creates a conflict of interest and financial incentive for Arnhold to allocate client assets to these firms, including First Eagle. Mr. Arnhold serves as a trustee/director of certain First Eagle registered investment companies (the “First Eagle Funds”). First Eagle, the investment adviser to those First Eagle Funds, compensates Mr. Arnhold for his services with respect to acting as a trustee/director. For his services, Mr. Arnhold receives compensation from First Eagle equal to what those First Eagle Funds pay trustees who are not interested trustees. Item 5 – Additional Compensation Mr. Arnhold has additional business activities that are detailed in Item 4 above. Item 6 – Supervision Arnhold maintains compliance policies and procedures designed to detect and prevent violations of federal securities laws, including a Code of Ethics, and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Arnhold. Employees are required to certify compliance with these policies and procedures annually. Page 22 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Mr. Arnhold serves as a Managing Director of Arnhold. The managing directors of Arnhold oversee operations and monitor advice. You may contact the managing directors of Arnhold and Arnhold’s Chief Compliance Officer, Mark Goldstein, at (212) 651-3700. Page 23 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Form ADV Part 2B – Brochure Supplement for Timothy L. Tabor Managing Director Effective: March 7, 2024 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Timothy L. Tabor (CRD# 1079602) in addition to the information contained in the Arnhold LLC (“Arnhold” or the “Advisor”, CRD# 290117) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Arnhold Disclosure Brochure or this Brochure Supplement, please contact us at (212) 651-3700 or by email at info@arnholdllc.com. Additional information about Mr. Tabor is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1079602. Page 24 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com  Item 2 – Educational Background and Business Experience Timothy L. Tabor, born in 1953, is dedicated to advising Clients of Arnhold as a Managing Director. Mr. Tabor earned a BA and a MA in Politics, Philosophy, and Economics from Oxford University in 1976. Mr. Tabor also earned a Bachelor of Business Administration from University of Oklahoma in 1974. Employment History: Managing Director, Arnhold LLC Senior Vice President, First Eagle Investment Management, LLC Portfolio Manager, Arnhold and S. Bleichroeder Holdings, Inc. 2017 to Present 2017 to Present 2002 to 2017 2002 to 2017 Item 3 – Disciplinary Information Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. Mr. Tabor has no instances to disclosure. However, we do encourage you to independently view the background of Mr. Tabor on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1079602. Item 4 – Other Business Activities Mr. Tabor is affiliated with Arnhold Management LLC, the holding company for Arnhold LLC and the companies and partnerships that are affiliated with Arnhold LLC and Arnhold Management LLC. Item 5 – Additional Compensation Mr. Tabor has additional business activities that are detailed in Item 4 above. Item 6 – Supervision Arnhold maintains compliance policies and procedures designed to detect and prevent violations of federal securities laws, including a Code of Ethics, and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Arnhold. Employees are required to certify compliance with these policies and procedures annually. Mr. Tabor serves as a Managing Director of Arnhold. The managing directors of Arnhold oversee operations and monitor advice. You may contact the managing directors of Arnhold and Arnhold’s Chief Compliance Officer, Mark Goldstein, at (212) 651-3700. . Page 25 Arnhold LLC 1370 Avenue of the Americas, 31st Floor, New York, NY 10019-4602 Phone: (212) 651-3700 * Fax: (646) 365-3065 E-Mail: info@arnholdllc.com